Pemigewasset
Wilderness Thoreau Falls Trail Bridge United States Department of Agriculture Removal Project
Town of Lincoln, Grafton County Forest Service Eastern Region New Hampshire Environmental Assessment
Pemigewasset Ranger District
May 2018
For Information Contact: Thomas Giles White Mountain National Forest 71 White Mountain Drive
White Mountain National Forest Campton, NH 03223 Phone: 603 536-6234 Fax: 603 536-3685 http://www.fs.usda.gov/projects/whitemountain/landmanagement/projects Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
This document is available in large print. Contact the Pemigewasset Ranger District White Mountain National Forest 603-536-6100 TTY 603-536-3665
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions partici- pating in or administering USDA programs are prohibited from discriminating based on race, col- or, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance pro- gram, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or ac- tivity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.
Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English.
To file a program discrimination complaint, complete the USDA Program Discrimination Com- plaint Form, AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assis- tant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected] .
USDA is an equal opportunity provider, employer and lender.
Cover photo: Thoreau Falls Bridge showing delamination of the stringers. (WMNF photo)
Printed on Recycled Paper
ii Thoreau Falls Trail Bridge Removal Project– Draft Decision Notice and FONSI
Table of Contents
Chapter 1: Purpose and Need ...... 1 Introduction ...... 1 Background ...... 1 Management Direction ...... 2 Bridge Condition, Location, and Access ...... 5 Purpose and Need ...... 8 Decision to Be Made ...... 9 Public Involvement ...... 10 Issues ...... 11
Chapter 2: Alternatives ...... 13 Alternative 1: Proposed Action – Removal of Bridge without Replacement ..13 Alternative 2: Removal of Bridge with Replacement...... 13 Alternatives Considered but Not Analyzed in Detail ...... 15
Chapter 3: Environmental Effects ...... 17 Recreation...... 19 Wilderness ...... 26
Other Agencies Consulted ...... 30 References ...... 30 Appendix A - Public Comments and Forest Service Responses ...... A-1 Safety Concerns Summary Response ...... A-1
iii Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
TThoreauhoreau Falls TrailFalls Bridge Bridge
Lincoln Woods LincolnVisitor Center Woods Visitor Center
Figure 1. The Thoreau Falls Bridge is located within the Pemigewasset Wilderness.
iv White Mountain National Forest – Pemigewasset Ranger District
Figure 2. The shortest access point to the Thoreau Falls Bridge is from Lincoln Woods and requires a ford across Cedar Brook.
v Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Figure 3. Wilderness zones are used to establish management goals and visitor expectations within different areas of wilderness. A small portion of the Thoreau Falls trail is zoned C to accommodate the bridge which is a developed feature in the Pemigewasset Wilderness.
vi White Mountain National Forest – Pemigewasset Ranger District
Disclaimer: The Forest Service uses the most current and complete data available. The accuracy of GIS and other data products (e.g., tables and figures) may vary. These data may be: developed from sources differing in accuracy, accurate only at certain scales, based on modeling, interpretation, or estimates, incomplete while being created or revised, etc. Using GIS or other products for purposes other than those for which they were created, may yield inaccurate or misleading results. The Forest Service reserves the right to correct, update, modify, or replace GIS products without notification.
vii Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
This page left blank
viii White Mountain National Forest – Pemigewasset Ranger District
Chapter 1: Purpose and Need Introduction
The Pemigewasset Ranger District of the White Mountain National Forest (WMNF) proposes the Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal project (Thoreau Falls Bridge Project). The project is in the Pemigewasset Wilderness near the Town of Lincoln, Grafton County, New Hampshire (Figure 1). The Thoreau Falls Bridge is located near the center of the 45,000 acre wilderness (Figure 2). The goal of this project is to address public safety concerns related to potential failure of the bridge and whether or not it is needed in the Pemigewasset Wilderness (Figure 4).
Figure 4. Time and storm damage have resulted in delamination and cracking of the stringers and sagging of the Thoreau Falls Bridge structure. For safety reasons, the bridge has a one-person at a time weight limit. Background
The land that includes the project area became part of the WMNF in 1936. Prior to that, the area was privately owned and extensively logged. The logging operations were supported by a network of logging railroads and camps. Following acquisition, many of the railroad beds and skid roads were converted to trails and supported recreational activities including hiking and backpacking.
1 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
The Thoreau Falls Bridge was constructed in 1962 to provide recreational hikers with a crossing of the East Fork of the Pemigewasset River and is part of the Thoreau Falls Trail (Figure 2). In a Forest Service Memo dated March 19, 1958 the Bridge was being considered with recognition that crossing the East Branch was “quite a river to cross” and during high water presented a “crossing problem.” The memo did not mention incidents of hikers being injured while crossing the East Fork at this location, nor are there records of crossing-related injuries prior to bridge installation. A recent assessment by Forest Service staff determined that wading across the river at this location is possible during typical flows encountered in summer and fall, but the risk levels increase substantially during and shortly after storm events and during snow melt when stream flows are moderate to high. The U.S. Congress designated the Pemigewasset Wilderness in 1984, adding it to the National Wilderness Preservation System (Public Law 98- 323). Management Direction
The following management directives are provided with emphasis added:
• 1984 N.H. Wilderness Act and the Wilderness Act of 1964: The Wilderness Act of 1964 defines wilderness in Section 2 (c) as, “A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value.” In Section 4(b & c) it states, “(b) Except as otherwise provided in this Act, each agency administering any area designated as wilderness shall be responsible for preserving the
2 White Mountain National Forest – Pemigewasset Ranger District
wilderness character of the area and shall so administer such area for such other purposes for which it may have been established as also to preserve its wilderness character. Except as otherwise provided in this Act, wilderness areas shall be devoted to the public purposes of recreational, scenic, scientific, educational, conservation, and historical use…(c) Except as specifically provided for in this Act, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this Act and, except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area.” Emphasis added. • Congress did not include any special provisions or restrictions in the legislation that created the Pemigewasset Wilderness.
• 36 CFR 293.2 states “Except as otherwise provided in the regulations in this part, National Forest Wilderness shall be so administered as to meet the public purposes of recreational, scenic, scientific, educational, conservation, and historical uses; and it shall also be administered for such other purposes for which it may have been established in such a manner as to preserve and protect its wilderness character. In carrying out such purposes, National Forest Wilderness resources shall be managed to promote, perpetuate, and, where necessary, restore the wilderness character of the land and its specific values of solitude, physical and mental challenge, scientific study, inspiration, and primitive recreation. To that end: (a) Natural ecological succession will be allowed to operate freely to the extent feasible. (b) Wilderness will be made available for human use to the optimum extent consistent with the maintenance of primitive conditions. (c) In resolving conflicts in resource use, wilderness values will be dominant to the extent not limited by the Wilderness Act, subsequent establishing legislation, or the regulations in this part.” Emphasis added.
• Forest Service Policy which appears in Forest Service Manual 2320 directs
3 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
that replacement of bridges only occur when crossing afoot during the primary season of public use cannot be negotiated safely (FSM 2320 p. 20).
• Forest Service Handbook, FSM 2320, Wilderness Management provides the following related to providing appropriate access (FSM 2323.13f2 p. 20): 2. Bridges. Design bridges to minimize the impact on the wilderness. Select locations that minimize the size and complexity of the structure. Provide or replace bridges only: a. When no other route or crossing is reasonably available.
b. Where the crossing, during the primary season of public use, cannot be negotiated afoot safely, or cannot be forded by horses safely.
c. Where unacceptable bank damage will occur from visitors seeking a crossing.
d. Where flood waters frequently destroy or damage less sturdy structures.
• WMNF Land and Resource Management Plan (LRMP) Wilderness Management Area Direction
o G-5: “Only those improvements needed to protect and manage the Wilderness resource, or that address an unusual and extraordinary public safety hazard should be constructed.”
o G-6: “The number and type of improvements, such as trails, footbridges, and signs should be kept to a minimum…”
• The Forest Plan objective for Wilderness is to manage the areas to standard in accordance with the Wilderness Management Plan (Forest Plan Appendix E) and national direction. “These lands (wilderness) are managed to allow natural processes to continue with minimal impediment, to minimize the effects and impacts of human use, to provide primitive and unconfined recreation opportunities…” The Forest Plan allocated lands within wilderness to one of four zones. The zones were developed to provide a balance between visitor use and preservation. The zones provide direction in the overall wilderness management strategy with each zone providing a unique characteristic in
4 White Mountain National Forest – Pemigewasset Ranger District
terms of ecology, social conditions, and management needs. Zone A includes areas without trails and generally has the lowest use while Zone D generally the highest-use (Forest Plan pp. 3-9, E-4 to E-9). Zones along trail corridors extend 250 feet on either side of the trail to account for the characteristics found along the trail (Table 1).
Table 1. Wilderness management zones provide expectations for how areas of the wilderness will be managed and the types of experiences visitors should expect to encounter, including water crossings per Forest Service Handbook (FSH 2309.18 p. 9) Zone Description
A Offers the highest degree of challenge, self-reliance, and risk; 500’ or more from all trails; no maintained trails or structures
B Offers a high degree of challenge, self-reliance, and risk; primitive trails and trail structures; natural fords
C Offers a high degree of challenge and risk, and lower degree of self-reliance than Zones A and B; trails with natural fords; bridges may exist for public safety and resource protection only
D Offers a moderate degree of challenge and risk, and lower degree of self- reliance than other Zones; trails with natural fords; bridges may exist for public safety and resource protection only
Bridge Condition, Location, and Access
The 60-foot long bridge is a single span “full tree length” log stringer bridge. It has a wooden deck, wooden rails and concrete abutments and is of simple utilitarian design. The log stringers were treated with creosote prior to installation. The bridge has deteriorated to the point that there is currently a single-hiker weight limit (Figure 5). Inspections over the years note various damage and minor repairs and include sketches and photographs of the bridge. Natural decay and storm damage have affected the bridge. Several layers of the log stringer have shredded off and there is an approximately 10 inch deep (one- half of the beam diameter) crack present at the midsection of the log (Figure 8). Warping of deck caused by deflection in stringers The shortest route to the bridge is a relatively flat 6.6 mile hike from the Lincoln
5 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Woods parking lot off the Kancamagus Highway (Route 112) (Figure 2). The wilderness boundary is 2.8 miles north of the Lincoln Woods trailhead and 3.8 miles south of the bridge. The Thoreau Falls Trail was categorized as a moderate use trail during the 2005 Forest Plan revision. Trail counter data recorded during Spring/Summer 2016 at the bridge crossing found an average of less than three people per day. The primary seasons of use are summer and fall, although the trail gets some winter use.
The section of river where the Thoreau Falls Trail crosses is just upstream of the confluence of the North Fork of the East Branch of the Pemigewasset River. The crossing site is an alluvial reach, which is a segment of river where the stream flow decreases enough for sediment and other materials to be deposited. The alluvial deposits form a floodplain that is flooded by the river relatively frequently. As is common among White Mountain rivers and streams, this section of river is prone to rise and fall quickly in response to storm events. Data collected at the nearest USGS gauging station located downstream of this crossing in Lincoln, NH, show discharges rates drop by half of peak within 12 hours after a storm event. High flow events can occur at any time of year. Except at very low flows, the river is too large and the boulders are too far apart to be able to cross by rock-hopping. At times of moderate to high flows the river could be difficult and dangerous to cross. During times of moderate to low flow, visitors would need to evaluate their ability and comfort level to determine if they had the experience and comfort level to cross the river safely. Crossing would have a low risk during times of low to moderate flow. Visitors approaching the bridge from either north or south must negotiate several unbridged river and stream crossing prior to reaching the bridge. Storm events have a similar effect on flows at these crossing as those described above for the Thoreau Falls Bridge location. Visitors coming from the south, including Lincoln Woods, via the East Side and Wilderness Trails must cross Cedar Brook (Figure 5) and two smaller unbridged crossings that require rock hopping or fording.
Visitors coming from the north, including Zealand, via the Ethan Pond Trail must cross the upper North Fork Pemigewasset River and its tributaries, including crossing above Thoreau Falls (Figure 6), 4 times without a bridge.
6 White Mountain National Forest – Pemigewasset Ranger District
Figure 5. Crossing at Cedar Brook (August 23, 2016).
Figure 6. Crossing above Thoreau Falls. (August 23, 2016). The bridge, and a ½ mile section of the Thoreau Falls Trail beginning at the junction with the Wilderness Trail, is in Wilderness Zone C (Figure 3, Table 1). The remaining 4.6-miles of trail to the junction with the Ethan Pond Trail is Zone B, accounting for 90% of the trail’s length. The small section of trail containing the bridge was designated as Zone C because of the presence of the bridge. Visitors to Zone B are advised to “plan ahead and be well prepared for challenging travel and primitive recreation opportunities with a high level of risk. Self-reliance and proficient navigation skills may be needed to facilitate travel on minimally maintained trails. These paths may be exceptionally hard to follow under winter conditions” (Forest Plan p. E-27). Whereas visitors to Zone C are advised to “plan ahead and be well prepared for challenging travel and semi- primitive recreation opportunities with a moderate level of risk. Navigation skills will better facilitate travel on moderately developed trails especially under winter conditions” (Forest Plan p. E-28).
7 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Purpose and Need
The purpose of the proposed Thoreau Falls Trail Bridge Project is to address the failing condition of the log bridge as it relates to public safety and its presence in wilderness. The bridge has deteriorated over time and it sustained damage during Tropical Storm Irene in 2011. Following Tropical Storm Irene, a Forest Service engineer completed a field inspection of the bridge. Based on the inspection, the engineer recommended that the bridge be removed from service due to the poor condition of the superstructure—the log beams supporting the decking were tattered, sagging, cracking (~½ the diameter of one beam), and showing a substantial difference in beam deflection (Figure 4, Figure 7). If the bridge were to remain in service, the engineer recommended that no more than one person cross the bridge at a time and to do so slowly to avoid accentuating forces on the structure. A follow-up field inspection completed in 2015 reinforced those recommendations and instituted annual field inspections as long as the bridge remains in service. The bridge remained in use and was signed with a recommendation for only one-person crossing at a time until summer 2018. In August 2017, WMNF engineering staff performed their annual safety inspection of the bridge and recommended the bridge be permanently closed to the public beginning summer 2018 due to further cracking, rotting, the overall failed condition to the wooden structure, and the safety risk it poses to the public. This project is needed to address the potential public safety concerns associated with the continued use of the bridge. The Wilderness Act defines wilderness as an area that provides “outstanding opportunities for solitude or a primitive and unconfined type of recreation.” In addition wilderness is designated “for the use and enjoyment of the American people” and recreation is one of the six public purposes of wilderness. In most areas visitor use of wilderness would be extremely limited without some type of trail for access. While the Wilderness Act defines wilderness as “undeveloped”, trails are defined as an acceptable improvement. Trail standards for wilderness typically reflect a more challenging opportunity and minimal imprint on the land. The need for structures such as bridges is minimized through design and location and structures are used only for the protection of the wilderness resource and not for the convenience of the visitor. Under the Wilderness Act, the Forest Service is required to insure that projects are reviewed and that actions taken to meet the purpose and need of projects are
8 White Mountain National Forest – Pemigewasset Ranger District
determined to be “…necessary to meet minimum requirements for the administration of the area for the purpose of this Act” (16 USC 1131). The Thoreau Falls Bridge predates designation of the Pemigewasset Wilderness. This proposal and analysis is needed to determine what, if any structure is necessary for crossing of the East Branch of the Pemigewasset River as part of the Thoreau Falls Trail.
Figure 7. Cracks and delamination of stringers. Decision to Be Made
Based on the analysis in this EA, the project record, comments from the public and contributions from the interdisciplinary team, Pemigewasset District Ranger will decide whether: • to implement the action as proposed or as described in an alternative and under what conditions and design features the decision should be im- plemented, • the decision meets all applicable laws, regulations, and policies, and if it is consistent with the Forest Plan or if an amendment is needed, and • to issue a Finding of No Significant Impact or to prepare an Environmen- tal Impact Statement (EIS).
9 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Public Involvement
This project has been listed on the quarterly WMNF Schedule of Proposed Actions (SOPA) since July 2015, and it will remain on the SOPA until after a decision is made. On August 4, 2015 a Scoping Report was released to the public and it was published to the WMNF website: http://www.fs.fed.us/nepa/nepa_project_exp.php?project=46602
Notification of the availability of the report (via email and letter) was sent to the list of individuals and organizations that commented on the Pemigewasset Bridge Removal Project (Decision Memo signed September 11, 2009). The Forest issued a press release, offered two public field trips, there was a front-page article in the Concord Monitor, an article on WMUR’s website, and a story on New Hampshire National Public Radio. Because of the amount of interst in the project, the Forest offered two public hikes to the bridge, one on September 26, and one on October 3, 2015. During and after public scoping the Forest received 147 comments from individuals, elected officials, private and public organizations. Those that supported the Proposed Action focused on adherence to the Wilderness Act and protection and restoration of the areas wilderness character. Those that supported replacement focused on the bridge’s role in providing access and a safe crossing over the East Branch of the Pemigewasset River.
The assessment of the project’s environmental affects was originally proposed to be completed as a Categorical Exclusion under 36 CFR 220.6(e)(1): Construction and reconstruction of trails. Due to the amount of interest and issues raised during public scoping, the District Ranger made the decision to conduct an environmental assessment to ensure a full analysis of tradeoffs and concerns. He felt that this process would provide an opportunity to more fully address the issues raised by the public. Interested members of the public received an update on the project, including the decision to conduct an EA, in December 2015. A Draft Environmental Assessment was prepared and released in a Public Notice published in The Union Leader on August 7, 2017 and made available for public comment for 30 days. During the 30 day comment period, the Forest received 41 letters which are captured without salutations or attribution in Appendix A - Response to Comments, of this document. The Forest’s response to these comments are available also as part of this Appendix. As a result of these
10 White Mountain National Forest – Pemigewasset Ranger District
comments, the final Environmental Assessment included a recognition of climate change and its potential impacts on the alternatives. Additionally, further explanation was provided on the adaptive management strategy responding to unnecessary resource impacts, if they occur, due to the crossing sites resulting from Alternative 1. Concerns for hiker safety with Alternative 1 were voiced repeatedly in many of the comments received and subsequently these concerns were addressed in a comprehensive response found in the introduction to Appendix A. Issues
The Interdisciplinary Team and the District Ranger considered all comments to identify issues and generate appropriate responses. Issues are statements that describe cause-and-effect relationships between the proposed action and its effects. Identifying and addressing issues early in the analysis provides the opportunity to reduce potential adverse effects and compare trade-offs among effects and alternatives to inform the public and the Responsible Official (FSH 1909.15 Ch. 12.4). Public concerns about the effects of the proposed activities generated the following issues (see also Project Record): Issue #1:
Public safety: Some commenters expressed concern that visitor safety would be compromised as a result of people having to ford the river or having to make potentially long backtracks that they may not be prepared for if they were unable to ford the river. Resolution:
• Develop Alternative 2 – Remove Bridge with Replacement
Measurement Indicator
• Assess the potential effects to public safety by estimating the number of days each month when the flow rates are expected to be too high to ford the river safely. This provides an estimate of when an attempted ford would likely be unsafe and/or visitors would have to backtrack to their trailhead of origin rather than crossing at that time and location.
• Assess Search and Rescue (SAR) data provided by NH Fish & Game to determine the frequency of emergency responses within the Pemigewasset Wilderness and the project area. SAR data provide a
11 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
means to assess the current location and frequency of SARs on the Forest relative to the location of Thoreau Falls Bridge and an opportunity to project the potential for increased SARs under the two alternatives. Issue #2:
Access: Some commenters expressed concern that removing the bridge without replacing it would limit access; summer and winter users who were not comfortable fording the river would feel obligated to choose other trails that did not require a bridgeless river crossing effectively limiting their access to this trail.
Resolution:
• Develop Alternative 2 – Remove Bridge with Replacement
Measurement Indicator
• Compare the effects of the alternatives on the estimated number of visitors currently using the bridge (how many people could potentially be effected) and the trends in visitor use of the Pemigewasset wilderness and other areas of the White Mountain National Forest. If visitors are displaced by the need to ford the river, approximately how many visitors could this effect? Issue #3
Wilderness Character: Some commenters stated that removing the bridge (without replacement) improves the wilderness character of the Pemigewasset Wilderness by eliminating a human structure, restoring the areas undeveloped condition and complying with Wilderness legislation.
Resolution:
• Develop Alternative 2 – Remove Bridge without Replacement
Measurement Indicator
• Compare the effects of the alternatives on the five qualities of wilderness character: untrammeled, undeveloped, natural, outstanding opportunities for solitude and primitive or unconfined recreation, other features.
12 White Mountain National Forest – Pemigewasset Ranger District
Chapter 2: Alternatives Alternative 1: Proposed Action – Removal of Bridge without Replacement
The existing bridge would be removed using traditional tools (e.g., cross-cut saws, sledge hammers, and other similar hand tools). The concrete abutments would be left in place and allowed to decompose over time. The creosote treated wood would be removed from the site for proper disposal. Depending on the size of material to be packed out (e.g., large pieces of bridge stringers) mechanized and motorized equipment, including chainsaws and helicopters, could be used. Up to two helicopter trips would be necessary to remove large material. Untreated wood materials would be chopped up and burned on site. Up to 12 trees greater than 3” diameter at breast height (DBH) would be cut down to facilitate bridge removal. The trail would maintain its current alignment and users would ford the river using their own discretion. Bridge removal would take approximately five days and would likely occur between early July and late September. Following bridge removal, the site would be monitored for user created impacts (soil erosion), and if resource concerns were to develop, they would be addressed with future project(s) in compliance with the National Environmental Policy Act. The Zoning for the small segment of Thoreau Falls trail would be administratively changed from Zone C to Zone B to reflect the change in conditions following bridge removal, resulting in the entire trail length being Zone B. Alternative 2: Removal of Bridge with Replacement
Removal of the existing bridge would be the same as described in Alternative 1 (the Proposed Action). Under Alternative 2, the bridge would be replaced in the same location as the current bridge using the same approaches to address accessibility. Because of the length of crossing, the new bridge would be constructed out of steel and timber in order to meet current Forest Service pedestrian bridge standards. In keeping with USDA-USDI guidelines, the bridge would also be designed to harmonize with the primitive character, natural and cultural setting to the extent possible. The existing concrete abutments would be used if they were structurally sound and capable of supporting a new bridge
13 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
built to current Forest Service standards. Otherwise, new concrete abutments would be installed to maintain the existing trail alignment. Construction would require the use of motorized equipment including helicopters, concrete mixers, jack hammers, and other small power hand tools needed to prepare the site and materials. Up to 4 additional helicopter trips could be necessary to transport materials and equipment for construction of the new bridge. There would be approximately 3,800 square feet of ground disturbance as a result of project activities (staging and construction) if the existing abutments were used. Approximately 1,800 square feet more ground disturbance would occur if new abutments had to be installed. In order to install new abutments, the old abutments would need to be removed and the area around the old abutments up to the stream would have to be excavated, the area where the new abutments were being installed would have to be dewatered of the abutment area, placement of concrete and rock, and re-vegetated. Approximately 18 additional trees greater than 3” DBH would be cut down to clear areas for construction and staging equipment and materials for bridge construction. Construction of the new bridge would likely occur between early July and late September and would take approximately 90 days. Design Features Common to All Action Alternatives
All applicable Forest Service National Core Best Management Practices, New Hampshire Best Management Practices, and Forest Plan Standards and Guidelines would be followed during implementation of this project. All necessary State and Federal permits would be secured prior to project implementation. Monitoring
Monitoring of conditions outlined in the Forest Plan and Wilderness Management Plan for streambank conditions would continue under all action alternatives. If the bridge is removed without replacement, the project area would be monitored for informal trail development and impacts to cultural sites. If resource concerns develop, then management proposals would be initiated to address the concerns.
14 White Mountain National Forest – Pemigewasset Ranger District
Alternatives Considered but Not Analyzed in Detail
The following alternatives were either generated by public comments or were generated during the Minimum Requirements Decision Guide process (project record) and were considered by the Interdisciplinary Team and the District Ranger, but they were not analyzed in detail for the following reasons: Bridge removal with replacement using non-motorized equipment and non-motorized transport
This alternative was developed during the Minimum Requirements Decision Guide (MRDG) process to assess the potential to replace the bridge without using tools that are prohibited under section 4(c) of the Wilderness Act. This alternative was considered, but dismissed from further analysis for the following reasons: 1) the feasibility of using pack animals to remove the old bridge and pack in materials for a new bridge is questionable given the size, weight, and quantity of material and the poor condition of the trail that includes a very large washout; and 2) the feasibility of constructing the new bridge that meets Forest Service standards is questionable. Bridge removal without replacement using non-motorized equipment and non-motorized transport
This alternative was developed during the MRDG process to assess the potential to replace the bridge without using tools that are prohibited under section 4(c) of the Wilderness Act. This alternative was considered, but dismissed from further analysis for the following reasons: the feasibility of using pack animals to remove the old bridge is questionable given the size and quantity of material and the poor condition of the trail that includes a very large washout; Bridge removal with installation of stepping stones
One commenter suggested that the bridge be replaced with stepping stones. This alternative was considered, but dismissed from further analysis for the following reason related to safety. Rock steps would not adequately address the perceived safety issues related to crossing the river. Stepping stones could also provide the perception of a safe ford even during times of high water, and they would not be sustainable in this very flashy location.
15 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Bridge removal with installation of a cable car or cables
Two commenters requested that the FS consider installation of a cable car or cables to provide a means of crossing the river once the bridge is removed. This alternative was considered, but dismissed from further analysis for the following reasons related to safety and wilderness conservation. There are not any current Region 9 Forest Service standards for constructing a cable car or cables. A cable car or cables would be a new and different type of permanent structure built in wilderness. A cable car would provide a mechanized form of transport which is prohibited under Section 4(c) of the Wilderness Act unless it is shown to be the minimum “tool” needed to administer the wilderness area to meet the purpose of the Wilderness Act. A cable car would fail to provide an over the water crossing if the mechanical components failed (e.g., frozen in place due to snow or ice buildup). Bridge removal with construction of a new trail connecting Bondcliff and Thoreau Falls Trails fording the North Fork of the Pemigewasset River
The Interdisciplinary Team discussed the potential for a new trail to connect Bondcliff and Thoreau Falls Trails providing a fordable crossing of the North Fork of the Pemigewasset River (no bridge). This alternative was eliminated from detailed analysis because constructing the approximately 1.5 – 2 miles of new trail through lands allocated to Zone A would be inconsistent with the Forest Plan (p. 3-16, Appendix E pp. 5-6).
16 White Mountain National Forest – Pemigewasset Ranger District
Chapter 3: Environmental Effects
This chapter summarizes the potential effects of Alternatives 1 and 2 on affected physical, biological, and social resources. The affected environment analyzed for direct and indirect effects was the immediate area around the existing bridge where removal would occur under both alternatives and where staging would occur under Alternative 2. The cumulative effects area was the Pemigewasset Wilderness, the timeframe was the past 11 years since the Forest Plan was revised and current management was established through three years into the future which encompasses the expected direct and indirect effects of the project, and included activities in Table 2.
Table 2. Past, present, and reasonably foreseeable future projects that were considered by resource specialists for analyzing cumulative effects. Project Time Period
13 Falls Campsite special use permit Past, Present, and Reasonably Foreseeable Future
Guyot Campsite Reconfiguration Project 2016-2018
Pemigewasset Bridge Removal Project 2009
Trail maintenance Past, Present, and Reasonably Foreseeable Future
The following resources were considered by specialists, but the effects of the alternatives on these resources were not analyzed in detail. Either the alternatives would not affect the resources or the effects would be negligible and there were no comments received from the public that would indicate a concern.
• Hydrology, Non-native Invasive Species, Scenery, Soil, and Wildlife Resource specialists reviewed the alternatives, including the application of Forest Service National Core Best Management Practices, Forest Plan Standards and Guidelines, and New Hampshire Best Management Practices, and participated in site visits. Based on their assessments, they determined that the alternatives would have negligible or immeasurable effects on these resources (see project record).
• A Cultural Resources Reconnaissance Report (CRRR No. 2015-04-09/ R2015092204009) with a determination of “No Historic Properties
17 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Affected” was submitted to the New Hampshire State Historic Preservation Office, which concurred with the determination on August 14, 2015. See Ruhan 2016 and signed New Hampshire Division of Historical Resources letter in the project record for more information.
• A Biological Evaluation of the effects of the alternatives on Federally Endangered, Threatened, and Proposed species determined that neither alterative would affect Canada lynx or small-whorled pogonia. The Biological Evaluation determined that the alternatives may effect, but were not likely to adversely affect northern long-eared bat. On March 15, 2016, the U.S. Fish and Wildlife Service concurred with this determination. In addition, the Biological Evaluation determined that the alternatives may impact individuals but were not likely to cause a trend to federal listing or a loss of viability for Regional Forester Sensitive species of woodland bats and mountain avens. (Woods and Sperduto 2016 in the project record for additional information).
• The East Branch of the Pemigewasset River was determined to be eligible for listing under the Wild and Scenic River Act during the 2005 Forest Plan revision process with this segment of the river being classified as “Wild” (USDA Forest Service, Appendix C 2005a; Forest Plan). Forest Plan Standards require the Forest Service to: “Manage eligible rivers to maintain their classification and eligibility until Congress designates the segments or decides not to designate them.” Additionally, Forest Service Handbook 1909.12 (Chapter 82.5) requires that the free-flowing condition, outstandingly remarkable values (ORVs), and inventoried classification of eligible rivers be protected. Removing the bridge would improve the scenic quality of the river at this location. If a new bridge were installed, it would be designed to harmonize with the primitive character, natural and cultural setting of the area resulting in no change from the condition that existed during Forest Plan revision. Therefore, neither alternative would have a negative effect on the free-flowing condition, potential outstandingly remarkable values (ORVs), or inventoried classification of eligibility of this river segment.
18 White Mountain National Forest – Pemigewasset Ranger District
Recreation
The following data were used to evaluate the potential effects of the alternatives on visitor safety and accessibility (Issues #1 and #2): stream flow data, visitor use levels, and search and rescue data from New Hampshire Department of Fish and Game (NHF&G).
Forest Service staff used a two-step process to assess the ability to ford the river as a function of stream flow (cubic feet per second; cfs). First, Forest Service staff and a few members of the public who accompanied staff on site visits made observations (summarized below) at the Thoreau Falls Trail Bridge site to determine if the river was fordable or not. Individuals assessed the river and determined if they would be comfortable fording the river under those conditions. The individuals represented a range of abilities and experience. Following the site visits, the corresponding steam flow rate data from the U.S. Geological Survey’s station on the East Branch of the Pemigewasset River in Lincoln, New Hampshire were obtained and reviewed. For example, during a site visit on May 3, 2016 a Forest Service Inter-Disciplinary Team came to consensus that the site represented an unacceptable level of risk to ford; the corresponding stream flow data was 513 cfs. Individuals felt comfortable fording the river when flow rates at the gaging station were below 300 cfs (Table 3).
Stream flow data have been collected at the USGS gauging station in Lincoln, NH from April 1993 to May 2016. These data were used to estimate the probability that flows would exceed a given rate during a particular month (Figure 8). For example, the probability of encountering a flow exceeding 300 cfs in July would be approximately 20% or there would be an approximately 80% probability of a flow rate at or below 300 cfs in July. In May, the probability of encountering a flow rate above 300 cfs would be approximately 90%.
Using this hydrograph (Figure 8), Forest Staff inferred that backcountry users would have the greatest opportunities for fording during the summer into late fall (when the probability of given flow rates being exceeded is smallest). There would be a lower probability of flows that would support fording during the spring snow melt (when the probability of given flow rates being exceeded is highest). Fording during winter months with snow and ice on the river would further complicate a crossing. This inference was supported by observations made by Forest Service staff during site visits.
19 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Figure 8. The percent probability that flow rates would exceed a given value was calculated using all available data collected at the USGS gauging station in Lincoln, N.H. between April 1993 and May 2016.
Table 3. Dates and times observations were made regarding fordability of the river and associated stream flow measurements (cubic feet per second; cfs) recorded at the USGS gaging station in Lincoln, NH. Dates with bold text indicate when rates of flow posed a higher risk to visitors if they attempted to ford the river as compared to lower flows. For the purpose of this assessment, flow rates below 300 cfs were considered to pose a moderate or lower risk. Date Time Flow (cfs)
7/9/2015 10:45 237 cfs
10/3/2015 12:46 249 cfs
3/16/2016 11:45 436 cfs
5/3/2016 13:19 513 cfs
5/25/2016 10:47 280 cfs
6/28/2016 10:00 105 cfs
8/23/2016 15:00 165 cfs
11/1/2016 12:00 193 cfs
20 White Mountain National Forest – Pemigewasset Ranger District
Visitor Use Data The visitor use level for Thoreau Falls Trail was categorized as moderate (7 - 25 people per day) during the 2005 Forest Plan revision. Visitor use categories are based on the number of people per day during peak use. More recently, in order to assess the potential effects of the alternatives on recreation, the Forest collected site-specific visitor use data by installing two trail counters alongside the trail. One counter was set up just south of the bridge and one just north of the bridge. The trail counters were set up from March 5 through October 31, 2016. However, the trail counter just south of the bridge did not record data during September due to a malfunction. This timeframe represented the primary season of use on the Forest. These data showed higher numbers of passes during the summer months with fewer passes occurring in the spring and late summer (Figure 9). This helps validate the assumption that the peak visitor use of this trail occurs during the summer months with heaviest use in July and August.
Figure 9. The total number of passes per month shows how the pattern of use changed across the monitoring period March – October 2016. *Due to a malfunction, the trail counter at Site 1 did record any data in September.
The counters recorded the number of times something passed by the counter on the trail; the counters did not distinguish between passes by people or wildlife. It is worth noting that many of these passes could have been from a hiker traveling
21 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
out and back across the bridge and not just passing by one-way enroute to a destination. There were three dates with unusual spikes in passes at Site 2 with no similar correspondingly data recorded at Site 1. On these dates (June 15, 20, and 23) the Site 1 trail counter (south side of the bridge) recorded 0, 2, and 0 passes respectively while Site 2 (north side of the bridge) recorded 38, 31, and 33 passes respectively. These data may have been the result of an animal(s) foraging in the area, were considered anomalies and were not included in the analyses. Figure 10 shows the variability in data throughout the monitoring period.
Figure 10. This figure shows the variation in the number of daily passes recorded by the trail counters between March 5 and October 31, 2016 including many days when zero passes were recorded. *Due to a malfunction, the trail counter at Site 1 did record any data in September 2016.
The two peak use days recorded by the trail counter at Site 1 were on Friday, June 17 (17 passes) and Saturday, October 8, 2016 (17 passes). The two peak use days recorded by the trail counter at Site 2 were on Sunday, June 26 (19 passes) and Saturday, October 8, 2016 (17 passes). During the Memorial Day, Fourth of July, and Columbus Day holiday weekends the trail counters showed a range of passes between 3 and 17 (Table 4).
22 White Mountain National Forest – Pemigewasset Ranger District
Table 4. Trail counter data recorded during Memorial Day, the 4th of July, and Columbus Day holiday weekends. Site # Saturday Sunday Saturday Sunday Monday Saturday Sunday
05/28 05/29 07/02 07/03 07/04 10/08 10/09
1 10 13 13 13 8 17 11
2 3 11 13 12 8 17 14
New Hampshire Fish and Game Search and Rescue Data The NHF&G data included all search and rescue incidents recorded on the WMNF from January 2008 through early October 7th, 2015 (project record). The vast majority of incidents occur outside of designated wilderness areas and no incidents were reported within the project area. Most incidents occurred in high use areas and were often attributed to a lack of visitor preparedness. The trip preparation typically completed by overnight wilderness visitors may help explain the vastly lower number of search and rescue incidents within the WMNF wilderness areas. The data did not indicate an increase in incidents after the Pemigewasset Wilderness Bridge Removal Project in 2009. That decision included decommissioning the section of trail that led to the formerly bridged crossing. Alternative 1 (Proposed Action):
Direct and Indirect Effects Access to the area would not be closed or restricted. However, removing the bridge would make access to the area more challenging. The potential increase in visitor risk associated with a stream crossing is addressed in the Environmental Effects, Wilderness section below. There would be a change in use patterns due to some displacement of hikers and backpackers who are unable or unwilling to ford the river at this site. Displacement may be more evident in the winter when visitors would have to cross on ice and snow. Increase in trail use by crews and localized noise would have an effect on recreation for a short period of time during bridge removal. Based on the trail counter data, it is likely that fewer than 1,000 visitors use this trail each year and most of the use is during the summer. Some of these visitors
23 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
would ford the river and some would have to modify their itineraries if river flows and/or experience levels prevent fording. Other visitors would be drawn to the remoteness of the area, and the challenge of the river crossing would be a draw to visitors seeking solitude and primitive forms of recreation. Although there may be a short-term reduction of use on the Thoreau Falls Trail, visitor trend data indicates that visitor use within the Pemigewasset Wilderness continues to increase (as shown by Appalachian Mountain Club overnight use at managed campsites and huts in and around the Pemigewasset Wilderness). As a result, the areas remoteness would be an increasing draw for visitors seeking solitude, especially in the Northeast where such experiences are limited.
Based on NHF&G data, the number of search and rescue incidents is not expected to rise if the bridge is removed. Very few search and rescue incidents occur in remote areas of wilderness likely due to visitors being more prepared and experienced for backcountry travel. The NHF&G data did not indicate an increase in the number of search and rescue incidents following the 2009 Pemigewasset Bridge Removal Project, which removed one suspension bridge and decommissioned a connector trail in the Pemigewasset Wilderness. The suspension bridge was removed to address similar safety concerns of a failing bridge and to improve wilderness character. Although, the two projects are not a perfect comparisons as the 2009 project included decommissioning of the connector trail so that visitors were not lead to a river ford, remoteness of the Thoreau Falls Trail Bridge locations, and different stream and stream bank characteristics, the lack of an increase in search and rescues following removal of the suspension bridge in addition to the general trends for where search and rescues occur in the Pemigewasset Wilderness suggest that search and rescue incidents would not increase as a result of this project. Signage and other notices would be used to alert visitors at the trailhead that the bridge was no longer in place. This would allow visitors to be aware of the new condition and decide whether or not to continue on the trail. Outreach (in particular the Trailhead Steward program), including direct visitor contact and posting of notices, has been attributed to reduced numbers of search and rescue incidents on the Forest by NHF&G. Outreach has included weather alerts to inform visitors of the potential for rapidly changing water levels and flow rates as a result of storms and spring snow melt.
Following removal of the bridge, the ½ mile section of trail between the intersection of the Wilderness Trail and the river crossing would be changed to
24 White Mountain National Forest – Pemigewasset Ranger District
Zone B resulting in the entire length of trail having the same management strategy. This would have a positive effect on visitors, as there would be a consistent message about expectations for the level of challenge, risk, and self- reliance encountered on this trail (Forest Plan p. E-27).
Cumulative Effects The cumulative effects of this alternative, combined with the removal of the suspension bridge and trail in the Pemigewasset Bridge Removal Project in 2009, would be a displacement and/or a potential reduction in visitor use/access to the certain areas of the Pemigewasset Wilderness. However, this former bridge and trail contained a shorter loop hiking opportunity than the Thoreau Fall Trail, and users likely sought a different opportunity, including a relatively short loop hike from Lincoln Woods. The users of the Thoreau Falls Trail Bridge are likely seeking more remote and lengthy wilderness hiking opportunities and use the trail to traverse from trailhead to trailhead across the Pemigewasset Wilderness, rather than a loop experience. Therefore, the affected user groups may be different and there would not be a cumulative effect on access opportunities for users of the wilderness. In addition, overnight use at Appalachian Mountain Club campsites and huts shows a trend of increased use in the Pemigewasset Wilderness, suggesting the Pemigewasset Bridge Removal Project did not impact visitor use levels. There is no indication that the Pemigewasset Bridge Removal Project in 2009 resulted in an increase in search and rescues; therefore, there would be no cumulative effects to visitor safety resulting from this alternative. Alternative 2:
Direct and Indirect Effects This alternative would have no direct or indirect effects to recreation compared to the current condition of a bridged crossing at this location, except for temporary disruption to visitors during bridge construction due to an increase in trail use by crews, and localized construction noise. There would be no changed in the real or perceived risk to visitor safety and no visitors would be displaced to other trails to avoid an unbridged crossing at this location. Use levels would be unaffected by this alternative.
Cumulative Effects Because there would be no direct or indirect effects to recreation, there would be no cumulative effects from this alternative.
25 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Wilderness
The following section includes a summary of recommendations presented in the Minimum Requirements Decision Guide (MRDG; project record) developed for this project. An MRDG is a tool developed to help responsible officials make informed decision regarding the management of wilderness within the context of the Wilderness Act. The protection and enhancement of wilderness character are an obligation of the Forest Service entrusted with stewardship of Wilderness areas. Wilderness character is comprised of five qualities: untrammeled, undeveloped, natural, outstanding opportunities for solitude or primitive and unconfined recreation, and other features or values (Table 5).
Table 5. The five qualities of wilderness character used to evaluate the impacts of management actions on wilderness. Quality Description
Untrammeled Wild, unconstrained, unhindered and free from modern human control or manipulation.
Undeveloped Without permanent structures, enhancements, or modern human occupation. Managed without the use of motorized equipment or mechanical transport.
Natural Ecological systems are substantially free from the effect of modern civilization.
Outstanding Opportunities for Offers self-reliance, challenge, non-motorized and non- Solitude or Primitive and mechanized recreational experiences. Provides a haven for Unconfined Recreation self-discovery and rejuvenation, a refuge from civilization.
Other Features or Values The unique qualities of a particular wilderness area including ecological, geological, or other features of scientific, educational, scenic, or historical value. “
These qualities are monitored and evaluated for any proposed project in Wilderness and used during the MRDG analysis. Chapter 1 of this EA has additional information on laws, policies, and guidance provided for the management of Wilderness and trails in Wilderness. Forest Service policy, which
26 White Mountain National Forest – Pemigewasset Ranger District
appears in Forest Service Manual (FSM) 2320 (Wilderness Management), directs that when existing improvements in Wilderness areas deteriorate to the point that normal maintenance does not keep them usable, the need for the structure is to be analyzed. If it is not essential to meet the minimum requirements of wilderness administration, the structure is not to be replaced (FSM 2324.34). The Minimum Requirements Decision Guide (MRDG) is a process used by managers to determine the minimum necessary to meet the administration of the Wilderness under Section 4(c) of the Wilderness Act. An MRDG was developed for this project in order to identify, analyze, and determine: 1) whether management action was necessary by asking the questions “Does the bridge need to be removed?” and 2) if so, what is the minimum necessary tool to implement this activity (how to remove the bridge and if to replace it).
Wilderness areas by nature, policy, and law present a higher safety risk for users. Reducing or eliminating risk is not necessarily a justification for a structure under the minimum requirements for the administration of the area. The structure must be needed to protect and manage the Wilderness resource, or address an unusual and extraordinary public safety hazard, and must be consistent with zone designations (Forest Plan p. 3-14). The MRDG discloses and considers factors including effects on wilderness characteristics, public safety, time constraints, costs, and impacts to other natural resources to help inform the Decision Maker. Table 6 provides a summary of the effects of the Alternatives on the qualities of wilderness character. Alternative 1 (Proposed Action):
Summary of Direct and Indirect Effects Overall, this alternative would enhance the wilderness character of the area by removing an unnecessary structure and increasing opportunities for solitude and primitive forms of recreation. Visitors would be exposed to increased risk as a result of having to ford the river during moderate to high flows. This alternative would require more self-reliance, acceptance and preparation for the possibility that trip plans might have to change, and would result in an experience driven more by the natural environment and landscape. The small segment of Thoreau Falls trail on the south side of the bridge that is currently Wilderness Management Zone C would be changed to Zone B to reflect the change in conditions and the area would be managed consistent with the remainder of the Thoreau Falls Trail further protecting the wilderness character of that area.
27 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Summary of Cumulative Effects Removal of this bridge without replacement combined the Pemigewasset Bridge Removal Project in 2009 would have a beneficial cumulative effect on the undeveloped, solitude and primitive forms of recreation qualities of the Pemigewasset Wilderness. The removal of the Thoreau Falls Bridge also completes the removal of all man-made trail bridge structures in the Pemigewasset Wilderness which increases its wilderness character by providing a wilderness experience that is devoid of man-made trail bridge structures. The Pemigewasset Wilderness is the largest federally-designated wilderness area in the northeast and the next closest wilderness that is larger is located in West Virginia. The significance of the cumulative effects of managing the Pemigewasset Wilderness more closely to adhere to Forest Service management direction and the Wilderness Act is notable given the opportunity and experience it would provide under this alternative, especially in light of the 70-80 million people that can access it with a day’s drive. Alternative 2:
Summary of Direct and Indirect Effects
Under this alternative, the small segment of Thoreau Falls trail on the south side of the bridge would remain in Wilderness Management Zone C and management of the area would not change. Although this alternative would result in no effect to wilderness character when compared to current conditions, this alternative would not improve the wilderness character of the area because the current developed condition and management would be maintained and opportunities for solitude and primitive forms of recreation would not be enhanced. This alternative would require less self-reliance, reduced chance that trip plans would have to change due to river conditions at the site, and would result in an experience less driven by the natural environment and landscape.
Summary of Cumulative Effects
When compared to the current condition, this alternative would have no cumulative effects on wilderness character. However, the reinstallation and maintenance of the bridge would continue to have reduced undeveloped, solitude, and primitive forms of recreation qualities of the Pemigewasset Wilderness.
28 White Mountain National Forest – Pemigewasset Ranger District
Table 6. Comparison of effects on the five qualities of wilderness character.
Wilderness Quality Alternative 1 Alternative 2
Untrammeled No effect No effect
Undeveloped Short term negative effects from Short-term negative impact on the work crews and helicopter use and undeveloped quality because of the long-term positive effects due to use of helicopter and power tools, bridge removal. and a long-term negative effect due to the presence of a new bridge manufactured using dimensional lumber and steel construction.
Natural No effect No effect
Outstanding Short-term negative effects on Short-term negative effects on Opportunities for solitude due to the presence of solitude due to the presence of Solitude or Primitive work crews and use of helicopter. work crews and use of helicopter. Unconfined Recreation Long-term positive effects on Long-term negative effects on solitude if some visitors are solitude as more visitors chose to displaced to other locations. Long- use this trail. Long-term negative term positive effects on effects on opportunities for opportunities for primitive primitive recreation due to bridge recreation due to unbridged crossing. crossing.
Other Values No effect No Effect
29 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Other Agencies Consulted
U.S. Fish and Wildlife Service
New Hampshire State Historic Preservation Office References
Ruhan, J.F. 2016. Thoreau Falls Bridge Project Heritage Report. White Mountain National Forest. Campton, NH.
United States Department of Agriculture (USDA) Forest Service. 2016. Mimimum Requirements Desicision Guide for the Pemigewasset Wilderness Thoreau Falls Bridge Removal Project, White Mountain National Forest. Campton, NH.
United States Department of Agriculture (USDA) Forest Service. 2008. FSH 2309.18 - Trails Management Handbook Chapter 10 - Trail Planning. Washington, DC.
United States Department of Agriculture (USDA) Forest Service. 2007. FSM 2320 – Wilderness Management. Washington, DC.
United States Department of Agriculture (USDA) Forest Service. 2005a. White Mountain National Forest Land and Resource Management Plan. Laconia, NH.
United States Department of Agriculture (USDA) Forest Service. 2005b. Final Environmental Impact Statement for White Mountain National Forest Land and Resource Management Plan. Laconia, NH.
United States Department of Agriculture (USDA) Forest Service. 2005c. Record of Decision for White Mountain National Forest Land and Resource Management Plan. Laconia, NH.
Woods, B. and D. Sperduto. 2016. Biological Assessment/Evaluation: Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project. White Mountain National Forest. Campton, NH.
30 White Mountain National Forest – Pemigewasset Ranger District Appendix A - Public Comments and Forest Service Responses
This appendix captures the responses the Forest received during the 30 Day Comment period following the release of the Draft Environmental Assessment on August 7, 2017. This appendix also provides the Forest Service’s response to the comments received. Safety Concerns Summary Response
Numerous people responded with comments concerning how the removal of the Thoreau Falls Bridge without replacement (Alternative 1) would threaten hiker safety. A list of these concerns include:
• The bridges actually may save lives or injury
• I think or hope that the forest service looks more at safety over wilderness as I believe both can co-exist
• I can plan on a safer crossing for trips at the crossing and not having To hike up or down looking for a better crossing
• It is extremely difficult to rescue people in that area
• Replace the bridge if condemned, as it is needed for public and management's safety
• Most of the time it is not possible to safely wade across the river
• The removal of this bridge will have a detrimental effect on the public’s access and ability to safely experience this area.
• Please replace the bridge. It is well used and serves an important function.
• We would not have wanted to ford the river, it is far too dangerous for most people!
• Stream crossings can be treacherous and chilling.
• Please replace the bridge so hikers get a dry start into their miles-long trek into the wilderness.
• I believe that the river at the Thoreau Falls Bridge is too dangerous to cross without a bridge for too many hikers in too many seasons.
• I think more people will be "forced" to cross this one for the reasons above, and more will get into very serious trouble.
• I am in favor of replacing the bridge when it becomes unsafe to cross.
• The absence of this bridge will put hikers/skiers … at risk from the attempt to cross the stream during periods of high water or incomplete coverage by ice.
• …fording the river at that point would dangerous. A-1 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
• …I believe that safety and access are vitally important. Without a safe and secure bridge at this location safety will be undermined.
• However when flows are higher, safe passage is extremely unlikely.
• The Commission believes that without a safe and secure bridge in this location, safety will be severely undermined.
• … I feel that there ought to be a bridge in that location, for reasons of public safety.
The Recreation section of the Environmental Analysis (EA) for this project documented the findings which were used to estimate at what level the stream would be fordable for most users followed by when these levels occur based on stream flow data. The EA then documents the use patterns to help determine the bridge’s primary season of use. Comparing this data, the EA concluded that it is generally considered safe to ford the river at this location during the bridge’s primary season of use, which is mid to late summer. The concern expressed in many of the comments to provide a bridge for safe access year round contradicts wilderness management direction found in Forest Service Manual (FSM) 2320 – Wilderness Management, which is described in the EA. This manual provides wilderness managers with a more explicit framework to implement the Wilderness Act of 1964 and other relevant statutes. Policy statements included in FSM 2320.3 include:
4. Cease uses and activities and remove existing structures not essential to the administration, protection, or management of wilderness for wilderness purposes or not provided for in the establishing legislation.
10. Inform wilderness visitors that they face inherent risks of adverse weather conditions, isolation, physical hazards, and lack of rapid communications, and that search and rescue may not be as rapid as expected in an urban setting in all publications and personal contacts.
Managers are directed to manage the wilderness as its own resource to ensure its character and values are dominant and enduring. Tradeoffs between ensuring safety and accepting risk are envitable in these management decisions and, in the case of bridges in wilderness, the following guidance is provided in FSM 2320.13f(2): …Provide or replace bridges only:
b. Where the crossing, during the primary season of public use, cannot be negotiated afoot safely, or cannot be forded by horses safely.
The methodology to evaluate this guidance is detailed in the Recreation section of the EA and summarized again above.
It is also worth noting that the Wilderness Act of 1964 provides only one provision for the safety of
A-2 White Mountain National Forest – Pemigewasset Ranger District persons in a wilderness area in Section 4.(c) Prohibition of Certain Uses, which prohibits commercial enterprises and permanent roads “…except as necessary to meet minimum requirements for the administration of the area for the purposes of the Act (including measures required in emergencies involving the health and safety of persons within the area,…”. The Minimum Requirements Decision Guide (MRDG) was used to first to determine the need for action, namely that it is necessary to remove the current bridge due to safety concerns. And second, to evalaute four alternatives to determine which alternative has the least impact on the wilderness resource. It was determined in the MRDG that a bridge at the location was not necessary and the least impactful way to accomplish the action which was determined to use motorized equipment (helicopter) over a short duration to remove the existing bridge.
Instead, the Act defines a wilderness as “an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements…” This definition is illustrated using a Wilderness Management Model in FS Manual 2320.6, which provides guidance for the Forest Service to manage wilderness:
Where a choice must be made between wilderness values and visitor or any other activity, preserving the wilderness resource is the overriding value. Economy, convenience, commercial value, and comfort are not standards of management or use of wilderness. Because uses and values on each area vary, management and administration must be tailored to each area. Even so, all wilderness areas are part of one National Wilderness Preservation System and their management must be consistent with the Wilderness Act and their establishing legislation.
One of the effects of Alternative 1, which is described in the EA, will be to introduce additional risk as a factor in a visitor’s decision making process when assessing the natural environment at the crossing without a bridge present. The convenience that would be afforded visitors by maintaining a bridge at this crossing are not standards for wilderness management. The criteria which defines when to make an exception for providing a structure, such as a bridge, for personal safety has been evaluated in the MRDG and the EA. Considering the consistency of intent found between the legislation and Forest Service Manual regarding how to manage wilderness, it would be exceptional for a manager to conclude, in this case, that a bridge should be provided for public safety. In regards to public safety, the comments received during the 30 day comment period did not reveal any new substantive information that would alter the proposed action when considered in the context of the legislation and Forest Service Manual direction regarding wilderness management. There are no exceptions to provide for such structures, in this case, and to make such an exception would be without justification. The lack of a bridge at this crossing and the resulting increase in challenge at higher water flows, and the inherent subsequent risk it presents to a visitor is in keeping with the Defintion of Wilderness in the Wilderness Act and the management direction found in FSM 2320. The discrepancy between many of the public’s
A-3 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
desires to replace the bridge and the decision to remove the bridge without replacement will no doubt generate more controversory and debate as to the role of federal wilderness areas in New England and in the East. Through this debate, the Forest Service is hopeful that the public’s understanding of the laws and regulations managers are charged with upholding will continue to grow.
Table A-1. Comments Received during 30 Day Comment Period and Forest Service Response
The following table captures the responses received during the comment period along with an abreviated Forest Service response . Many of the responses to comments will refer to the discussion of safety above.
# Comments FS Response
1 Thanks for this follow-up to comment on your Noted. Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project I highly recommend the Alternative for Removal without replacement and as described by your preferred Alternative.....It is the correct decision as required by the Wilderness Act of 1964 and Forest Service Manual direction and following minimum tool choices and application.
2 I want you to know that I think the Thoreau Fall Bridge See Safety Concerns Summary should be replaced, not removed. This removal is typical of Response in regards to the whether Forest Service thought, some line in some black book says the bridges are necessary for safety. such and such. You obey the sentence without regard to We regret that you do not feel your what we on the ground who use these facilities want or concerns are heard. We consider what makes common sense. You did this same thing years every comment based on its merits ago on the Wilderness Trail and that was really STUPID. and whether or not it has been You cannot cross the Pemi there now!! Wilderness or not, adequately considered as part of
A-4 White Mountain National Forest – Pemigewasset Ranger District
the bridges are necessary and don’t harm the environment. the analysis. The harm to the The bridges actually may save lives or injury. Think of the environment is duly noted in the possibilities. I hike the Whites 52 weeks of the year, every analysis as to the effects the bridge Wednesday. has to wilderness character. Some potential harm to the environment was identified in the preservatives found in the stringers with mitigations to remove them and dispose of them properly as part of the proposed action. Please do take the time to read the introduction to this appendix for a more comprehensive review of your concerns.
3 I wanted to express my thoughts on the debate about the See Safety Concerns Summary Thoreau Falls bridge I believe there has to be a balance Response, located at the beginning between when and where a bridge is a must for safety of this appendix, in regards to the issues Some of these crossing are very dangerous even in whether the bridges are necessary non high water after a storm. for safety. Look at the women who lost her life a few years back on the As described in the EA, resource Gale river trail (may have the wrong tr) But it was in that concerns for future potential area, and that was a smaller stream. impacts to the riparian area because I think or hope that the forest service looks more at safety of herd paths will be addressed as over wilderness as I believe both can co-exist Other states the need arises with a commitment have bridges that blend in with the surroundings very well. to future monitoring and action It make planning trips better as a solo hiker I can plan on a should resource damage reach an safer crossing for trips at the crossing and not having To unacceptable threshold. hike up or down looking for a better crossing, this would also help in not creating herd paths along the banks also if something happened up stream or down from the main trail crossing I may not be found It just takes one wrong step, I and others have stories of close calls on some of these crossing. Also of issue, concern is a crossing can be fine one day and
A-5 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
if rain moves in the crossings can become hard as well And most trail don’t offer another way around (trail). Also with the popularity of winter hiking and camping I don’t want to be wading streams. once again hope you will consider when and where a bridge is a must and when one is not needed.
4 Please replace the Thoreau Falls Bridge in the See Safety Concerns Summary Pemigewasset Wilderness. The bridge pre-dates the Response, located at the beginning wilderness designation in that area and thus is exempt. It is of this appendix, in regards to the extremely difficult to rescue people in that area, and a new whether the bridges are necessary bridge will allow year round recreation. for safety
Any exemptions for pre-existing structures would have been in the enabling legislation under Special Provisions. There were no Special Provisions for the Pemigewasset Wilderness Area in the New Hampshire Wilderness Act of 1984.
A-6 White Mountain National Forest – Pemigewasset Ranger District
5 This is my "RESTATEMENT" -my views on earlier See Safety Concerns Summary PEMIGEWASSET WILDERNESS BRIDGE REMOVAL Response, located at the beginning PROJECT dated August, 27, 2015. {Copy included.) My of this appendix, in regards to the now recommendation on this Thoreau Falls Bridge remains whether the bridges are necessary the same - for safety.
"Replace the bridge if condemned, as it is needed for public The Forest remains committed to and management's safety and the same action to others in following the NEPA process and this condition of need for replacement in any Wilderness on regret that this process has taken this Forest". longer than originally anticipated. This was, in large part, due to the This new appeal for inputs, continued review, another amount of interest this project Environmental Assessment- this project has been at generated. Notice will be provided excessive costs, possibly enough to finance a portion of to the public concerning this replacement costs of the bridge. We earlier providers of our decision and any management 2015 inputs received no follow on what the White actions that are implemnted will be Mountain National Forest was doing in this lapse of accompanied by a thorough public indecision. My concern for the personnel and public, Forest education and awareness effort. Employees, those involved in wading this {and other Forest rivers), nor does it indicate "CARING" for this Forest, its The practicality of the Wilderness total uses, users of the now 'Wilderness" lovers that directs Act is beyond the scope of this it back to its once "Nature" characteristics.. project. Changes to the content of the law would have to be pursued As a member of the Forest Management Team on the Forest within the legislative process and in the 1960 decade the upper northeastern area of the East isn’t included in this project. Branch received review for probable Scenic Area designation knowing this area's past 100 years with remains of railroad logging activity, but commanding views from the mid slope areas In its mountain setting. We established six Scenic Areas for proclamation at 50th Anniversary of Weeks Law celebration at Crawford House in 1961, and the earlier Great Gulf "Wild Area" of its kind before Wilderness Act we were CARING ahead of the ways of the preservationist, or todays' "purist" environmental concerns over our "total" Multiple Use Management, that includes Forest Fire Protection.
I found after my retirement in 1987, our earlier study, our files, early photographs, its history, for possible East Branch
A-7 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
of the Pemigewasset Scenic Area. It doubled in size for some reason, then proposed for Wilderness. We took with pride our 1960 Forest Management Team's interest in planning , finding funds for construction of the two major suspension bridges on E. Branch of the Pemigewasset and Wild River, and the Thoreau bridge in the 1960 decade; it indicated sound reasoning to assist river crossing, passage over these rivers for personal safety, enjoyment of their forest recreation pursuits. I view most of the environmental restraints placed under the Wilderness Act impractical, their protection and maintenance standards not practical for application for maintaining safe passages for our "Eastern" Forest visitors.
With my earlier August 27, 2015 inputs, I offer my views in this letter for consideration in your decision-making on the proposal for action on the Thoreau Bridge. I trust we contributors will be provided with notice of your proposal and action advanced and approved by Forest Supervisor- the Forest accepting responsibility of safety for all forest users and Forest Service employees.
A-8 White Mountain National Forest – Pemigewasset Ranger District
6 After reviewing the Environmental Assessment for the The bridge, in its current condition, Pemigewasset Wilderness Thoreau Falls Bridge Removal is considered a hazard. Leaving it Project I would like to suggest that neither the replacement in place does nothing to mitigate or removal options be chosen, and that no or minimal the known hazard. The MRDG resources be further expended on this project. (project) identifies that there is a For some reason a No Action alternative was not discussed need for action. Leaving bridge in the EA nor was there a cost-benefit analysis, but based on components in place or partially what I do know I would oppose spending scarce resources dismantling the bridge fails to on this project when they could be used for much greater mitigate resource concerns with the benefit elsewhere . preservatives found in the wooden The trails in the WMNF are going downhill fast, literally bridge componenets. and figuratively, and that is where the resources should be spent. Leave this bridge alone. Keep the helicopters at home. Put up some signs warning people of the danger of course, at the bridge and at the access trailheads. If you must, rip out the wood nailed into the main logs, or even drop/push the main logs off their concrete/rock supports so they lay across the stream boulders, but don't spend a dime more. Call it a historical artifact like all the junk from the logging days and leave it in place. We hikers get across streams in all sorts of ways, including walking/shimming along fallen logs across streams. We all did that for a few years across the Little River on a downed tree, we all currently do that on the Dicey’s Mill trail on a downed tree, and there are others where we use a mix of rocks, beaver dams and downed trees. We know or should know the risks of using the downed stems versus rock hops or wades, and we make our choice. We can use those main logs to good effect. Leave them in some fashion.
A-9 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
7 I am writing in opposition to the removal of the Thoreau See Safety Concerns Summary Falls Bridge. I have read the Draft Environmental Response, located at the beginning Assessment of August 2017 and take issue with several of of this appendix, in regards to the the points. whether the bridges are necessary 1. Most of the time it is not possible to safely wade across for safety. the river. I have been to the site twice, once in July and The EA used the crossing at Cedar once in October. At both times I did not feel it would have Brook as a comparison and been possible to wade across the river. Your analysis of indicator for the stream flow levels “safe” wading levels does not take into account the water that lie ahead when entering from temperature. Lincoln Woods. Similarly, one can 2. I do not feel the North Fork can be compared with the gauge the stream flow levels found Cedar Brook crossing. The streams are completely different. at the north end of the Thoreau Cedar Brook is slow and sandy, the North Fork is fast and Falls Trail as an indicator of what full of boulders. I have been across Cedar Brook twice and lies ahead when approaching from did not have any problems crossing. the North. These indicators provide 3. I do not feel the North Fork at the bridge can be additional information concerning compared with the crossing above Thoreau Falls. Again the the potential risk that a hiker may streams are completely different. Above the Falls the encounter at the crossing at the TF stream passes over wide slabs. On the day I crossed above bridge site and the analysis does the Falls with difficulty I could not have crossed at the not conclude these indicators bridge. should be considered definitive. The removal of this bridge will have a detrimental affect on the public’s access and ability to safely experience this area.
8 I am an avid hiker in the White Mountains and I use the See Safety Concerns Summary Thoreau Falls bridge often when hiking in the Pemi Response, located at the beginning Wilderness. I would like to go on record as a proponent of of this appendix, in regards to the replacing the bridge. That river is far too difficult to cross whether the bridges are necessary without a bridge and hiking around would result in many for safety. more miles of travel, extending an already long day. While As far as leaving the blazes and I understand the idea behind total wilderness areas, I think cairns marking user created trails, some level of man-made impacts should be allowed. In my off of maintained trails, this would opinion, removing blazes from trees and cairns marking directly contradict the Forest trail junctions (such as the slide trail on Owls Head) is Service’s legal and policy ridiculous and takes things too far. The paths themselves
A-10 White Mountain National Forest – Pemigewasset Ranger District
are man-made impacts. Are we to sweep leaves over them obligations for Wilderness every time we hike? Lets be real. stewardship (see EA Wilderness Please replace the bridge. It is well used and serves an Guidance pages 2-5). important function.
9 Please replace the Thoreau Falls Bridge over the See Safety Concerns Summary Pemigewasset River. My wife and I had a wonderful Response, located at the beginning
hiking and wilderness experience, and completed the 48 of this appendix, in regards to the 4,000 footers, by crossing the bridge. We would not have whether the bridges are necessary wanted to ford the river, It is far too dangerous for most for safety. people!
10 Yes, please replace the Thoreau Falls Bridge The See Safety Concerns Summary Pemigewasset Wilderness will still be a wilderness, but Response, located at the beginning safer, for those of us who enjoy the wilderness. Stream of this appendix, in regards to the crossings can be treacherous and chilling. whether the bridges are necessary for safety.
11 I strongly support replacing the TF Bridge. There's no way I See Safety Concerns Summary would be able to access that end of the Pemi Wilderness Response, located at the beginning otherwise. It seems to me that a bridge is an extraordinarily of this appendix, in regards to the small impact on the overall wilderness but essential for safe whether the bridges are necessary
A-11 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
enjoyment. for safety.
12 I write to oppose the removal of the Thoreau Bridge and to The proposed action in the EA support its repair or replacement. The preservation of the provides for monitoring of the area Pemigewasset Wilderness is an important public policy. around the crossing site for Support for such a policy is not possible, however, without evidence of unacceptable resource continued access by the public to the wilderness area. Those impacts. If they do occur, these who experience first hand the beauty, tranquility and impacts will be assesssed and splendor of this treasured resource are likely to be the most mitigations would be developed. ardent protectors and supporters, not only of the Pemi wilderness, but also of broader conservation initiatives. If we are to continue to allow public access, something not in question at this juncture, then we should do so with responsible stewardship of the land that minimizes the environmental impact of such public access. One of the best ways to minimize human impact is to encourage all visitors to limit their presence as much as possible to the network of hiking trails which exists within the wilderness. Marking and maintaining these trails in safe and usable condition benefits conservation of the wilderness by encouraging just this behavior. Leaving portions of the trail in an unsafe condition will not so much discourage visitation to the wilderness as it will encourage hikers and skiers to impact a wider footprint within the wilderness in search of alternative ways of access. In short, I believe that rebuilding the Thoreau Bridge will place a very small environmental burden upon the wilderness which will be more than offset by the conservation benefits of a well maintained trail network. If at some point the level of visitation within the Pemi wilderness jeopardizes its character as a wilderness area then we should look to limit access through a system of permits, as the Park Service does in many of the nation's most popular national parks, and not through allowing the
A-12 White Mountain National Forest – Pemigewasset Ranger District
existing trails to become unsafe for continued public use.
13 Hi, I’d like you to count my vote in favor of replacing the See Safety Concerns Summary T.F. Bridge. I once crossed the river across the stepping Response, located at the beginning stones and pretty much freaked out when I had to look of this appendix, in regards to the down into the raging waters. Please replace the bridge so whether the bridges are necessary hikers get a dry start into their miles-long trek into the for safety. wilderness.
A-13 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
14 I am writing with regard to the Thoreau Falls Bridge This project will not remove trail project. I am opposed to the proposed removal of the mileage. Many of the trails in the historic Thoreau Falls Bridge. Pemigewasset Wilderness area use In recent years, we have seen a dramatic increase in hiker old logging railroad beds. The days in New Hampshire. We now see parking lots regularly bridge at Thoreau Falls was overflowing and trails being used during previously idle constructed after the logging era periods, such as nights and shoulder seasons. The change is and concurrence for its removal staggering, yet we’re struggling to recognize and adapt. was obtained by the State Historic I believe it is imprudent to remove trail mileage and Preservation Office. infrastructure without suitable replacement. The greater A financial analysis was completed Pemigewasset area has isolated areas of high use, as well as as part of the Minimum many disjointed sections (some created by previous bridge Requirements Decision Guide removals and trail closures) that impede a broader (available in the project record). distribution of hiking traffic. One could suggest that it is inconsistent to preserve 20th century logging infrastructure as historic while eliminating hiking infrastructure from the same era. Regardless, it is time to revisit the planning for this area. As a taxpayer, I do not think a decision can be made without presenting a detailed financial analysis of the proposals. Perhaps this situation could be used to foster new alternatives, such as reaching out to historical restoration contractors, leveraging educational research institutions, and enabling collaborative fundraising.
A-14 White Mountain National Forest – Pemigewasset Ranger District
15 I wish to put on record my opinion that the Thoreau Falls See Safety Concerns Summary Bridge should be replaced, not removed. Response, located at the beginning I'm sure your time is valuable and I'm sure my points are of this appendix, in regards to the redundant with other opinions, so I'll get right to the point. whether the bridges are necessary I've been hiking in the White Mountains for twenty years, for safety. and I have seen both positive and negative movement on The proposed action in the EA issues pertaining to safety, environmental impact, provides for monitoring of the area stewardship, and education. around the crossing site for I've also seen many informed and ill-informed hikers, and evidence of unacceptable resource I've watched both types make good decisions and bad impacts. If they do occur, these decisions. impacts will be assesssed and I believe that the river at the Thoreau Falls Bridge is too mitigations would be developed. dangerous to cross without a bridge for too many hikers in too many seasons. It is also too far into the woods - people who arrive there may be discouraged, but pride or desperation or a sense of "I've already come this far" will push them to cross anyway. Unlike the Black Brook or Wilderness Trail bridges that were already removed, this bridge is a vital link with no real alternative routes, so the data that says no increase in search and rescue was reported when those other two were removed may not be relevant here. I think more people will be "forced" to cross this one for the reasons above, and more will get into very serious trouble. I simply don't believe that a bridge impacts the wilderness experience enough to take these risks, especially when it can be clearly argued that the forest service has multiple clauses it can use to justify a replacement. On an equally important front, I believe that people trampling waterfront vegetation and moving rocks and logs in an attempt to find a place to Ford does more ecological harm than this bridge does. Take a look along the Rocky Branch Trail to Mt Isolation for evidence of that. Please keep our community and environment safe, and replace this bridge.
A-15 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
16 I am in favor of replacing the bridge when it becomes See Safety Concerns Summary unsafe to cross. The absence of this bridge will put Response, located at the beginning hikers/skiers who wish to do a couple of different trips-- of this appendix, in regards namely a loop up and down each side of the East Branch or whether the bridge is necessary for a through hike or ski from the Zealand hut to Lincoln safety. Woods—at risk from the attempt to cross the stream during
periods of high water or incomplete coverage by ice.
17 I understand that there are plans for the removal of the See Safety Concerns Summary Thoreau Falls Bridge. I have been over that bridge a Response, located at the beginning number of times and think that fording the river at that of this appendix, in regards point would dangerous. Unless you re-route the trail whether the bridge is necessary for further East towards Stillwater junction I think the bridge safety. should be rebuilt.
18 In the documents I noted that a cable car or cables as an As you mentioned, the proposal for alternative to a bridge was classified as “Alternative a single cable to assist with the Analyzed but not considered in detail”. I think the Forest crossing without a bridge was Service should consider installing a single cable as a safety considered in the Alternatives measure. The cable should be strung across at the best Considered but not Analyzed in crossing point and be at least head high. Persons crossing Detail. Please also refer to the would be able to grasp the cable while rock hopping for rationale underlaying the case for balance thereby minimizing the risk of falling, hitting their not replacing the bridge in the head on a rock and drowning. More important at times of Safety Concerns Summary high water it could prevent a person attempting to wade Response at the beginning of this from being swept downstream. Finally if crossing on a Appendix in regards to the whether snow bridge if the bridge failed it could help the the bridge is necessary for safety. unfortunate extricate themselves from the water and ice. I
wish also to mention that hikers could slide their heavy packs across on the cable and hop/wade the stream unencumbered. That alone could be a life saver. I concede that if the cable is in place someone will leave a sling
A-16 White Mountain National Forest – Pemigewasset Ranger District
suspended from a carabineer on the cable and hikers will use the sling to slide themselves across when the crossing is tough. A very low budget cable car.
19 Thank you for accepting my comments on the Thoreau See Safety Concerns Summary Falls Bridge. Response, located at the beginning of this appendix, in regards to the First I would like to compliment the White Mountain whether the bridge is necessary for National Forest for your comprehensive and balanced Draft safety and the Minimum Environmental Assessment. You have fairly examined the Requirements Decision Guide in issue and have reached out to the public in a transparent the project record discusses fashion. I appreciate very much the thoughtfulness you whether or not the bridge is the have provided. minimum necessary for the I continue to believe that the Thoreau Falls Bridge should administration of the wilderness . be replaced. I appreciate the concerns for wilderness The proposed action in the EA preservation but I believe that safety and access are vitally provides for monitoring of the area important. Without a safe and secure bridge at this location around the crossing site for safety will be undermined. evidence of unacceptable resource The bridge as noted is in a remote location. Hikers will not impacts. If they do occur, these want to or may not be able to easily backtrack and may impacts will be assesssed and attempt to ford the river when conditions are conducive to mitigations would be developed. safe passage. When water flow is low an experienced hiker
would have little problem. When water flows are moderate passage may be possible. However when flows are higher, safe passage is extremely unlikely.
The day that the Forest Service hosted an inspection I
A-17 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
would consider the flows moderate. I was able to cross but was in water to my mid thighs. A river crossing at the Thoreau Falls in my opinion is far more difficult that any of the other river crossings in that area.
Not replacing the bridge will encourage hikers to find alternate locations to cross the river causing erosion and more usage of the wilderness area near the trail on both side of the river. Should the bridge be removed and not replaced, in my opinion it is only a matter of time before there are problems - likely to be significant problems -- at that river crossing. The law allows for wise administration of the Pemigewasset Wilderness Area. Replacing the bridge is consistent with that authority.
In my view the replacement of the bridge will in no way undermine wilderness values. The bridge will not be visible until a hiker is almost upon it. As proposed it will be unobtrusive and not undermine a hiker's sense of solitude or the primeval nature of that trail.
Thank you again for your consideration of my comments.
A-18 White Mountain National Forest – Pemigewasset Ranger District
20 The Commission to Study and Recommend Improvements See Safety Concerns Summary to the New Hampshire Hiking Trails Network [The Response, located at the beginning Commission] was established in 2016 to address the growth of this appendix, in regards to the in use of our State's hiking trail network and has been whether the bridge is necessary for working diligently to come up with creative solutions that safety. will have a positive impact on vital natural resources in our The Environemtal Assessment state. The Commission is made up of members and leaders addresses the Wilderness Zone and of New Hampshire's volunteer trail maintenance groups as that the Zone C designation at the well as representatives from state and federal agencies. bridge crossing was in fact a result While the focus of the Commission in statute focuses on of the presence of the bridge. There resources to maintain trails, a key underlying objective were no plans during the Forest which that focus addresses is to ensure that hikers have a Planning process too remove the positive experience when they are hiking. The removal of bridge. The bridge’s deterioration this bridge would be contrary to that objective. This letter is and unsafe condition warranted an to inform you that the commission has voted six to one, analysis to determine if a bridge is with one abstaining, in support of replacing the Thoreau necessary at that location and notes Falls Bridge once the old bridge is removed. that if the bridge is removed under the proposed action, a The Commission believes that without a safe and secure corresponding adjustment to the bridge in this location, safety will be severely undermined. Zone from C to B will be Water crossings in this area are possible, but only when the implemented, consistent with the river flows are low. Crossings pose challenges for even surrounding area. Nonetheless, the experienced hikers, who may easily lose their balance when zoning situation provides guidance crossing under moderate flow. of what level of features or It is also very important to keep in mind that the bridge development should be. sees a higher traffic volume during the winter months. The Forest Service’s experience Many back country skiers and winter hikers rely on this with managing the Pemigewasset safe and secure crossing to both begin and end their day in Wilderness does not support the the forest. This is especially true of north to south hikers contention that the bridge sees a and skiers. If a skier or hiker, in the north to south higher traffic volume in the winter. direction, did not know that the bridge was removed and It is worth noting that the bridge is got down to the river towards the end of the day, it could approximately in the middle the result in an emergency, requiring them to back track and wilderness, resulting in traverse have a long and difficult, potentially dangerous hike or ski. from north or from south, a hiker It is the opinion of the commission that these concerns or skier that is forced to turn make a bridge crossing in this location a safety around would have about the same
A-19 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
requirement. The commission appreciates the ability to distance to backtrack as they would make comments and the Commission commends the White if they proceeded. Mountain National Forrest for allowing the public to
participate in this process and for giving consideration to this matter.
21 I wish to express my opinion regarding the removal or See Safety Concerns Summary replacement of the Thoreau Falls Trail Bridge. In short, I Response, located at the beginning feel that there ought to be a bridge in that location, for of this appendix, in regards to reasons of public safety. whether the bridge is necessary for The applicable rules for the different classes of wilderness safety. clearly allow for the existence of a bridge in this location. The Wilderness Management Plan Indeed, a short section of the Thoreau Falls Trail has been for the area will only allow for zone designated Zone C specifically to allow for the existing changes from more developed to bridge. less developed (go from Zone C to Forest Service Policy which appears in Forest Service B but can not go from a Zone B to Manual 2320 directs that replacement of bridges only occur C). when crossing afoot during the primary season of public use cannot be negotiated safely (FSM 2320 p. 20). The assessment of one’s ability to It is well known that conditions allowing safe crossing of ford the river was completed in the the river, without a bridge, seldom occur, coming only well Environmental Assessment and after spring runoff and then only after a sufficiently long concludes there is a high probablity dry period has reduced the volume flow along the river. of fordability during the primary Hikers using older maps showing continuous trail or season of use as mid-late summer. relying on older descriptions of the trail that mention the If the proposed action is bridge will continue to expect to be able to continue upon
A-20 White Mountain National Forest – Pemigewasset Ranger District
reaching the river. Even when advised by appropriate implemented, it will include a signage of there being no safe passage, except possibly public awareness campaign with a during times of very low water flow, should the bridge not noticeable signing effort at the be replaced, the natural tendency of wilderness area hikers appropriate trailheads and trail will be to assume that a crossing will be possible, even if it junctions. may take somewhat longer to find a suitable location. The prospect of otherwise turning around and going back multiple miles will only encourage the taking of what could be unreasonable risk. It's human nature to do so. The effective dead-ending of that trail on either side by removal of the bridge, without replacing it, would be an invitation to disaster. We ought not to adhere blindly to "one size fits all" thinking when it comes to wilderness management. Existing rules for the wilderness clearly allow for replacement of the bridge. Safety, in this particular case, does indeed call for replacement.
A-21 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
22 I have been a frequent visitor to the Pemi in all seasons See Safety Concerns Summary since 1960. I strongly disagreed with the decision to Response, located at the beginning remove the Pemi suspension bridge but never submitted of this appendix, in regards to the comments at the time. It would have been a futile thing in whether the bridge is necessary for any case, since somewhere around 90% of the comments safety. opposed removal and were ignored by the decision makers. Substantive comments are vital for While I understand the constraints the FS operates under FS decision makers, the number of with the Wilderness Act I must protest the continual comments for or against is not as dismantling of preexisting structures that have served the important at the impacts identified public well for many years. They have allowed flexibility by comments (for example if one in which route to hike or ski as weather and the parties comment identifies a critical physical condition change. They have created loops that oversight it is much more allow those of us who do not have long weekends and important than 100 comments that vacations to share in the outdoors with a quick day hike. simply say they agree or disagree They have alleviated potential hazards at significant stream with the proposed action; crossings, reduced erosion and facilitated search and rescue comments for or against are not efforts. The whole notion that the hand of man should be considered as votes.) obliterated in the Pemi seems a little silly to me because the Pemi was not a wilderness when it was designated and it Forest Service Manual 2320 – will never be a true wilderness again. We in New Wilderness Management in section Hampshire simply have too many people too close to the 2320.6 – The Wilderness WMNF for that to be the case. The wilderness the FS is Management Model provides a trying to create is only slightly removed from the illusions framework and model for created by Disney. Let’s stop pretending and accept that managers to consider the difference with increased population, demands on the WMNF and the between an absolute or pure Pemi will increase and making access more difficult will wilderness and what the conditions push ever more visitors to use already overused parts of the are on the ground. The Forest WMNF. Let’s instead make access easier and spread the Service goal is not to achieve an visitor load around the whole forest. If that requires absolute wilderness. To quote change of Wilderness status then perhaps that is what “Where a choice must be made needs to be done. between wilderness values and Please count me as opposed to the removal of the Thoreau visitor or any other activity, bridge. preserving the wilderness resource is the overriding value.” The increased population demands surrounding the WMNF are a compelling reason to make the
A-22 White Mountain National Forest – Pemigewasset Ranger District
differences between the wilderness areas and their surroundings all that more pronounced in favor or preseving and enhancing the area’s wilderness values.
A-23 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
23 I am writing in support of replacing the Thoreau Falls See Safety Concerns Summary Bridge located in the Pemigewasset Wilderness. I am an Response, located at the beginning avid hiker and have crossed the Thoreau Falls Bridge of this appendix, in regards to several times, twice on a ski trek from Zealand Hut to whether the bridge is necessary for Lincoln Woods. I love the area, partly because it is not as safety. crowded as other parts of our beautiful While Mountains
I crossed the bridge as recently as a year ago. I agree that the bridge is not safe any longer. I urge you to adopt "Alternative 2 - Remove Bridge with Replacement". Even during a relatively dry spell, crossing the East Fork of the Pemigewasset River is dangerous. Taking the bridge down without a replacement will definitely leave hikers/skiers in situations that would cause fatalities, especially during winter or early spring.
I understand the concept of a wilderness area and was in favor when the Pemigewasset Wilderness Area was created in 1984. However, the safety of hikers/skiers must be the number one priority.
Again, I urge you to adopt Alternative 2 - remove Bridge with Replacement.
24 Thank you for sharing the Draft Environmental Assessment See Safety Concerns Summary dated August 2017 with me. Response, located at the beginning of this appendix, in regards to I take exception to certain direct and indirect effects for whether the bridge is necessary for Alternative 1 (Removal without replacement) that starts on safety. page 23: The statement on the number of A. The report states that access to the area would not be SAR incidents is not expected to closed or restricted. I think that bridge removal without rise is based on the information by replacement definitely restricts or limits safe access to the NH F&G which showed no SARs in area north of the bridge sit e. This is especially true during the general area of the bridge. The high flows and late fall and late winter/early spring. To EA doesn’t discount that if the
A-24 White Mountain National Forest – Pemigewasset Ranger District
write that removing the bridge without replacement makes bridge is removed, the crossing access more challenging is an understatement. would be more challenging, especially in winter. The B. The report reads that based on historic NHF&G data, the responsibility for safety is different number of search and rescue incidents is not expected to than risk, our studies indicate rise if the bridge Is removed and not replaced. I do not primary season of use is during low believe that this is a valid comparison because currently, flows, resulting in low risk for the there is a safe means of access and egress via the existing individual. However, this does not bridge, even with its limited capacity. If the bridge were to allivate the indivudal’s need to be be removed and not replaced, then the safe means of access safe in a remote and wilderness and egress will be removed. This is especially true for the setting and make good judegement southbound hiker or winter skier. Despite all outreach calls for their personal safety in efforts, I would expect an increase In the search and rescue times of higher flows. incidents.
In summary, please give consideration to the southbound hiker or winter skier trying to reach Lincoln Woods by the end of the day. There is not a trailhead steward at many of the trailheads, and the AMC Hut crews are not always up to date with stream crossing information. Further, in my experience, trailhead stewards have been reluctant to divulge specific stream conditions.
If Alternative 1 prevails, then I request consideration be given to replacing the Pemigewasset Bridge removed in 2009 to provide a safe means of access and egress to the Thoreau Falls Trail and surrounding areas.
A-25 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
25 I am writing in response to your invitation to provide Noted. comments on the proposed Pemigewasset Wilderness As described in the proposed Thoreau Fall Trail Bridge Removal Project. I submitted a action, if implemented, there will letter in favor of removing the bridge during the earlier be a concerted public information commenting period. I am still strongly still in favor of its campaign and sign at trailheads removal. and trail juctions notifying hikers I have read your supporting documents and as I stated that the bridge has been removed. above I am in favor of removing the bridge in question for
the following reasons:
1. The Wilderness Act of 1964 states that, ""A wilderness, in contrast with those areas where man and his own works dominate the landscape, ls hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain." There are few areas in the White Mountain National Forest where this above statement is the rule. I believe this act was created to insure that the few areas that are declared as "Wilderness" are truly wilderness, and that there are no signs of man's intrusion into this pristine environment. At this period of time so much of our protected federal and state land is under assault. The wilderness is being threatened every day for economic gain. Our true wilderness is disappearing. Whatever we have left, especially in the WMNF should be protected. The number of people tramping along the trails of the WMNF are increasing every year and we should make every effort to protect the Wilderness Areas we have from further degradation. I truly value the opportunity to hike in a wilderness where there is no sign of man's intrusion into this environment as there are so few of these opportunities in the WMNF.
2. As I stated above I have hiked across this bridge several times and I am very familiar with the area and the entire Pemigewasset Wilderness. The small river that the bridge crosses can be forded most of the year, except perhaps
A-26 White Mountain National Forest – Pemigewasset Ranger District
during spring runoff or an unusual rain event. From your studies it appears that few people even use this trail to cross the bridge in question. The several times I hiked this trail I never met another trekker. I cannot justify building a new bridge at considerable cost to the tax payer for so few people who may use it. In addition the Shoal Pond Trail can be used by hikers who want to access the Cedar Brook Trail or the East Side Trail or other trails in the Mt. Carrigain Region or the Ethan Pond Trail. This trail provides a safe and rewarding alternative.
When the bridge is removed I would like to suggest that a sign be placed at each end of the Thoreau Falls Trail stating "The bridge over the Pemigewasset River has been removed and hikers should proceed at their own risk if there choose to ford the river. The Shoal Pond Trail offers a sound alternative to reaching your destination." I have hiked the Bond Cliff Trail to where the bridge used to cross the Pemigewasset at the junction with the Cedar Brook Trail. I have forded the Pemigewasset River have not risked my own safety. I think your reasons for removing that bridge should rule in favor of removing the Thoreau Falls Trail Bridge.
In conclusion I am very much in favor of removing this man made structure and I am strongly opposed to building a new bridge. To construct and insert a new man made structure into this Wilderness Area (at considerable cost) would be in violation of the spirit and intent of the 1964 Wilderness Act and the designation of the WMNF Pemigewasset Wilderness.
Thank you for requesting my input into the decision making process. If you would like further comments or suggestions I will gladly provide them.
A-27 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
26 I am a winter user of the Thoreau Falls Trail. I am See Safety Concerns Summary requesting that: Response, located at the beginning - the Thoreau Falls bridge be replaced of this appendix, in regards to - the new bridge be of similar construction to the existing whether the bridge is necessary for bridge safety. It has been argued that the river can be waded if the bridge Preserving the “hand of man” in a is removed. That may be true in the dry summer months. wilderness areas is contrary to the But wading is not a good idea at times of high water; it is applicable legal and policy not a viable option in winter when the river is not mandates for managers. The completely frozen. historical value fo the bridge was It has been argued that removal of the bridge will restore a evaluated by the Forest’s more "natural", "wilderness" setting. That is partially true, archaeologist and concurrence on of course. However, it is not the case that removing the the bridge’s removal was obtained bridge will eliminate the last vestige of human activity in by the State Historic Preservation the area. The trails are built on "the hand of man" - the old Office. logging rail lines and dugways. The habitat is not old forest; it reflects the pioneering species that established Although FS does not have winter themselves following the clear cut of the logging era. use data there is a consensus Eliminating the bridge will not restore "wilderness" to the amongst the wilderness and trail Pemi. Taken together, it's clear that replacing the bridge is a managers that the primary season sensible action. of use is not during winter months. There is no need to use concrete and steel to construct the This is evdent through vehicle replacement. If the Forest Service is willing to contemplate counts at trailheads, visitor counts a "waiver" to allow bridge replacement in a Wilderness at Lincoln Woods, first hand Area, it would be consistent to contemplate a "waiver" that experience on the trails and use would permit a log bridge with a span that is no longer levels at huts. allowed under current construction guidelines. One need The concept of replacing the bridge only consider the history of the existing structure - which using native materials and non- has lasted more than 50 years - for evidence of the viability mechanical tools was explored in of the "traditional" construction methods. the Minimum Requirements To conclude: Decsision Guide. - Replace the bridge to support continued safe access - Use "traditional" (natural) construction materials to maintain the aesthetics of the area
A-28 White Mountain National Forest – Pemigewasset Ranger District
27 The following comments on the Pemigewasset Wilderness Please refer to the Summary of Thoreau Falls Trail Bridge Removal Project Draft Direct and Indirect Effects section Environmental Assessment (EA) come from Wilderness of this document and a further Watch. Wilderness Watch is a national wilderness explanation is available in the conservation organization focused on the protection of all Minimum Requirements Decision Wildernesses in the National Wilderness Preservation Guide in the project record. System, including the Pemigewasset Wilderness. Our
organization previously commented on this project two years ago.
From reading the Draft EA, we understand that the Proposed Action (Alternative 1) calls for the removal of the bridge without replacement. This alternative would use traditional tools to remove the bridge, but would allow mechanized and motorized equipment (including chainsaws and helicopters) to be used for removal of large material. Up to two helicopter trips might be necessary to remove this large material from the Wilderness.
In general, Wilderness Watch supports the Proposed Action, Alternative 1. But we strongly urge the Forest Service to refrain from using chainsaws and helicopters if at all possible.
Earlier, the Forest Service removed a different bridge (a suspension bridge) from the East Branch of the Pemigewasset Wilderness using all nonmotorized means. Wilderness Watch supported that project. We urge the Forest Service to continue that tradition of removal of installations and structures inside the Wilderness with the Thoreau Falls bridge removal as well, and to do so without motorized tools or transportation. Doing this project in this manner will be good for Wilderness.
Overall, we believe that this project will enhance the wilderness character of the Pemigewasset Wilderness, and if conducted using nonmotorized means, will further enhance the wilderness character of the Pemigewasset Wilderness. We believe that this project is in keeping with
A-29 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
the 1964 Wilderness Act and the 1984 New Hampshire Wilderness Act.
A-30 White Mountain National Forest – Pemigewasset Ranger District
28 The EA minimizes the historic legacy of logging railroads, See Safety Concerns Summary hiking trails, and bridges that have been in place providing Response, located at the beginning a access to loggers and hikers for nearly100 years. The of this appendix, in regards to Wilderness Act permits managers to take into account whether the bridge is necessary for previous use and historical context in administrating safety. Wilderness Areas. The bridge should be replaced with a The Thoreau Falls Bridge was built, new one that will last another 50 years. as you mention, following the Henry and Sons built the first railroad bridge at this loggging periods and subsequently location some time around 1910 in order to harvest timber doen’t have a historical logging in the valley of the North Fork. This area was called North context, nor is it considered a Fork Junction in those days. It was natural to build a bridge historic structure. The history of the at this location since the span required is much less after area and it story of transformation subtracting flow from the North Branch. is well documneted and a subject of further cateloging and reports from Parker Young purchased the assets of the timber assets of our archaeologist/cultural resource the Henry’s in 1917 and had big plans for the area including team. The bridge was not construction of hydroelectric power house at North Fork determined to be historically Junction with a dam just below Stillwater. These plans were significant and this project received shelved when Parker Young came on hard times as result of concurrence from the State Historic the depression and other factors with result that in 1936, a Preservation Office. sale was consummated and Parker-Young conveyed 70,000 acres of forest land to the USFS with Parker-Young retained The Environmental Assessment logging rights for 20 more years. Railroad logging began to does disclose some possible wind down in the East Branch valley by the early 1940’s displacement of hikers seeking although timber continued to be removed into the 1940’s by other crossing or other trails as truck via the East Branch road. opposed to fording without a bridge. The issues associated with Many RR grades were soon converted to hiking trails. My higher use levles occuring on other 1955 White Mountain Guide reports Kancamagus Highway popular summits is beyond the has yet to be completed. It also reports the old No. 17 trestle scope of this project, but is seeing is still standing, but is not kept in repair and hikers proceed very focused attention in other at own risk and goes on to note there is no bridge at the studies and reviews. Thoreau Falls Trail crossing of East Branch. My 1966 Guide reports the Thoreau Falls Trail now has a 60’ long bridge In regards to wilderness zones, the crossing over the East Branch. Prior to construction of this Forest Plan is very specific with a bridge, hikers probably crossed on the river on remains of standard not to manage areas that RR trestles dating from logging era. would move the zone classification
A-31 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Visitation to WMNF is Increasing from a more primitive zone to a less primitive zone as your The 4000 Footer Committee records indicate a steady comment suggests. increase in giving out awards of the NH 4K patches. Thanks to proximity to urban areas, winter and summer The Outfitter Guide rules you visitation to WMNF NH 4000’ peaks continues to increase mention are beyond the scope of along with consequential damage to fragile alpine forest this project. and will result in requirement to further harden high altitude wilderness trails. Ironically NH 4000’ awards were started to disperse usage away from popular summits. USFS should work with outdoor organizations to develop new incentives and policies to disperse visitation to other areas.
The TFT and bridge provides important low elevation and moderately graded connecting trails between southern and northern regions of the Pemigewasett Wilderness. The continued presence of a bridge at this location would provide safety and convenience of hikers and could provide possible future options for dispersal of traffic to lower elevations away from heavily traffic on the Bonds and Zealand ridges.
The RR and truck roads were constructed to high standards cutting through high ground and filling in low ground and removing glacial boulders making possible hiking trails with moderate grades and good footing. It would be impossible to construct hiking trails to such high standards today. These well-built grades (including Thoreau Falls Trail) should not be relegated to Class B status, but should be utilized to best use and elevated to Class C status along the entire length in order to encourage and provide options to hikers for low elevation and moderately graded hiking trails and planning loop hikes when hiking the Bonds and Guyot ranges.
Bridge Removal Will Reduce Access to Wilderness
A-32 White Mountain National Forest – Pemigewasset Ranger District
USFS wilderness policy increasingly results in locking up the wilderness so as to deny access as much as possible to the average outdoor recreationists. Under the current plan, Wilderness Experience would be restricted mainly to elite few hikers and discriminates against older and less able Americans who also hunger for Wilderness Experience.
A recent USFS communication of Oct 2016 to AMC NH Chapter Excursion committee is also appears to be designed to reduce access to wilderness areas.
Supporting Documents: White Mountain National Forest — Land and Resource Management Plan
• Chapter 3 - Management Area Direction o Pg. 15: Special Uses
▪ S-1a: Because Zone A should have the lowest levels of recreational use and the fewest recreation-related impacts, outfitter / guide use is prohibited in Zone A. (Note: AMC hike leaders are issued guide cards and as such, are considered “outfitters/guides”.)
http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/s telprdb5199906.pdf
• Appendix E - Wilderness Management Plan o Pg. 6: Zone Descriptions
▪ 2.1.1: Zone A - areas 500 feet or more from all trails
http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/s telprdb5186043.pdf
Outfitter / Guide Prohibited Use:
• In general, outfitters/guides are prohibited from leading bushwhacks in Zone A of designated Wilderness areas (Zone A encompasses areas 500 feet or more from a trail).
A-33 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
• In all designated Wilderness areas, leading bushwhacks to peaks 500 feet or more from a trail are prohibited. An example of this would be Mt. Resolution, which as it is located 0.15 mile off trail, would be a prohibited side trip on an AMC group hike. Similarly, while a hiker from the general public could bushwhack up to Red Rock Pond or Shoal Pond Peak in the Pemi Wilderness, AMC hike leaders are not permitted to lead AMC trips to these areas, as those trips would take groups of people 500 feet or more from a trail.
USFS is in my opinion an overzealous "wilderness protector". Outfitter/Guide trips to places like Red Rock Pond and Owls Head RR Spur should be permitted so long as excursions are respectful of resource and follow leave no trace and hiker safety principals. Officially sanctioned Outfitter Guides should be permitted to lead trips to Zone A. I would agree group size should be limited to 6 or less when going to Zone A areas.
Thoreau Falls Bridge removal is in my opinion overly protective policy particularly in light of increased visitation. The EA sites statistics indicating few people visit the area. Elimination of the bridge will only further reduce visitation. USFS Policy should be other way around. What can be done to safely increase visitation and reduce impacts on higher elevations ridges? There are plenty of remote wilderness experiences to be had elsewhere in New England whose wilderness character will always be preserved thanks to longer drives from urban areas it takes to get to them and where a hiker can risk his life if they wish doing hazardous water crossings.
A-34 White Mountain National Forest – Pemigewasset Ranger District
29 I strongly object to the Forest Service's planned removal of See Safety Concerns Summary the bridge at Thoreau Falls, and urge that it instead be Response, located at the beginning replaced. The bridge is on a heavily used route between of this appendix, in regards to Zealand Notch/Rte 302 and the Kang. The trails from whether the bridge is necessary for Lincoln Woods along the Pemi are heavily used, and to safety. treat this area as a wilderness area ignores the fact that this Replacing the bridge downstream is a major recreational area. As a runner and a XC skier, the of this project is beyond the scope bridge is an important connection for me. of this project. The river crossing is difficult and unpleasant when the water is low in the summer. In the winter or high water, it is extremely dangerous or impossible. If the bridge is removed, people will die trying to make the river crossing. I strongly urge the bridge be replaced, not removed, and that the other bridge downstream on the Pemi be replaced as well.
30 My vote would be to keep/replace the bridge. As an older See Safety Concerns Summary hiker, I have problems with river crossings. I am for Response, located at the beginning anything that would make the wilderness more accessible of this appendix, in regards to to someone like me. I understand that man-made structures whether the bridge is necessary for are not allowed, but I would err on the side of safety. safety.
A-35 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
31 I think the bridge should be replaced for the following See Safety Concerns Summary reasons. Response, located at the beginning I've been backpacking in that region in late Sept since the of this appendix, in regards to 1970's. whether the bridge is necessary for 1. Even in Sept>Oct it can be very dangerous or impossible safety. to ford. Replacing the suspension bridge is 2. If not replaced users will seek alternative places to cross. outside of the scope of this project. 200 yds or so downstream at the confluence of the North Fork and The East Branch there's a much safer place to cross. Users will be bushwhacking and crossing at the unlawful campsite where the old rail road crossed. 3.People enjoy making the trek in summer and winter from the Zealand Falls region down the Thoreau Falls Trail and out to the Kanc. The bridge makes that possible in all weather and water levels. For my 2 cents worth I'd like to see the suspension bridge rebuilt. That crossing was one of the neatest experiences hiking in the Whites. I was backpacking there the weekend before it was removed.
32 I request that you do not remove the bridge at the lower See Safety Concerns Summary end of the Thoreau Falls Trail across the East Branch in the Response, located at the beginning Pemigewasset Wilderness. About nine years ago, the USFS of this appendix, in regards to needlessly removed another nearby bridge across the East whether the bridge is necessary for Branch, which eliminated several popular hiking and x-c safety. skiing routes in the Pemigewasset Wilderness. Both of these
bridges required some maintenance, but those costs pale in comparison with the costs of bridge removal. But, more important, removal of these bridges places hikers and x-c skiers, as well as NH Fish and Game officers and their would be volunteer rescuers, at fatal risk should they try to wade across the river. The USFS in New Hampshire has apparently ignored all public input into their poor decision making the past few years, and removal of these bridges is only the latest example. Hundreds, if not thousands, of
A-36 White Mountain National Forest – Pemigewasset Ranger District
back-country users of one of our most valuable resources in the White Mountain National Forest will be forever grateful. Many thanks for considering this request to save the Thoreau Falls Trail bridge.
A-37 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
33 I am opposed to the removal of the Thoreau Falls Trails See Safety Concerns Summary bridge for the following reasons: Response, located at the beginning Though it appears the high point of activity for the bridge is of this appendix, in regards to the summer season there is a fair amount of use during the whether the bridge is necessary for winter season as groups complete a Pemi-Traverse, skiing safety. from Route 302 into Zealand Falls Hut and out either Part of the analysis used in the EA Thoreau Falls trail or the Shoal Pond trail, exiting via the included a review of the use levels Lincoln Woods trail. This is a 24-26 mile backwoods ski at the Zealand Falls Hut as completed in one day. The average time of completion is reported by the AMC from 2004 to about 9 hours, though the longest has been 14 hours! I have 2011. The data showed fairly been part of a group of people completing this traverse. I consistent seasonality one might have done it 5 times since 2004. The group size has ebbed expect, with high use in July and and flowed, (over 70 total through the years), but they have August and lowest use levels in been completing the traverse for over 30 years starting in April, which corresponds to spring 1982, which predates the establishment of the area as a melt and poor trail conditions. Wilderness. I fell this qualifies as a "historical use. 36 CFR Winter months from January to 293.2 states...... National Forest Wilderness shall be so March are also reported to be low. administered as to meet the public purposes of This data – while not directly RECREATIONAL, scenic, scientific, educational, linked to the trail use at Thoreau conservation and HISTORICAL uses..... Falls Bridge – is an indicator that is My concern is for the safety of these groups. No where in consistent with the analysis the study did you take into account winter use!!! I only presented in the EA. The primary noted that the summer season was peak and I believe season of use determination is an consultation with the AMC regarding winter use of important criteria that was used in Zealand Falls hut as a jumping off point for a Pemi-traverse following the management should have been warranted. I specifically remember one direction in FSM 2320. traverse where the trail had already been broken out by a group who had been before us. That was a nice treat. Historic uses of the of the Once one has made the commitment to head into the Pemigewasset Wilderness were Wilderness area during the winter, the ability to cross @ the considered and the area is rich in Thoreau Falls bridge could mean life or death for some. As respecting those uses, including the noted according to AMC overnight use @ managed trails used for foot travel. The campsites hikers visiting the wilderness seems to be proposed action does not seek to increasing and removal of the bridge could lead to alter hiking use, however it also unintended consequences for NH Fish and Game as well as acknowledges the increase in the Forest Service. Could one not assume that if summer challenge with removing a bridge. use was increasing, that winter use also may be growing? The tradeoffs associated with
A-38 White Mountain National Forest – Pemigewasset Ranger District
You looked at water flow data from April 1993 to May 2016. increasing challenge and risk No mention of CLIMATE CHANGE and it's impact was versus convenience were noted in your evaluation. My concern is with global considered in light of the warming/climate change and the impacts on stream flow in management direction found in the future as regards to public safety. As we have seen from Forest Service Manual 2320 and the Hurricane Harvey we may be entering an era of uncertainty framework of the Wilderness Act in and though there have been no rescues to date, my concern developing the proposed action. is if the bridge is removed we will see more rescue activity or possibly deaths. As noted in your draft EIS, Forest Service Handbook, FSM 2320 Wilderness management provides the following guidelines: Provide or replace bridges only: a. When no other route or crossing is reasonably available. I fully understand winter is not a "primary season" but safety of individuals in the winter season should also be a consideration when making this decision. You have no data regarding winter use and rescues can be dangerous and time consuming. And there is a reason that bridge was placed there in the first place as noted in the EIS on page 2. The bridge is 6.6 miles from the Lincoln Woods parking lot. I do not see how removal that far from a trail head would increase opportunities for solitude and primitive forms of recreation. If the bridge were closer to a road or trail head then that might be the case. Lastly, I have experience in the woods going back over 40 years, including with the USFS, the AMC, and as an Outward Bound instructor. I have participated in my share of rescues and fully understand the risks of an outdoor experience. I do not feel replacing the Thoreau Falls Trail bridge will harm or reduce one's "Wilderness Experience" I therefore urge you to remove the old bridge according to wilderness guidelines, and replace it with one suitable for the wilderness area. I urge you to endorse Alternative 2.
A-39 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
34 Of the Alternatives proposed, I support Alternative 2 See Safety Concerns Summary because it is the only one that retains a bridge at this Response, located at the beginning crossing point. I would hope that once it is selected, some of this appendix, in regards to thought be given to a crafts-in-residence project using whether the bridge is necessary for native stringers from nearby and planking hand-sawn on safety. site. The project title is called “removal” It is unfortunate that the author of the Draft EIS had as a result of any alternative that already decided on the result before writing it. Note that would be selected, would involve the title is "Thoreau Falls Trail Bridge Removal project" not removing the currently unsafe "Bridge Study" or similar. Also although the Wilderness Act bridge. says that "wilderness areas shall be devoted to the public purposes of recreational, scenic, scientific, educational, There is no requirement in conservation, and historical use…" the highlighted phrases Wilderness to make trails or are drawn only from Wilderness provisions and not from bridges accessible for the mobility Federal laws regarding access for the mobility-impaired or impaired (current bridge fails this historic preservation. In particular, the bridge was built in test). 1962 so it is an historic structure with statutory protection Historic preservation concern but no mention of this was made in the DEIS. The DEIS addressed by 106 compliance with exaggerates the difficulty of the stream crossings on the concurrence on project from NH approach routes. On the West approach the Cedar Brook State Historic Preservation Office. crossing has only about 20% of the drainage area of the East Branch and was routinely forded by NH Fish & Game Resource concerns for future vehicles before Wilderness designation, while the other 2 potential impacts to the riparian crossings are yet another order of magnitude smaller. On area because of herd paths will be the North approach the crossing at Thoreau Falls can be addressed as the need arises with a jumped across at low water or avoided entirely by a short commitment to future monitoring bushwhack to a bridge outside the Wilderness boundary, and action, should resource while the other 3 crossings are minor rivulets not even damage reach an unacceptable shown as water on the AMC map. Apparently no trail threshold. counter data was collected in winter perhaps because a Providing features in wilderness demonstration of substantial winter use would inhibit areas to meet accessibility needs is bridge removal. adddressed in: The DEIS notes that "Congress did not include any special provisions or restrictions in the legislation that created the 1990 - American with Disabilities Pemigewasset Wilderness." but fails to note that in that era Act (ADA), Title V Section 508 (c) trails in Wilderness areas were managed very similarly to “Federally Designated those in non-Wilderness so such provisions were
A-40 White Mountain National Forest – Pemigewasset Ranger District
unnecessary. Wilderness protection was promoted as Wilderness preventing logging and snowmobiling not that all traces of (1) IN GENERAL – Congress man should be removed so that the land would revert to reaffirms that nothing in the trees and animals. An outsized percentage of backcountry Wilderness Act prohibits structures such as lean-tos and footbridges were located in wheelchair use in a wilderness area Wilderness areas as compared to the rest of the Forest, and by an individual whose disability it is unlikely that those areas would have been designated if requires its use. The Wilderness Act it was known that all such facilities would be removed. requires no agency to provide any Construction of new and relocated trails was common in form of special treatment or the Great Gulf and Dry River areas for access and resource accommodation or to construct any protection after Wilderness designation when this brought facilities or modify any conditions added funding. Unfortunately Wilderness funding is now of lands within a wilderness area to spent on paperwork instead of actual on-the-ground work - facilitate such use. how many seasonal trail crew could be hired for the same amount as one Wilderness Manager? I would be more While this provision pertains to amenable to removing structures from Wilderness if the wheelchair use, attempting to make Forest Service would provide similar amenities elsewhere, the wilderness more accessible for but no effort is being made to do so. Instead existing the less energetic and athletic structures elsewhere are also being removed due to overuse contradicts the Defintion of from a declining resource base. The effect of removing this Wilderness found in the Wilderness bridge will hence be felt Forest-wide. Act of 1964. The discussion of Alternative 1 ignores the new trail that would need to be constructed since hikers are unlikely to rappel down one concrete abutment to cross the river at its deepest point and then climb up the far abutment. A good bridge location is generally where a river is narrow and deep while a good ford is where the river is wide and shallow. If the Forest Service does not mark a trail to a good ford then no doubt many herd paths will appear. Guideline 5 states that structures are allowed to "address an unusual and extraordinary public safety hazard" which is exactly what exists at this site. From the flow graphs presented, safe fording at the site is only available for about 3 months per year due to unstable ice, high water, or frigid temperatures. Suppose someone not in peak physical condition and carrying a heavy backpack tries crossing in late September - if they slip and break an ankle and
A-41 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
immerse their pack you now have a life-threatening situation due to hypothermia which would not exist with a similar fall on dry ground or at minor crossings. The concept of Wilderness Zones did not exist when the Pemigewasset Wilderness was designated and was apparently invented to create more paperwork. It actually reduces hiker safety by forbidding otherwise reasonable activities - for example, a group of 5 would not be allowed to bypass the crossing near Thoreau Falls by bushwhacking to the bridge because that would exceed the allowable group size in Zone A. Changing the area around the subject bridge from Zone C to Zone B is mere paperwork of no concern to actual hikers. I doubt the assertion that "Other visitors would be drawn to the remoteness of the area, and the challenge of the river crossing would be a draw to visitors seeking solitude and primitive forms of recreation" as they can ford the river already if they wish to. I don't think that you will be able to find a single hiker who will actually hike the Thoreau Falls Trail only if the bridge is removed while you will find plenty who will no longer go there if it is gone. The pressure to remove the bridge comes from armchair types who aren't going there anyway. The members of the public who accompanied staff on site visits were self-selected as those able to walk 13 miles at a steady pace and do not include those who hike more slowly and might take 10 hours or more for the hike, or those who would camp out on such a hike distance. We can expect that hikers at the low end of the ability spectrum might feel less comfortable fording a river hence might find the 300 cfs level too high. Hiking away from roads should not be limited to the energetic and athletic, rather it should be possible for the differentially-abled to enjoy the backcountry. Removing this bridge without replacement is a step in the wrong direction for inclusion and diversity.
A-42 White Mountain National Forest – Pemigewasset Ranger District
35 Thank you for the opportunity to comment on the Thoreau See Safety Concerns Summary Falls Trail Bridge Project. I am a frequent visitor to the Response, located at the beginning Pemigewasset Wilderness and have been to the bridge a of this appendix, in regards to number of times over the years. Back in 2015 I visited the whether the bridge is necessary for bridge with then-District Ranger Jon Morrissey and Chuck safety. Henderson from Senator Shaheen's office. After reviewing The Forest Service is obliged to the analysis, I am in favor of Alternative 2, removing the analyze each project on it’s own bridge with replacement. I believe that hiker safety is of merits and recognizes that the prime importance in this location, and that the replacement decision to maintain or replace of the existing structure with a bridge that meets required bridges in other wilderness areas standards but is designed to "harmonize" with the on the Forest was based on the Wilderness setting as much as possible is the preferred circumstances and conditions at course of action. I do not believe replacing the bridge those locations and are not would unduly compromise the Wilderness character of the intended to serve as standards Pemi, as the present bridge has been in place for 55 years. elsewhere. Although the flow of the East Branch is normally low in the peak use summer and fall seasons, there are frequent instances where the flow is dangerously high. Hikers who have traveled many miles to this point might be tempted to cross at potentially dangerous flow levels rather than backtrack for a long distance. This is a potentially more dangerous crossing than Cedar Brook or the North Fork at Thoreau Falls (where there is an option to use a bridge upstream and bushwhack back to the trail). If not well- frozen, this crossing would be problematical for skiers or snowshoers traversing the Pemi. Due to hiker safety concerns, there are well-engineered bridges present in both the Great Gulf and Presidential Range-Dry River Wilderness areas. I believe the Dry River bridge - which in my experience is located in a low-use area - has been both replaced and then repaired. The replacement of the Thoreau Falls bridge would be consistent with the decisions made in these two other Wilderness areas.
A-43 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
36 I am writing to you today to voice my concerns regarding Noted. the Thoreau Falls Trail bridge project.
Please find enclosed a list of ten reasons why I feel the Thoreau Falls Trail bridge should NOT be rebuilt. I also sent comments to Forest Service during the first comment period.
I have been exploring the 45,000 acres that make up the Pemigewasset Wilderness for many years. Human influence (trail blazing, permanent structures, trail work) is very limited in the Pemigewasset Wilderness, and that is what attracts many backcountry hikers, including myself, to this wilderness.
Removing the Thoreau Falls Trail bridge, which is considered a permanent man made structure under the Wilderness Act, would push the Pemigewasset Wilderness that much closer to the "Natural State" it once was.
The Pemigewasset Wilderness, a designated wilderness, is unique and unlike any other area in the White Mountain National Forest. If it is managed like the rest of the National Forest, the meaning of wilderness will be lost. And if the values of the wilderness act are not upheld, it is senseless to preserve the Pemigewasset Wilderness as a designated wilderness.
And after reading the current draft environmental assessment, whatever the final decision is the work needs to be done per the guidelines of the Wilderness Act. If Forest Service can't do the work by hand, leave the bridge as is and let it rot away.
In my opinion, rebuilding a bridge on a trail that sees little foot traffic undermines wilderness values. Re: Ten reasons why the Thoreau Falls Trail bridge should not be replaced
1) Day hiking to Thoreau Falls from Lincoln Woods Trailhead - In my years exploring the Pemigewasset
A-44 White Mountain National Forest – Pemigewasset Ranger District
Wilderness, I have crossed paths with only a handful of people hiking to Thoreau Falls from the Lincoln Woods Trailhead. Out and back to Thoreau Falls from the Lincoln Woods Trailhead is about a 23 mile hike, and I think the number of people who actually do this hike is far and few. Many people can't hike 23 miles in a day, so it is unrealistic to think Thoreau Falls Trail (starting at Lincoln Woods Trailhead) is a major route to Thoreau Falls.
Hiking mileage to Thoreau Falls:
From the Ethan Pond Trailhead - Out and back is roughly 10 miles From the Zealand Trailhead - Out and back is roughly 10 miles
From the Lincoln Woods Trailhead - Out and back is roughly 23 miles
Even though the popularity of the Thoreau Falls Trail is debatable, the number of miles that must be hiked to reach Thoreau Falls can suggest what is the more popular route. And with this information it is highly likely the majority visit Thoreau Falls from the Ethan Pond and Zealand Trailheads, not the Lincoln Woods Trailhead.
2) Thoreau Falls Trail already has a dangerous water crossing - If one begins a hike at the Lincoln Woods Trailhead with a plan to visit Thoreau Falls, they must hike the Pemi East Trail, to the Wilderness Trail, to the Thoreau Falls Trail, cross the bridge in question, and continue to hike the Thoreau Falls Trail for a number of miles before reaching the falls. Upon reaching Thoreau Falls, the Thoreau Falls Trail crosses the bridge-less North Fork of the Pemigewasset River and continues to the Appalachian Trail. In order to view the falls, one has to cross this bridge- less water crossing. *Thoreau Falls Trail has no bridge at the Thoreau Falls crossing.
During a rain event, this crossing can be dangerous, and one slip could result in a person being dragged down
A-45 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
Thoreau Falls. The only way to avoid this crossing is by bushwhacking upstream to the Appalachian Trail and then hiking back down the Thoreau Falls Trail to view Thoreau Falls.
3) Thoreau Falls will still be accessible - Thoreau Falls will not be closed if the Thoreau Falls Trail bridge is removed. People will still be able to visit Thoreau Falls from the Appalachian Trail. The bridge in question and Thoreau Falls are located on opposite ends of the Thoreau Falls Trail. And Forest Service has stated the trail will remain open, only the bridge will be removed, which means the Thoreau Falls Valley will still be accessible.
4) Compared to the removed suspension bridge - In 2009, the 180 foot long suspension bridge that crossed the East Branch of the Pemigewasset River, along the Wilderness Trail, was removed because of safety concerns. Removing this suspension bridge eliminated a very popular hiking and cross-country ski loop. The 60 foot Thoreau Falls Trail bridge crosses the same river, only deeper in the Pemigewasset Wilderness, the water-crossing is much shorter, and it receives much less hiker traffic than the Wilderness Trail bridge did.
This comparison alone makes it very difficult to justify replacing the Thoreau Falls Trail bridge. To remove a bridge from a very popular trail and then replace a bridge on a trail that is lightly used is not justifiable.
5) Cross-country skiers - If Thoreau Falls Trail is a popular cross-country ski route how are skiers crossing the bridge-less North Branch of the Pemigewasset River at Thoreau Falls? Even though I have never seen ski tracks along the Thoreau Falls Trail, I don't doubt skiers use the trail. It is a beautiful area during the winter, but how are they crossing the bridge-less, water crossing on the North end of Thoreau Falls Trail? Refer to #2.
A-46 White Mountain National Forest – Pemigewasset Ranger District
6) Safety- Safety is a concern, but the reality is people are crossing bridge-less brooks and rivers
•every day in the White Mountains. A good example is downstream from the Thoreau Falls Trail bridge at the site of the suspension bridge that was removed in 2009. People, including myself, are crossing the river at the removed suspension bridge site frequently without issue. It is the same river the Thoreau Falls Trail bridge crosses, only it is a much wider crossing, and deeper in spots.
7) The Pemigewasset Wilderness is not really wilderness - The Pemigewasset Wilderness is one of six wilderness areas in the White Mountain National Forest. Referring to #8, the Wilderness Act of 1964 defines wilderness as an area that may also have historical value. The Pemigewasset Wilderness is not without human influence and is rich with East Branch & Lincoln Railroad artifacts, but by definition it very much is considered wilderness. These designated areas are unique in character and are unlike other areas in the National Forest. If they are managed like the rest of the National Forest, the meaning of wilderness will be lost.
Many years from now, the current human impact in the Pemigewasset Wilderness will be gone. And a future generation will be able to enjoy this wilderness as it once was. What we do today can help guarantee this.
8) Definition of wilderness - The Wilderness Act of 1964 defines wilderness in this way: "A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally
A-47 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type' of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value."
9) Designated wilderness area - The Thoreau Falls Trail bridge is located in a designated wilderness area, and these areas are governed under the National Wilderness Preservation System and the Wilderness Act of 1964. Both have strict guidelines when it comes to man-made structures in designated wilderness areas, and permanent improvements are not allowed within these areas. Removing the Thoreau Falls Trail bridge, which is considered a permanent man-made structure under the Wilderness Act, would push the Pemi Wilderness that much closer to the "Natural State" it once was.
10) Replacing the bridge - If Forest Service decides replacing the bridge is the best option they need to stay true to wilderness values and build the new bridge with only natural materials from the immediate area of the bridge. A modem day bridge placed in this location will ruin the spirit of the Pemigewasset Wilderness. And if this can't be done then the bridge should not be replaced.
In my opinion, rebuilding this bridge would undermine wilderness values, and the above reasons are why I feel the Thoreau Falls Trail bridge should not be replaced.
A-48 White Mountain National Forest – Pemigewasset Ranger District
37 I would like to go on record as opposing the proposed See Safety Concerns Summary removal of the Thoreau Falls Trail hiker bridge. Response, located at the beginning As a long-time hiker and skier in the "Pemi", I believe that of this appendix, in regards to removal of this last remaining bridge will make a vast area whether the bridges are necessary of the Pemigewasset Wilderness inaccessible to all except for safety. an elite few. This project does not deny access, The scoping letter identifies the time of peak usage of the the EA does acknowledge there bridge and trail to be during the summer months. That is will be high water events during also the time of lowest water levels and when weather which access will not be possible, conditions are most forgiving. During those times fording primarily occurring outside of the the river is certainly a possibility. primary season of use. However, I am a backcountry skier, and over the past years have seen an increase in backcountry activity during the winter months. During those times, the risk associated with an open river crossing during periods of high water and cold temperatures is a significant safety risk, for both recreationalists and rescue personnel. Removal of the Thoreau Falls Trail bridge would make a large area inaccessible during the non-summer seasons. Over the past 10 years, climate change has certainly been evident, based on my observations. I have participated in, and often led, X/C ski trips, known as the "Pemi Ski Thru", from the winter parking area on Rte 302 near Zealand Road through the Pemi to the Lincoln Woods area. Originally we used to plan these trips for late March, which allowed for a greater, more consistent snowpack, and longer daylight hours. Our original route used to take us south on the Shoal Pond Trail, with a river crossing at Stillwater Junction on ice bridges. Several factors came into play. First, the decreased maintenance and blazing on Shoal Pond Trail made it progressively difficult to follow in the winter (obviously we are experienced winter travelers, very familiar with map and compass skills). Second, late winter
A-49 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
weather has changed, we have seen increasingly earlier thaws and flooding rains. These climatic changes resulted in difficulty crossing at Stillwater Junction - arriving to find ice bridges washed out and torrents of raging water. Thus the decision was made to change the route from Shoal Pond to Thoreau Falls Trail. Hurricane Irene was not particularly nice to Thoreau Falls Trail, either, resulting in several re-routes up the east bank away from the old railroad grade. But we had a dependable means of crossing the East Branch on the bridge. During recent past winters we have had to move our ski trip up by almost 3 week from when we used to plan, to the first weekend in March, to assure decent snow conditions. During recent trips I encountered more people recreating in the "heart" of the Pemi than I have at any time previously. Skiers, day hikers on snowshoes, campers. It was wonderful to see all these folks out enjoying THEIR National Forest. Should the bridge be removed, this segment of the Pemi will effectively be closed to winter activity. The prudent winter traveler will not take the risk to cross the East Branch without the safety of the bridge. Of course, we know not all who venture into the most-accessible wilderness areas on the east coast will make sound judgements. Meaning, lives will be endangered as folks cross the river if there is no longer a bridge. And not just those who recreate, but the rescuers who will be forced to go deep into the Pemi to aid the stricken. So I stand by my original statement - please do not remove the bridge. As it currently stands, and is clearly identified in your scoping letter, the section of trail where the bridge is located is clearly designated suitable for a bridge, particularly when one looks at the safety issues involved. We don't need an elaborate suspension bridge - a couple stout logs across the river, even without dual siderails, is entirely adequate, and in keeping with the tone of the wilderness. This area has seen mechanized activity for well
A-50 White Mountain National Forest – Pemigewasset Ranger District
over 100 years, so pristine wilderness - old-growth forest it is not. Should you desire future communication with me please do not hesitate to contact me. I appreciate your interest in this project.
A-51 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
38 I request that you do anything within your power to See Safety Concerns Summary prevent the removal of the bridge at the lower end of the Response, located at the beginning Thoreau Falls Trail across the East Branch in the of this appendix, in regards to Pemigewasset Wilderness. About seven years ago, the whether the bridges are necessary USFS needlessly removed another nearby bridge across the for safety. East Branch, which eliminated several popular hiking and The Forest Service considers all x-c skiing routes in the Pemigewasset Wilderness. Both of comments received during the these bridges required some maintenance, but those costs analysis process. We do consider pale in comparison with the costs of bridge removal. But, the merits of the comments more important, removal of these bridges places hikers and presented in light of statutory and x-c skiers, as well as their would-be volunteer rescuers, at regulatory guidance and look for fatal risk should they try to wade across the river. The USFS information not previously in New Hampshire has apparently ignored all public input considered and information not into their poor decision making the past few years, and considered sufficiently. The removal of these bridges is only the latest example. potential for increasing risk without a bridge in high water situations was acknowledged and disclosed in the environmental assessment.
A-52 White Mountain National Forest – Pemigewasset Ranger District
39 I am opposed to any further removal of bridges in the See Safety Concerns Summary WMNF Pemigewasset Wilderness. Response, located at the beginning The earlier removal of a bridge today imperils all whose of this appendix, in regards to itinerary now includes fording the East branch -- a huge whether the bridges are necessary error in WMNF judgement. for safety. This recent plan to remove the Thoreau bridge will add still
another threat and safety obstacle to so many winter trampers and backcountry skiers. I would invite the money to be used to rebuild the Pemi bridge instead -- or at least actually remove the debris from the deconstruction of the Pemi (Camp 10) bridge. Please, do no further harm.
40 I write tonight to express my opposition to further bridge Maintaining the bridges for hiker removal in the Pemigewasset Wilderness. convenience is not a criteria in the I have used the bridges on many hiking trips, and dozens of guidelines for wilderness x-country ski traverses and would appreciate being able to management. continue to use them in the future. I did not appreciate the See Safety Concerns Summary removal of the bridge spanning the East Branch several Response, located at the beginning years ago, but at least that time there was an alternate route of this appendix, in regards to out to Lincoln Woods, thought longer, and less enjoyable whether the bridges are necessary than the route along the opposite shore. for safety. Removing the Thoreau Bridge will be worse. Please, Please, Please do not remove this bridge. Many of us use it.
41 I oppose any further removal of bridges in the WMNF See Safety Concerns Summary Pemigewasset Wilderness. Removal of these bridges Response, located at the beginning imperils the safety of hikers and skiers experiencing the of this appendix, in regards to wilderness the area is intended to preserve, particularly whether the bridges are necessary those traversing across the Pemigewasset Wilderness from for safety. north to south in the winter, often arriving at a bridge in the
dark. In the absence of a bridge, either an attempt to cross
A-53 Pemigewasset Wilderness Thoreau Falls Trail Bridge Removal Project
the frozen surface on potentially questionable ice or, alternatively, adding unnecessary miles to a taxing trek in often dropping temperatures, unnecessarily increases the risk of serious injury or death. A number of us are drawn from out of state to enjoy the unique wilderness quality of the Pemigewasset, contributing in the process to the New Hampshire economy. We want to continue to do so, safely. To what end are public monies spent on wilderness preservation if not for those properly trained to be able to traverse that wilderness without unnecessary risk of life and limb, due to the elimination of existing bridges? Please prevent any further removal of bridges in this area.
A-54