PO Box 14814 • Portland, • 97293

November 11, 2010

Michelle Lombardo Mt. Hood National Forest 16400 Champion Way Sandy, Oregon 97055

Subject: Barlow District Road Decommissioning

Dear Ms. Lombardo:

Trailkeepers of Oregon (TKO) supports the ongoing National Forest (MHNF) effort to identify roads for closure and decommissioning, especially when both environmental and recreational objectives can be achieved as a result of closures. This is a major turning point for the agency toward sustainability and a renewed recreation and conservation focus.

We offer these comments in strong support of the closures currently proposed for the Barlow District. The deteriorating network of logging roads in this part of the MHNF has also left many the trails truncated and increasingly difficult to reach, thus discouraging recreational use.

We believe road closures and accompanying trail system enhancements would allow for more convenient, safe access for recreation in these areas for hikers, cyclists and equestrians.

Our comments do not attempt to cover the entire Barlow District, and instead, focus on the proposed closures focus in the Barlow Butte/White River, Frog Lake Buttes and Boulder Creek shown on the map to the left.

We are recommending a bolder approach than you have proposed in the scoping materials, both for road closures and trail system enhancements. In making our recommendations, we followed these overall criteria in identifying road closure and conversion opportunities:

 opportunities to close or decommission deteriorating, unsafe trailhead access roads by relocating trailheads to safer, more well-traveled routes

 restoring areas of high recreation potential wherever possible through the removal of roads, or conversion of roads to trails

 limiting roads-to-trail conversion to cases where an obvious enhancement to trail networks exists in order to continue focusing scarce trail resources on existing trails and strategic new trail connections.

Barlow Butte/White River

To help restore this highly accessible area to a backcountry condition with an emphasis on quiet recreation, we recommend closing and decommissioning all roads shown in red on the following map:

(a larger version of this map is shown in Attachment A)

Barlow Road Decommissioning Page 2

We also propose the following trail system enhancements through road conversions and new trail segments, as shown on the previous map:

1. Proposed Barlow Pass Trail - North Section – we recommend converting a series of roads to trails (shown in yellow), joined by new trail segments, in order to create a new Barlow Pass Trail that connects the White River Trail (No. 538) to the year-round trailhead at Barlow Pass. The north section would consist of converting roads 3560 and 011 to trail, and connecting this new converted road segment to the Barlow Butte Trail (No. 670) with a short new trail segment, just east of the Barlow Pass trailhead.

Because this proposed new trail exists outside the wilderness area that encompasses Barlow Butte, it would allow for bicycle loops from Barlow Pass or the trailheads along Barlow Creek using the new Barlow Pass Trail and historic . It would also provide for hiking and equestrian use.

2. Proposed Barlow Pass Trail - South Section – to complete the new Barlow Pass Trail, we propose converting the portion of Road 240 shown in yellow on the map to trail, and constructing a new trail connection, shown in orange, to the White River Trail (No. 538).

The new trail segment represents a substantial project, and is one that TKO would be interested in partnering with the Forest Service to design and construction. Because of the potential to serve cyclists and equestrians, we anticipate volunteers from these communities having an interest in the project, as well, with TKO serving as volunteer coordinator.

3. Proposed Barlow Butte Cutoff – the proposed Barlow Pass Trail creates an opportunity to formalize use of an unmaintained trail on Barlow Butte to provide new access from White River to the scenic summit ridge of Barlow Butte. A short new trail segment (shown in orange) would connect converted Road 3560 (shown in yellow) to the unmaintained cutoff trail (shown in green), and could be part of a TKO partnership with the MHNF.

4. Proposed Barlow Butte Cutoff – we recommend converting Road 240 to trail from Klingers Camp historic site to the White River Trail (No. 538) roughly one mile north of the historic site, thus extending the White River Trail. This expanded route would continue to serve hikers, cyclists and equestrians, and would provide access from the Klingers Camp trailhead to the new Barlow Pass Trail.

Frog Lake Buttes Backcountry

Like the adjacent Barlow Butte area, road decommissioning on the east slopes of Frog Lake Buttes offers an opportunity to restore the area to a backcountry condition, with an emphasis on quiet recreation.

Barlow Road Decommissioning Page 3

To help this area recover from the intensive logging that has occurred over the years, and the heavy OHV use that the area currently suffers, we recommend decommissioning all roads shown in red on the following map:

(a larger version of this map is shown in Attachment B)

With the new MHNF OHV plan in place, the Frog Lake Buttes area can now be managed with an emphasis on quiet recreation that complements expanded wilderness encompassing the buttes, and the proximity to the adjacent Twin Lakes wilderness and Pacific Crest Trail corridor.

The area includes the scenic Catalpa and Green lakes, yet the existing trail network is disjointed and confusing. Therefore, we recommend the following road-to trail conversions, complemented by new trail segments:

1. Proposed Green Lake Trail - East Section – to create a new trail to Green Lake, we propose conversion of the portion of Road 250 (shown in yellow), accompanied by re-designation of the western portion of the Bonney Meadows Trail (No. 471) from the Barlow Creek trailhead to converted Road 250 as part of the new trail, to avoid confusion for recreationists. This conversion would also include a very short trail extension from the terminus of Road 250 to Green Lake. Barlow Road Decommissioning Page 4

The full extent of the trail from Barlow Creek to the lakes would be open for hikers and equestrians. However, we also propose maintaining Road 250 access to the current Catalpa Lake trailhead in order to provide bicycle access to the converted road portion of the new Green Lake Trail, which lies outside the Twin Lakes wilderness boundary.

2. Proposed Green Lake Trail - West Section – to provide for loop hike and backpack opportunities through the Twin Lakes wilderness from the Barlow Creek trailhead, we are proposing a new trail segment (shown in orange) that extends the proposed Green Lake Trail to the Frog Lake Butte Trail (No. 484). Like the new trail segments proposed for the Barlow Pass Trail, TKO could be a partner with MHNF in helping plan and construct this new trail segment.

3. Proposed Barlow Creek Trail – we recommend converting Road 220 to trail (shown in yellow on the map), extending from a new trailhead at its south terminus on Forest Road 43 to its north terminus near the Grindstone Campground, with a midpoint trailhead at the Barlow Creek Campground. We also recommend a short, new trail segments from the north terminus of converted Road 200 to the Grindstone Campground and from the south trailhead to the Barlow Crossing Campground to complete the network.

This new trail would provide an outstanding new bike and equestrian trail, given the grade, opportunity to design the tread for these users, and proximity to three campgrounds. It would also be open to hikers.

Boulder Creek Backcountry

The road closure initiative provides a unique opportunity to restore the environmental integrity of Boulder Creek drainage, while also expanding recreation opportunties. This is an area already popular with hikers, cyclists and equestrians, but badly impacted by the legacy of logging roads. Our general recommendation is to decommission most roads in the area (those shown in red on the map on the next page), converting some to trails.

The Boulder Creek area provides an especially strong potential for cyclists and equestrians, due to the lack of wilderness restrictions (for cyclists) and the proximity to the Badger Creek wilderness, popular with equestrians.

We recommend the following trail system enhancements through road conversions:

1. Bonney Butte Trail – we recommend converting Road 130 (to Bonney Butte) to a trail (shown in yellow on the map, below), and establishing a trailhead and pullout at the junction of the new trail and Road 4891 (which we recommend retaining as a popular and somewhat historic primitive road).

Barlow Road Decommissioning Page 5

(a larger version of this map is shown in Attachment C)

Barlow Road Decommissioning Page 6

While we recognize that Road 130 is used for activities related to the Bonney Butte raptor project, the very short length of this road means that a conversion to trail would have little impact on current users, and would likely enhance the wildlife habitat on the butte. Converting the road is also the best way to recognize the new wilderness designation that follows the west side of Road 4891, and encompasses Bonney Butte.

2. Little Boulder Lake Way Trail – one of the best opportunities for a road-to-trail conversion is for Road 123 (shown in yellow), which terminates within a few dozen yards of Little Boulder Lake, and also connects to the Forest Creek Trail (No. 473), creating a loop between the Boulder Lakes and Bonney Meadows. Our proposal includes a 100-yard segment of new trail connecting Road 123 to Trail 473.

The clear conservation objective of this conversion is to prevent OHVs from reaching Little Boulder Lake, and thus we were disappointed that this road was proposed to remain open in the scoping materials released by the MHNF. We urge you to reconsider your position on this road.

3. Relocate the Boulder Lake Trailhead – our most substantial recommendation for the Boulder Creek valley is to relocate the Boulder Creek Trailhead to a point roughly 3.5 miles south of the current trailhead, on Road 4880. Under this proposal, the segment of Road 4880 from the new trailhead to Swamp Creek would be converted to trail, leading to the Hidden Meadows (No. 472) and Forest Creek (No. 473) trails.

The converted road, Forest Creek Trail and extended Little Boulder Way Trail would become the new approach to the Boulder Lakes from the south, and by design, is a longer approach. Boulder Lake, in particular, suffers from heavy use as a result of the very short trail access that currently exists, threatening the health of the lake.

This proposal also allows for most of Road 4880 to be decommissioned, providing great environmental benefits to the Boulder Creek Watershed, since the road currently follows the stream corridor for more than six miles into the upper canyon.

4. Proposed Boulder Way Trail – building on the proposed new Boulder Lake Trailhead, we propose a road-to-trail conversion of an unnumbered road (see map) that branches from Road 4880 at the new trailhead and descends almost to Boulder Creek. This road is not shown in your scoping materials, but provides an important new trail opportunity, and should be called out. Our proposal also calls for an additional quarter mile trail segment to connect this converted road to the Boulder Creek Trail (No. 478). This new trail would become the Boulder Way Trail.

Barlow Road Decommissioning Page 7

This proposal also assumes that the Boulder Creek Trail would come back into maintenance (unclear, now, since the trail shows up on the MHNF database but is not listed as a maintained trail on your website).

The significance of this connection is to provide a major new backcountry loop hike combining Boulder Lakes and Boulder Creek that would be open to hikers, equestrians and cyclists. If constructed, this would represent the most extensive backcountry cycling opportunity in the MHNF, and the only overnight “bike-packing” trail. This is also consistent with the new “national recreation area” designation for the Boulder Creek area.

5. Proposed Grasshopper Point Trail – as part of developing a strong network of connecting trails in the Boulder Creek backcountry, we recommend converting the full extent of Road 4870 to become the Grasshopper Point Trail, with the purpose of providing access to the Boulder Creek Trail (No. 478) from a new trailhead where Road 4870 intersects Road 4860, near Post Point. This new trail would focus on equestrian use, given the close access from paved Forest Road 48, and the lengthy approach into the Boulder Creek valley.

6. Grasshopper Point Trail Extension – to complete the trail network on the east side of the Boulder Creek valley, we recommend that a new trail be constructed from the terminus of converted Road 4870 and Grasshopper Point, a former lookout site and prominent viewpoint that would provide an attractive destination for hikers, equestrians and cyclists. This would become the northern segment of the proposed Grasshopper Point Trail.

TKO could partner with the MHNF to help design and construct this extension, ideally in conjunction with bicycle and equestrian advocates, since this new connection would provide a major new route for these trail users.

We are also recommending that the Grasshopper Point Road (Road 4860) remain open, though it is seldom used, since it provides access to Badger Lake for irrigation district purposes. Because of the rugged nature and light vehicle use on the road, it can function as a bicycle and equestrian connection from Grasshopper Point to intersecting trails that connect to the Boulder Lake and Boulder Creek trails, forming attractive new loop options.

How We Can Help

In our short history as trail advocates, TKO has built a solid track record of active stewardship with USFS since 2007. We are co-sponsors of the annual Trail Skills College, which began at Cascade Locks in June 2009. We have also worked closely with other trail advocacy groups, and our board membership spans a variety of Mount Hood National Forest environmental and recreational stakeholders, so are able to coordinate diverse volunteer partnerships in tandem with the USFS.

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We would like to be part of the planning and constructing the trailhead and trail building opportunities proposed above, and look forward to partnering with you in making these proposals a reality. We are especially excited about the opportunity to offer our trail-building support to leverage road decommissioning that provides clear conservation and recreation benefits.

As a first step toward building this partnership, we would like to suggest a field trip with the Forest Service to some of the opportunity areas to see the possibilities on the ground, and would be happy to coordinate such trips into the field as snow levels permit.

Thank you for considering our comments, and please feel free to contact me ([email protected]) with any questions or suggestions on these proposals.

Sincerely,

Ron Northway, President Trailkeepers of Oregon P.O. Box 14814 Portland, Oregon 97293 [email protected]

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