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USFS - Eldorado National Forest

 The Forest Ground Operations application for Operations and Maintenance funding is so monolithic that I’ve elected to respond to it separate from the other elements of the Eldorado National Forest Grant Application. I’m not sure whether to criticize this or congratulate it. Batching a bunch of projects together the way Eldorado has done in their Ground Ops grant aggregates them in a practical way for submission, but it also allows just about every box to be legitimately checked on the Evaluation Criteria. This is quite an advantage for scoring – possibly an unfair advantage, when other Ground Ops grants are scored and ranked against these aggregate multi-projects. Nothing can really be done for this set of grants, so I commend the Forest for delivering a project with such a high score, even as I question whether it was fair to other O&M applicants to do so.
 
Deferring maintenance would put the ENF trail systems at risk and could result in the need for costly restoration projects in the future that might otherwise be unnecessary. The result of deferring the maintenance work outlined in this project would be an increase in the long term costs of providing OHV recreation on the Eldorado NF, which must not be done – the backlog of deferred maintenance is one of the primary reasons repeatedly raised for the many closures that resulted from the Route Designation / Travel Management process. It’s tough not to be in favor of projects that include trail repair, drainage structure maintenance and installation, clearing of downed trees, brushing, and sign repair or replacement on designated OHV routes, posting of kiosks and information bulletin boards at designated OHV trailheads and staging areas, servicing vault restrooms at staging areas, installation or maintenance of barriers needed to restrict travel off of designated routes, monitoring associated with the OHV use and resource protection needs… and I shouldn’t even be able to complain much about printing and distributing Motor Vehicle Use Maps, but THAT definitely deserves further comment.
 
I understand that good maps will sustain OHV access and help prevent the creation of unapproved trails, and that MVUMs are an essential part of educating and informing OHV users about the designated roads and trails and are also critical in eliminating off-route travel, but I DO NOT find these to be acceptable maps. The ENF MVUM map is too minimal with no lake, river, peak, campground, topographic, or other context – this makes them downright unusable, and a tool that could have been used to keep users on the trail is almost entirely wasted. Worse yet, Region 5 is pushing a separate grant request to provide the REST of the content on a separate map… so the MVUM is a ‘freebie’ that is nearly worthless, and now users are going to have to pay through the trust fund or out of their own pockets for a map that they can actually use?!?!?! I’m at a loss as to how to comment maps in this grant – I support the reasons for creating these maps, but I can’t support continued production maps with such marginal value, especially not fifteen thousand of them at $1.50 per unit, as noted in the Contract Expenses Line Items. Please rework these maps at minimum to show major peaks, bodies of water, campgrounds, and topographic contours (recommend a minimum of 200-foot topographic countours to keep the routes as the primary focus) in addition to the existing map’s presentation of designated roads and trails that are open to motorized use. This would add minimal complexity to these maps but would add IMMENSELY to their usability. I’ve worked with subsets of USFS GIS files, and it would be less than a day’s work to turn these few layers on and re-insert the map element in the print files. As well, please work this $22.5K chunk of maps through multiple bids; I pay for printing in my professional life and expect that many more than 15K units can be purchased for that $22.5K.
 
I have several other specific comments:
- This grant application proposes to use a combination of FS employees, California Conservation Corps crews, CalFire inmate crews and volunteers to accomplish trail maintenance work, tread repair on trails too narrow for use of the SWECO or mini-excavator, or when motorized equipment is not otherwise available, but does not detail which trails are too narrow for a SWECO. Travel Management cut out most of the high-quality single-track motorcycle experiences on all public land, and especially in the ENF. As few single-track trails remain, this is an exciting development about which ENF should share more information widely about where these hand crews will be working.

- The Forest Ground Ops grant application includes measures to address off-trail resource issues occurring on National Forest System lands adjacent to the Rubicon Trail, including an OHV Manager and 120 days of a Technician’s time to monitor efforts to address human waste disposal. Please provide more information on this program before submitting the final grant proposal. Rubicon trail users need to know the scope and intent of this program so that they can assist and stay informed. ENF requested grant funding for similar efforts last summer, but has not shared the outcomes, counts, or progress from that program, and we must avoid a similar unpublished outcome for the program proposed in this grant application.
- Please rewrite the section of the Project Description in the Project Cost Estimate worksheet that refers to ‘resource impacts’ and ‘discharges,’ since so little conclusive documentation exists to quantify these impacts. While the CVRWQB has indeed issued a CAO to USFS and El Dorado County, no direct impacts have been measured to the waters of the State -- at most, there is *potential* for impacts. Let’s work together to mitigate these potential impacts, but carefully avoid overstating the problem until it can be better-defined.
- The only line item that really jumped out at me from the Project Cost Estimate spreadsheet was the item for one SWECO Advanced Operator Training for $39.6K. That seems quite high (about half the price of an actual Sweco Trail Dozer!), please check the price and provide more information.
 
ENF has solid relationships with the Hi-Lander 4Wheel Drive Club on Barrett Lake Jeep Trail, and OHV coalitions and organizations like Friends of the Rubicon, Rubicon Trail Foundation on Rubicon Trail. In the larger context, covering the whole Forest, the Friends of Eldorado National Forest coalition has a great history of pitching in, and the California Association of Four Wheel Drive Clubs has provided volunteer support for many decades. These clubs, coalitions, and organizations work tirelessly in the ENF, and outreach to them makes sense to deliver the 325 days of volunteerism that this Ground Ops grant application identifies for this grant, which equates to 2520 hours of volunteerism (assuming an 8-hour day). The values of these hours are a little, odd, since this ENF Forest Ground Ops Application values volunteers at $138/day which equates to $17.25/hour and the ENF Patrol Grant Application values volunteers at $15/hour, and the Barrett Application values volunteers at $20.25/hour. Please identify the difference or correct it to synchronize these applications. I hope ENF continues to maintain and improve these relationships to drive education and volunteerism, but beyond that, many hundreds more undocumented hours are devoted to the Forest every year by OHV volunteers. I encourage the Forest to work even harder to formally document these hours, it will draw them closer to the volunteers and helps with the match to OHMVR. This is truly a win-win-win proposition, since it binds federal, state, and local resources together to work on the trail resources that they all value.
 
In the Public Input section of the Evaluation Criteria, the application describes public notification starting March 2, 2010. This is just not enough notice – in future years, I’d request that the Forest develop proposals and discuss them with potential partners. This would avoid ‘surprising’ partners by linking them to projects they’d not yet discussed, and allows the Forest to identify and confirm a longer list of partners. The March comment period for OHMVR is not a sufficient interval for users to work with their Forest. I’ve asked for more information several times above in my grant comments, and there’s no real opportunity to obtain the information I have requested and comment further on this new information. Generally, on future grants it would be useful to have more details on what types of maintenance will be done, and where it will be done. I don’t want this to be an obstacle for approving this grant, but it would help with future accountability. This grant application has good information about what will be done, but insufficient information as to where that work will be done.
 
I have a general comment, as well -- I’ve never been particularly comfortable with the use of grant funds to *maintain* departments; I look at grant funding more as a way to jump-start programs and ‘prime the pump’ than as sustaining funding in perpetuity. Requesting $350K for staff in a total proposal for $515K means that 68 percent of the request is staff-directed, which seems like sustaining dollars that the agency should be primarily providing. I’m more in favor of the proposed actions in this Forest Ground Operations grant than I am concerned for the staffing usage for this year, but I would encourage USFS to plan next year with a different approach, and carry staffing/management costs on USFS budget, saving the grants for project-specific materials or contract costs. [Randy Burleson - 4/5/10]


 General Application Requirements --
The OHV Visitor Opportunity Summary in this and other grants is skewed by mixing thousands of acres of winter access while thousands of miles of trails are closed to OHV during seasonal closure. With 12 months of OHV opportunity documented, this incorrectly gives the impression that both the trails and acreage are open year-round to all vehicles, which is not the case. I know this is a flaw in the Evaluation Criteria themselves, and will comment this to OHMVR for discussion for subsequent years, but I felt obliged to comment it here. In the meantime, please correct the start/end dates on Question 1a (not 2006 or 2007)
 
For Question 2, I assume these items are documented on the MVUM map, and if that’s the case, you’ll need to uncheck the following items.
* Map with OHV Recreation opportunities clearly shown is available on the Land Manager’s website (the MVUM is anything but clear since it lacks context: with lake, river, peak, campground, topographic countours, etc)
* Map indicates relative difficulty of each OHV trail (MVUM maps do not clearly document relative difficulty)
* Map indicates appropriate OHV use type (ATV, dirt bike, 4x4, OSV, etc.) (with black/greyscale only, MVUM maps do not well-differentiate between various OHV types or seasons of allowable use)
It is incredibly frustrating that ENF delivered such a minimal MVUM map after the OHV trust fund pumped twelve million dollars into the statewide USFS Travel Management process. ENF needs to deliver a USABLE document with lake, river, peak, campground, topographic contours, and other context, and it is unconscionable to even consider following the Region’s strategy of charging extra for the type of usable map OHV users should have received in the first place. I appreciate that ENF use many methods of communication to reach its various users, but the MVUM map needs work. Hopefully funding this grant will move them well towards this goal. Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.
 
For Question 13, I don’t believe that Sound Level Testing occurs with the 50%-or-greater frequency listed -- I've *NEVER* seen it in Eldorado National Forest, where I recreate 50% or more of the summer weekends. Please substantiate where and when testing occurs – I suspect you'll find that ENF provides sound level testing on less than 25% of holidays and weekends. The application states that sound testing is routinely conducted during OHV events, but I doubt that there are sufficient events to get the average up to 50%. Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.
       
-- PLANNING GRANT - Rubicon Trail Dispersed Use --
I support this grant request that will designate appropriate camping/picnicking/recreation areas alongside the Rubicon Trail, and re-open motorized access routes to them. While I’m ideologically opposed to calling this ‘the development of dispersed camping,’ I still support the project, and grant funding for it (campsites can be dispersed <i.e. undeveloped> or developed <undispersed>, but not both, and I wish the agencies would stop blurring that line). The funds from this grant would fulfill the ‘due diligence’ environmental analysis and design required by the inexplicably overlapping rules that govern development, and please all the anti’s and -ologists that might otherwise stop this project in the middle of its implementation – if you focus on the ends, this project delivers a good result for OHV users, even if it does thrash a great deal while getting there. I’m particularly pleased to see Eldorado National Forest acknowledge their role in responding to the requirements of the Cleanup and Abatement Order (CAO) that the Central Valley Regional Water Quality Board (CVRWQB) imposed on Eldorado National Forest and El Dorado County.
 
Why this area was not included after consideration in ENF’s Route Designation / Travel Management process continues to frustrate me, but it pleases me that USFS is honoring their commitments to execute continued management process even after the FEIS/ROD to review routes for addition into the Forests’ System of Roads and Trails. Route Designation incorrectly closed many small spurs along Rubicon by erroneously excluding them from consideration during Route Designation (USFS elected not to consider routes near Rubicon because they deemed it to be a County Road -- while the road itself is a public highway through El Dorado and Placer Counties, these stub roads off of it are indeed historic routes on USFS property that should have been considered for inclusion into ENF’s System of Roads and Trails). It is particularly satisfying to see this small reversal in fates – these area were popular for dispersed camping before Route Designation (most were created when the Forest was open to motorized travel, and then later legislatively deemed to be ‘unauthorized’) and they will be popular again once the planning is completed, and the actual work can be done. I support this grant in that it would study what should have been done during Route Designation, and allow a return to historic usage patterns, with all the I’s dotted and T’s crossed for the -ologists.

 I’d like USFS to correct several oversights and omissions in their description of the resource:
* There are too many things wrong with the following statement to count: “El Dorado County is currently managing the trail, however the Forest Service is responsible for management of the uses off of the trail.” Please replace it with this full statement, which accurately reflects ownership, claims, responsibility, and right-of-way. “Rubicon Trail is a public highway / right-of-way that runs through El Dorado and Placer Counties, crossing public lands in Eldorado National Forests, Tahoe National Forest, and the Lake Tahoe Basin Management Area, as well as multiple privately-owned parcels. The Counties provide some management to the right-of-way itself, and the agency-owners and private property owners are responsible for management of uses and resources alongside the rights-of-way.”
* The following sentence is incorrect for several reasons: “Visitor counts conducted in 2003 and 2005 indicate that as many as 35,000 OHV’s travel the Rubicon 4WD Trail during the summer months (EDC Draft Rubicon Trail Master Plan, 2007).” First, that 35,000 figure drawn from estimations executed in 2001 (not 2003 and 2005) has been proven incorrect and over-generalized time and time again – I’ve attached a Rubicon Trail Foundation White Paper that dispels this mythical information and provides a more realistic assessment of annual use: XXXX.“ The county-commissioned consulting firm, Environmental Stewardship and Planning, estimated trail use to be significantly less than 35,000 in 2004, and Friends of the Rubicon confirmed the much lower trail usage in 2005 by performing extensive holiday weekend counting. Subsequent Rubicon Trail Foundation counting studies estimate well under a third of that 35K RECREATION DAYS number made so long ago (note that this was a rec-day count and NOT an OHV count!). A further problem exists with citing information from the Draft Rubicon Trail Master Plan – the El Dorado County Board of Supervisors refused to certify this document or the work contained in it. For the purposes of this grant, I suggest replacing the sentence quoted above with the following sentence: “Visitor counts conducted in 2005 by FOTR and 2009 by RTF show that the Rubicon Trail enjoys approximately 25,000 _visitor_days_ per year, and that the vehicle count is less than half off that.”
* The following sentence is also incorrect – see the details in the first bullet of this section of my comments: “As described previously, the trail is managed by El Dorado County and the Forest Service manages the uses off of the Trail.” Please replace this overly-simplified interpretation with the following sentence: “Rubicon Trail is a public highway / right-of-way that runs through El Dorado and Placer Counties, crossing public National Forest lands and multiple privately-owned parcels. The Counties provide some management to the right-of-way itself, but the agency-owners and private property owners are responsible for management of uses and resources alongside the rights-of-way.”

* Please correct the following sentence: “By designating appropriate dispersed camping areas, the proposed planning project will aid in reducing the impacts from improper disposal of human wastes…” to read: “By designating appropriate dispersed camping areas, the proposed planning project will aid in reducing CONCERNS OF improper disposal of human wastes…”
 
Specific scoring improvements are available:
* under Question 2: Planning Project, there is erroneous information about ‘past closures along Rubicon Trail’ needs removed. This explanation currently states: “Past closures along the Rubicon Trail have occurred for all public use due to human waste impacts.” Though Spider Lake was indeed closed due to concerns of POTENTIAL contamination, the tests made to verify this concern were inconclusive, and subsequently found to be similar to other high-country lakes (see attached Rubicon Trail Foundation White Paper that dispels this mythical contamination: “no real (contamination) pattern exists and that test samples were well within accepted limits”). I recommend stating something less-general, more correct, and more in parallel with the checkboxes that ask about “potential effects” and replacing that sentence with the following sentence: “Spider Lake was closed due to concerns of potential impacts to water quality and public health.”
* add checks for Question 3: Motorized Access to include water sports, rock-climbing, and family recreation – these routes will see increased usage since so many other routes along Rubicon Trail were shut down when they were omitted from consideration in Route Designation
* add checks for Question 7: Sustain OHV Opportunity for one or the other of the last selects  – since spur routes along Rubicon Trail were omitted from consideration in Route Designation, they were shut down and signed closed in 2005 after Judge Karlton’s 08/16/05 Forest Order that limited travel to the routes shown on the Motor Vehicle Restriction Map. Either the second to the last item is true (Project supports development of OHV Opportunities in areas that lack legal OHV Opportunity) or the last item is true (Project will develop a system of designated OHV routes for an existing OHV Opportunity) – pick one.
* add a check for Question 8: Identification of Funding Sources – OHMVR has been the source of most agency funds for Rubicon in the past decade, with some help by the County and Forest, and full volunteer matching-hour support from OHV coalitions and organizations like Friends of the Rubicon, Rubicon Trail Foundation, and California Association of Four Wheel Drive Clubs. It is no stretch to state that funding sources have been identified, even if funds are not yet fully committed.
* reword the explanation Question 9: Offsite Impacts – while the CVRWQB has indeed issued a CAO to USFS and El Dorado County, no direct impacts have been measured to the waters of the State. At most, there is *potential* for impacts, and these impacts have not been specified to come from areas of dispersed use – this incorrect and over-general interpretation needs corrected, even if it has no impact on scoring the grant. Please change this section to read: “The Central Valley Regional Water Quality Control board issued a Cleanup and Abatement Order to Eldorado National Forest and El Dorado County indicating concern for potential impact to waters of the State from recreation on the Rubicon Trail.”
Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.

Along with these questions, I’d like to compliment ENF on planning overnight stays for field staff as indicated by inclusion of Rubicon Trail per diem in the budget sheet. As far back in the woods as Rubicon resources are, it makes little sense to spend half the day commuting, leaving a half day for work, and it makes far more sense to work a full day on the trail and stay overnight, then be ready to work another full day. The per diem amounts acknowledge practicality – good work! As well, I am generally encouraged by documentation of volunteer matching and heartily encourage Forest management to do even more of this – with 320 hours of documented volunteerism built into this grant application, counting every hour will be key. I do have a question about the value assigned to these volunteer hours – the ENF Patrol Grant Application values volunteers at $15/hour, the Rubicon Planning Application values volunteers at $20.25/hour, and the ENF Forest Ground Ops Application values volunteers at $138/day which equates to $17.25/hour. Please identify the difference or correct it to synchronize across these various ENF applications.

ENF has solid relationships with OHV coalitions and organizations like Friends of the Rubicon, Rubicon Trail Foundation, and California Association of Four Wheel Drive Clubs, and I encourage ENF to continue to develop and maintain these relationships to drive education and volunteerism. Beyond that, many hundreds more undocumented hours are devoted to the Forest every year by OHV volunteers. I encourage the Forest to work even harder to formally document these hours, it will draw them closer to the volunteers and helps with the match to OHMVR. This is truly a win-win-win proposition, since it binds federal, state, and local resources together to work on the trail resources that they all value.
 
Overall, even with these factual errors, this is a good grant proposal that takes good steps toward reflecting the realities of historic usage on the ground. Omission of short routes to campsites during Route Designation dis not easily change the pattern of use even with significant efforts made to education and enforcement. This leaves us in the situation where, at many places along Rubicon, the Forest needs to buck up and deliver the engineering to catch up to the use, instead of continuing to attempt to legislate and enforce it away, pretending responsible OHV use never happened at these sites. This grant proposes a great step in that direction, and restoring access to Rubicon dispersed campsites is a promising advancement that benefits all users – and remember that while Rubicon enjoys much motorized use, it has a long history of travel by foot, by horse, and by wagon, and even today enjoys use by hikers, mountain-bikers, cross-country skiers, snowshoers, and other muscle-powered recreationists. All of these users need legal places to park, camp, and embark as they use the Rubicon Trail and the lands on either side of it.
 
-- DEVELOPMENT GRANT - Barrett 4WD Trail Bridge --
I’m very much in support of this grant proposal, as construction of the bridge will conclusively secure access to the Barrett Lake Jeep Trail, which supports 4WD, ATV, UTV, RTV, motorcycle, and mountain bike users, as well as a variety of non-mechanized users. The current route essentially crosses two creeks, and the planned routing moves primarily over granite to cross below where these two creeks join together. I’m less excited about the restoration and revegetation plans, but securing access with the re-route and new bridge is well worth supporting the whole package, regardless. Sediment delivery via the current route is truly minimal thanks to the hard work of the adopt-a-trail club, the HiLanders 4WD Club, and an overly-short allowed season of use. Considering how well-managed this trail currently is, I doubt that the bridge/reroute will have any significant effect on the well-being of the storied Yellow-Legged Mountain Frog or otherwise affect watershed health and/or water quality, but if installing the bridge will secure access to this classic High Sierra trail, it will be grant money and volunteer hours well spent! It would be even better if this new bridge and routing extended the season of use by getting the trail out of the wettest areas. Retaining access is of extra importance since this trail preserves motorized access to the Pyramid Inventoried Roadless Area.
 
ENF has solid relationships with the Hi-Lander 4Wheel Drive Club on Barrett Lake Jeep Trail. This club and their friends have worked tirelessly to maintain Barrett Lake jeep Trail and fund-raise to be able to match with cash, above and beyond their many volunteer hours. The grant application identifies 480 hours of volunteer effort for this grant. That volunteer hour valuation is a little, odd, since the ENF Patrol Grant Application values volunteers at $15/hour, this Barrett Application values volunteers at $20.25/hour, and the ENF Forest Ground Ops Application values volunteers at $138/day which equates to $17.25/hour. Please identify the difference or correct it to synchronize across these various ENF applications. If ENF corrected the rate to $20.25/hr and made even greater use of volunteers, I suspect the match could be increased over 26%, earning 3 extra points to enhance this grant’s competitiveness.
 
I hope ENF continues to maintain these relationships to drive education and volunteerism, but beyond that, many hundreds more undocumented hours are devoted to the Forest every year by OHV volunteers. I encourage the Forest to work even harder to formally document these hours, it will draw them closer to the volunteers and helps with the match to OHMVR. This is truly a win-win-win proposition, since it binds federal, state, and local resources together to work on the trail resources that they all value.
 
Specific scoring improvements are available, beyond the 26% match discussed above:
* add a check for Question 3: Diversified Use to include Recreational Utility Vehicles (RUV), also known as side-by-sides (see the Trail Report at: http://www.utvguide.net/trip_report_barrett_lake_2007.htm )
* add a check for Question 5: Recycled Materials – reroutes and restoration will make use of multiple green line Carsonite recycled plastic markers to indicate new route and close the old route. As well, downed woody material, logs, and cut branches would be placed to discourage vehicle travel (this vegetative material and boulders would be gathered from the area adjacent to the trail)
* add a check for Question 6: Sustainable Technologies – it will be simple to specify a paint with low volatile organic compound emission materials and make use of local building materials as barrier rocks, thus reducing the fuel costs and emissions that would otherwise be caused by transporting barrier rocks
* add a check for Question 10: Utilization of Partnerships – currently this is just one point, but in addition to the Hi-Lander 4Wheel Drive Club, there are other partners who fully intend to assist with successful accomplishment of this project: California Association of Four Wheel Drive Clubs, Sacramento Jeepers Club, Top Gun Club, and Friends of the Eldorado National Forest. All of these groups will tuck in behind the Hi-Landers, in support of their Adopt-a-Trail relationship with USFS Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.
Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.

-- DEVELOPMENT GRANT - Long Canyon Dispersed Use --
I support developing two acres and about half a mile total of roads in a campsite near the intersection of the Eleven Pines Road (14N08) and the Lower Meadows Road (14N16), as well as some dirt roads on Nevada Point Ridge and Ralston Ridge. While I’m ideologically opposed to calling this ‘developed dispersed camping,’ I still support the project, and grant funding for it (campsites can be dispersed <i.e. undeveloped> or developed <undispersed>, but not both, and I wish the agencies would stop blurring that line). The funds from this grant would fulfill the ‘due diligence’ environmental analysis and design required by the inexplicably overlapping rules that govern development, and please all the anti-recreationists and -ologists that might otherwise stop this project in the middle of development – but if you can focus on the end goal, this project delivers a good result for OHV users, even if it does thrash a great deal while getting there, and do so under an incorrect moniker – in the end, this will be a ‘designated campground’ not a series of ‘dispersed campsites.’
.
Why this area was not included after consideration in ENF’s Route Designation / Travel Management process continues to frustrate me, but it pleases me that USFS is honoring their commitments to execute continued management process even after the FEIS/ROD to review routes for addition into the Forests’ System of Roads and Trails. Route Designation closed thousands of miles, and seasonal restrictions further close and about a third of the year’s worth of access to what trails are left, so it is particularly satisfying to see this small reversal in fates. The Long Canyon area was popular for dispersed camping before Route Designation, and will be popular again once the work funded by this development grant is completed. I’m specifically concerned about the loss of high-quality single-track motorcycle experiences on public land, and hope that routes in this area can be developed with that in mind, especially since this area is a short ride away from the Hunter’s Trail motorcycle route.
 
I support this grant, which in the words of the forest, ”would develop an existing but unmanaged dispersed camping area,” and encourage USFS to develop similar projects that reflect the realities of use on the ground. Omission of short routes to campsites during Route Designation does not change the pattern of use without massive efforts for education and enforcement – and here as in many other cases, the Forest needs to buck up and deliver the engineering to catch up to the use, instead of trying to legislate and enforce it away. I hope that this grant request is funded and the work successfully completed – it stands as a strong example of what ENF needs to do in many other places. As a regular Rubicon user, I know many places along Rubicon trail that were incorrectly excluded from consideration during Route Designation (USFS elected not to consider routes near Rubicon because they deemed it to be a County Road -- while the road itself is a public highway through El Dorado and Placer Counties, these stub roads off of it are indeed historic routes on USFS property that should have been considered for includion into ENF’s System of Roads and Trails), and I hope that ENF uses this Long Canyon work to develop a ‘cookbook’ that can short-cut restoration of motorized access to campsites that were created when the Forest was open to motorized travel, and then later legislatively ‘unauthorized.’ Restoring access to the Long Canyon camping area is a promising first step that benefits all ENF users that drive into the Forest to execute their preferred form of recreation… unless they hike all the way there, they need legal places to park, camp, and embark.
 
I hope ENF continues to establish and maintain relationships with OHV clubs to drive education and volunteerism, but beyond that, many hundreds more undocumented hours are devoted to the Forest every year by OHV volunteers. I encourage the Forest to work even harder to formally document these hours, it will draw them closer to the volunteers and helps with the match to OHMVR. This is truly a win-win-win proposition, since it binds federal, state, and local resources together to work on the trail resources that they all value.
 
Specific scoring improvements are available:
* add checks for Question 3: Diversified Use to include motorcycle, sand-rail/buggy, ATV, and Recreational Utility Vehicles (RUV) – this route is passable by all these vehicles and will see increased usage since so many other routes in ENF were shut down by Route Designation
* add a check for Question 10: Utilization of Partnerships – currently this is not checked, but if USFS were to reach out and make a few contacts before they are required to finalize this grant, I am sure that clubs/organizations are available to assist with successful accomplishment of this project: California Association of Four Wheel Drive Clubs and Friends of the Eldorado National Forest would be great places to start.
Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.
       
-- RESTORATION GRANT – Silver Fork Road Barriers --
Though it makes good sense to repair to restore this parcel now that the Forest owns it, I have to ask how wise it was to acquire it in the first place, knowing full well how much restoration work would be required, and how much that would cost. While it was in private ownership, maintenance and impacts to Waters of the State were the responsibility of the owners, but now that USFS owns the property, an obligation exists for USFS to maintain the property and mitigate negative impacts. This liability seems large in retrospect, but it is a done deal now.
 
I question the value assigned to barrier rocks – this grant application and the Cable Road grant application value Barrier Rocks at $125/each, and the Bassi/Millionaire Camp grant application values them at $100/each. Please identify the difference or correct it to synchronize across these various ENF applications.
 
The largest single expense in this application is boulders that USFS already owns (more than 80% of the funding, or $91K in total, with $22K donated as match and $69K in request for grant funding). This gives the appearance that USFS is selling rocks it owns to OHMVR to give back to USFS at no cost. I recommend a change or an explanation.

-- RESTORATION GRANT - Bassi/Millionaire Camp Unauthorized Routes --
Here again, though it makes good sense to repair to restore this parcel now that the Forest owns it, I have to ask how wise it was to acquire it in the first place, knowing full well how much restoration work would be required, and how much that would cost. While it was in private ownership, maintenance and impacts to Waters of the State were the responsibility of the owners, but now that USFS owns the property, an obligation exists for USFS to maintain the property and mitigate negative impacts. This liability seems large in retrospect, but it is a done deal now.
 
I am generally encouraged by documentation of volunteer matching and heartily encourage Forest management to do even more of this – with 80 hours of documented volunteerism built into this grant application, counting every hour will be key. I do have a question about the value assigned to these hours – this Restoration grant values volunteers at $20.25/hour, and other grants use a range of lesser values (the ENF Patrol Grant Application values volunteers at $15/hour and the ENF Forest Ground Ops Application values volunteers at $138/day which equates to $17.25/hour). Please identify the difference or correct it to synchronize across these various ENF applications.
 
Even while I appreciate the volunteers, the answer to Question 6: Primary Funding Source does not stand up to mathematical double-checking. The biggest cost category is Staff, with a significant amount matched from USFS budgets, and a much smaller portion made up of volunteer’s donated time. Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.
 
I also question the value assigned to barrier rocks – this grant application values Barrier Rocks at $100/each, and the Silver Fork and Cable Road grant applications values them at $125/each. Please identify the difference or correct it to synchronize across these various ENF applications.
 
-- RESTORATION GRANT - Cable Road Unauthorized Routes --
It is a shame that this area was not patrolled more actively after the fuels reduction project was completed – the barriers, water bars, and mulching were great engineering, but with insufficient education and enforcement, some of these good works were essentially undone by rogue users. I’m pleased to see LEO and FPO line items in the Project Cost Estimate spreadsheet – ENF needs to assign patrols to enforce this area with higher priority lest history repeat.
 
Please revise the sentence that says: “User created OHV trails lead to many trash dump sites and the area is an eyesore to forest visitors and the surrounding community neighborhood.” I have never seen an OHV toting an appliance into the forest to abandon, and unless evidence exists to prove otherwise, it is incorrect to assume that the illegal dumps were created by OHVs.
 
As with the Silver Fork application, the largest single expense in this Cable Road application is boulders that USFS already owns (about half of the funding, or $9K in total, with $2K donated as match and $7K in request for grant funding). This gives the appearance that USFS is selling rocks it owns to OHMVR to give back to USFS at no cost. I recommend a change or an explanation.
 
Specific scoring improvements are available:
* add a check for Question 4: Measures to Ensure Success to include Educational signage, which is listed in the Project Cost Estimate spreadsheet (and update the explanation)
* change the answer for Question 8: Utilization of Partnerships – please check with both Friends of the Eldorado National Forest (FOE) and Please Leave It NRA Klean (PLINK) to ensure that they have bought into this project (if they have not, then change the answer)
* it would be simple to pick up a point under Question 9: Scientific and Cultural Studies by adding a verification component to the restoration used at Cable Road, allowing a check to be added to the box for: ‘Examine methods to ensure success of Restoration efforts.’
Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.

-- RESTORATION GRANT - Rock Creek/Poho Area Unauthorized Routes --
I appreciate that ENF is prioritizing maintenance and restoration efforts at Rock Creek – this is one of the best motorcycle sites within a few hours of Sacramento, San Francisco, and Reno.
 
I am generally encouraged by documentation of volunteer matching and heartily encourage Forest management to do even more of this – with 10 days of documented volunteerism built into this grant application (that’s 80 hours), counting every hour will be key. I do have a question about the value assigned to these hours – this Restoration grant values volunteers at $150/day which equates to $18.75/hour, and other grants use a range of other values (the ENF Patrol Grant Application values volunteers at $15/hour, the ENF Forest Ground Ops Application values volunteers at $138/day which equates to $17.25/hour, and the Bassi/Millionaire Camp Restoration Application values volunteers at $20.25/hour). Please identify the difference or correct it to synchronize across these various ENF applications.
 
Specific scoring improvements are available:
* add a check for Question 8: Utilization of Partnerships – currently this is not checked, but if USFS were to reach out and make a few contacts before they are required to finalize this grant, I am sure that clubs/organizations are available to assist with successful accomplishment of this project: California Off-Road Vehicle Association, California Association of Four Wheel Drive Clubs, and Friends of the Eldorado National Forest would be great places to start.
* it would be simple to pick up a point under Question 9: Scientific and Cultural Studies by adding a verification component to the restoration used at Cable Road, allowing a check to be added to the box for: ‘Examine methods to ensure success of Restoration efforts.’
Please re-evaluate and re-score this grant application with the above changes so that this grant application competes fairly with other grant requests.
 
Here again, I question the value assigned to barrier rocks – this grant application values Barrier Rocks at $60/each, and the Silver Fork and Cable Road grant applications values them at $125/each. Please identify the difference or correct it to synchronize across these various ENF applications.
 
-- General Comments Summary --
In general, not specific to any individual grant request, I continue to be disappointed to see how few motorized routes remain on this Forest after completion of the FEIS and ROD that came out of ENF’s Route Designation / Travel Management process, which is one of the reasons why I’m still workin with Public Lands for the People in their lawsuit against ENF’s Route Designation actions. OHV lost thousands of miles of access to roads and trails in ENF but there have been no meaningful changes to Forest staffing to reflect how many fewer miles now need maintained or patrolled, and how many fewer months those services are needed courtesy of seasonal closures. I am also disappointed at how little of the Forest is left to cross-over uses such as OHVs used over-the-snow in the FEIS/ROD. Seasonal closures and ‘Managing away’ (a.k.a. ‘closing) roads to use by wheeled vehicles over-the-snow has lost us access to hundreds/thousands of miles of access to OHV opportunity, but ENF’s funding requests continue unabated… you’d think that fewer miles of opportunity might correspond to fewer grant dollars required, but that certainly isn’t reflected in ENF’s grant requests. Let’s hope that the funds requested will result in a higher level of service on the routes that survived Travel Management.
 
I continue to support ENF’s emphasis on engaging education and enforcement by working with local user groups, and hope to see continued expansions in this effort. Informational open houses at major trailheads would work particularly well – depending on the season, a hot cup of coffee or a cold bottle of water are great icebreakers between ENF staff and users, especially with so many rules changed as a result of Route Designation. Informal on-site forums like this will be invaluable to communicating rules changes to users, most of whom would try to be legal in the midst of an inscrutable system of seemingly ever-changing rules. This sort of visible appearance at trailheads not only helps with educating on changes in rules, but sends a visibly message to criminals that Forest staff is meaningfully on the trails. Local club meetings are another great way to get education out, and prioritizing attendance by a ENF representative will pay huge dividends in user awareness and buy-in. Please continue to reach out to local clubs in the next years!
 
In future years, I encourage Eldorado National Forest to establish and maintain better documentation of ENF’s Over Snow Vehicle (OSV) program – I suspect that future grant funding would be available if ENF documented this program more thoroughly. I definitely hope to see better documentation of OSVs and over-the-snow OHVs in future grant cycles. [Randy Burleson - 4/5/10]


 I fully support this grant with my money and my time as a volunteer. [Scott Johnston - 4/5/10]



 I think that the below should be another 2 points for this grant. There were many routes in the vicinity of rubicon prior to Route Designation that were identified as not part of the system. This was opportunity that lacked legal definition.

7. Sustain OHV Opportunity - Q 7.

Project supports development of OHV Opportunities in areas that lack legal OHV Opportunity (2 points)

I also think that the explanation leads the reader to believe that designated camping is going to be made. By definition, dispersed camping can not be designated. this process needs to stay tuned to providing legal motorized access to parking that is off the Rubicon trail. Many, if not all of these routes that will be identified are existing and have been for decades.

I need to draw attentipon to the second sentence in the first paragraph of the request. "More specifically, there is a need to determine locations where it is appropriate to drive 4WD’s and other OHVs off of the Rubicon 4WD Trail to participate in these dispersed activities." this is the objective, not designating camping. This area of the ENF is open to all camping, picnicking, etc. in a dispersed manner with no restrictions of any kind.

I do support this grant as it will allow the ENF to support camping and picnicking and clearly states the future intent to apply for sanitation measures such as toilets. [Scott Johnston - 4/5/10]



 As we are sure you already know, the organizations "The Friends of Eldorado National Forest" and P.L.I.N.K. are strong supporters of the Forest Service in Eldorado, and we are committed to working with the Forest Service through volunteer efforts in order to keep our forest in good shape.
 
With this mission for our organizations in mind, we have asked several people to review and comment on the 2010 grant applications submitted to the Department of Park and Recreation: OHMVR division in order to help insure grant monies are received.
 
In reviewing some of the grant applications, several of our volunteers found this under grant request G09-02-03-R04 R Restoration - Cable Road Unauthorized Routes:
 
...The Forest would like to stop further degradation of the area by controlling OHV traffic by installing rock and gate barriers

then under section 8 for the same grant request:

utilization of partnerships
List partner organization(s):
Friends of the the Eldorado and Please Leave it NRA Clean Organization (PLINK)
 
Again, while both The Friends of Eldorado and PLINK are committed to working with the Forest Service in Eldorado, both organizations are first and foremost pro-access organizations. Our base of volunteers are forest users which are volunteering their time to ensure routes that stay open or routes are added to the forest, not to close them. We are sure that this is just a small mistake by the grant writer, who did not understand the mission of our organizations.
 
Being named in the grant request to help close routes has caused several of our volunteers to question the overall goal of our organizations, which is to insure motorized access to the forest. This could deter us from attracting volunteers on future work-parties.
 
Furthermore, neither organization was approached by the Forest Service about working on Cable road to close off these areas.
 
Please change the grant request sent into the OHMVR by removing our names from this particular project. We are willing to work on any project to enhance the forest, but our mission of promoting motorized access does not allow us to work on any projects that would close routes. If we were to work on a project to close routes, it would severely limit our ability to retain volunteers for both our organizations.
 
Committed to working with the Forest Service, [The Friends of Eldorado National Forest and PLINK  - 4/5/10]


 The California Wilderness Coalition (CWC) strongly supports the Inyo National Forest’s 2009-2010 restoration and ground operations grant application proposals for Cooperative Agreements with the The California Wilderness Coalition (CWC) strongly supports the Eldorado National Forest’s 2009-2010 restoration, ground operations, and Barrett 4WD Trail Bridge grant application proposals for Cooperative Agreements with the Off-Highway Motor Vehicle Division of the California Department of Parks and Recreation. We believe that these proposals reflect the Eldorado National Forest’s ongoing commitment to maintaining an OHV program that balances recreational opportunities with ecological safeguards.
 
We are particularly pleased by the requests for funding to restore native vegetation, close unauthorized routes, construct barriers, and perform other restoration and monitoring activities. Illegal OHV use in the Bassi/Millionaire Camp area is causing erosion and damage to sensitive riparian habitats. The proposed restoration activities in this area will help to improve habitat viability and discourage continued OHV incursions, including the potential for incursions into the Pyramid Inventoried Roadless Area (IRA). Likewise, restoration of the area around Girard Bridge along the Silver Fork Road, including the installation of barriers to prevent continued OHV use in unauthorized areas, will help to prevent degradation of the surrounding habitat and sedimentation of the Silver Fork of the American River. We also support the proposed restoration projects along Cable Road and in the Rock Creek/Poho Area.
 
Although located in the Pyramid IRA, we support the Barrett 4WD Trail Bridge Development project because we believe it will reduce resource damage that currently occurs where the trail crosses the Jones Fork of Silver Creek. On-going monitoring of the completed project should be done to ensure that OHV users are staying on the new route and that restoration of the existing route is successful.
 
We also support the Eldorado National Forest’s ground operations grant request. We hope that the proposed activities, including trail maintenance, installation and maintenance of signs and barriers, monitoring, public education efforts, and distribution of Motor Vehicle Use Maps will help reduce the problem of illegal OHV use off designated routes.
 
CWC would be happy to assist the Eldorado National Forest with the proposed restoration activities outlined in the grant application. If you need volunteers to help implement these or other projects, please do not hesitate to contact us.  [Sean Baumgarten - 4/2/10]



 Everyone asking for Grant money does it with honorable intentions to manage our public lands , provide sustainable recreation and protect resources.  I agree with all of that and am not one to say "do not fund"  but there are exceptions from my point of view. 
 
In reviewing these grants for 2009/2010  It it is alarming how the % of actual work on the ground changes from one agency to another.  From experience I would like to see no more than 5% of the grant request for staff under Ground Operation go to management.   The key to sustainable recreation on our public lands are for our grant money to be spent on the ground.  
 
Every single grantee should be preaching "Stay on Designated Trail"   regardless what your job is, it is the responsibility of every person involved with OHV that this message has to pushed.
 
Every single grantee should encourage those that are law abiding citizens to put pressure on the "Willfully Ignorant" to change their way so that we can have a "Sustainable OHV recreation"  for future generations. 
 
Lastly I want to thank every single person involved in working on  OHV recreation for your time and dedication . [Ed Waldheim "OHV activist for access to public lands for all" - 3/28/10]


 We are opposed to providing OHV money to the USFS to close the trails!

We have paid to have the trails put in to their inventory. Now they ask for OHV money to have them closed! As we have seen in the "Route Designation" process the USFS is not a good investment for OHV funds.
Give the grants to groups that actually enhance OHV opportunity, like the BLM. [Brendan Hathaway  - 3/17/10]



 Please do not give any state money to a federal agency to close our public land to us.  I whole heartedly reject what the federal government is doing to our lands.  They are tying to kill local economies and discourage people from living free.  It appears as if they all want us to sit and a desk and enjoy the forest on a screensaver. [Casey Crandall - 3/11/10]



 My continued support and gratitude to those of you involved. I love recreating in our California OHV parks. My only reservations is an interest in continuing to defend our right to ride as a priority. Obviously this effects us all. Keep working hard! Thank you, [Greg - 3/9/10]