Proposed Mt Bike Routes Threaten Willamette NF Wildest Land_Comment Letter

To Middle Fork District Ranger Duane Bishop, Deputy District Ranger Mrs. Juilerat, Mr. Rowell, Mr. Torres, and Willamette Nat’l Forest Supervisor Tracy Beck.

In regards to the proposed 2+ mile Cowhorn Cut-off Trail inside the 157,000 Acre Oregon Cascades Recreation Area and Bunchgrass Trail Connector connecting the 9,000 acre Cornpatch Roadless Area with the 9,000+ acre Mt David Douglas-Fuji Mt Roadless Area.

I visited the Windy Lakes inside the Oregon Cascades Recreation Area as well as followed the first half mile of the flag line for the proposed Cowhorn Cut-Off Trail into the Windy Lakes area on Saturday October 20, 2018. (See Map Pic #1). The trail would start off of Trail # 3643 at the intersection of Trail # 3642 about 1 mile east of Lake Timpanogas.

Within the first 1/10 mile of the proposed trail the route comes within 75 feet of a 3-4 acre lake (Pic #2) which has no evidence of human use. This small un named lake and wetland area will be impacted via access from this new trail if it’s allowed to proceed.

After about a half mile along the "flag line “ I proceeded off trail to the Pacific Crest Trail (PCT) to reach the “middle" Windy Lake to assess human impacts. Once I reached the PCT I proceeded south where the PCT is nearest the Windy Lakes. I proceeded off the PCT trail cross county to the “middle" Windy Lake. It is about a 400 feet drop in elevation and about a half mile.

The Windy Lake (I’m estimating 30 - 50 acres) closest to the Pacific Crest Trail had not one foot print or evidence of human activity until one reached Trail # 3850 that proceeds to the southern most Windy Lake. 

I found one fire ring right off the trail (Pic #3) but it was at least 100 feet from the lake bank and I found no evidence of human impact to the lake shore (Pic #4). 

As I proceeded along the Trail # 3850 among 300 - 500 year old Mt hemlock to the southern most Windy Lake I discovered a few Mt bikes tracks. Upon reaching the lake the trail abruptly disappears into a patch of grassy sedges about 40 feet from the lake bank where one can see some humans or animal had been sitting or laying (Pic #5). I did not discover any evidence of camping or a fire ring. 

I proceeded back to the PCT and headed south towards Cowhorn Mt and Indigo Lake. Upon getting back on the PCT I quickly discovered Mt bike tracks on the PCT (Pic #6). They continued as far as the Cowhorn Mt trailhead and Trail # 3643 to the Indigo Lake Trail. Mt biking is prohibited on the PCT. Image # 7 is of the "middle" Windy Lake, a smaller lake, and Crescent Lake to the right via a PCT vista.

As I approached the Indigo Lake on Trail # 4238 from Windy Pass every trail switch back had substantial erosion damage (Pic #8) from Mt bikes from either braking too hard or going to fast or simply over use. Solving this “Mt bikes vs. switchback” problem seems to be a mystery thus far. In the interim, water bars need to be intensively maintained on the these soft volcanic soils to prevent serious erosion from snow melt and thunderstorms. 

I arrived at Indigo Lake just before sunset. As one can see (Pic #9) the bank along Indigo Lake and at least 150 feet from the lake is bare dirt from years of camping impacts and over use. I did not have time nor access (all sites seem full) to assess how many fire rings are around this portion of the lake. I suspect that the Windy Lakes would suffer a similar fate if the proposed Cowhorn Cut-off trail is built. 

As I noted in earlier correspondence Mt bikes already have access to the Windy Lakes via several other trails east of Summit Lake and near Crescent Lake so if they really have the desire to visit the Lakes then they can ride about 6 miles or thereof to access the lakes.

If this proposed Cowhorn Cut-off trail is built to the Windy Lakes the lakes will be severely degraded environmentally because of easier access to all of them. It will also impact people who visit the area who seek solitude as well as hunters. If allowed to proceed this will obviously increase human users many times its current numbers thus have significant impacts to rare and sensitive wildlife, significant impacts to the water quality of all the Windy Lakes via soil impacts as well as "toxic fire pits" with burned garbage, and significant impacts to plant and animal communities along the banks of all the lakes because of physical impacts as well as invasive species introduction. 

RE: Bunchgrass Trail Connector. Some of the CE maps seems to be incomplete. 

I also have major concerns about the proposed Bunchgrass Trail connector which would connect the 9,000 acre Cornpatch Roadless Area to the 10,000 acre Mt David Douglas-Fuju Mt Roadless Area. There are very large and sensitive meadows where the current Bunchgrass Ridge Trail (Tr. # 3559) literally cuts through (Pic #10 of Big Bunchgrass Meadows)and is still recovering from the Warner Creek fire of 1991. I hike and visit this roadless area several times a year when it is not under snow. There are numerous high-intensity fire impact areas and meadows along the Bunchgrass Ridge trail that need less use - not more - until it fully recovers. 

In closing I would urge the Willamette National Forest to either withdraw their proposals that would dramatically increase human impacts and severally degrade the Cornpatch Roadless Area, the Oregon Cascades Recreation Area, as well as sensitive and rare wildlife within or prepare an environmental analysis such as an Environmental Impact Statement which must assess impacts from Mt bikes, increased camping, "fire ring toxics" via garbage burning (Pic # 11), introduction of invasive species on rare and sensitive wildlife as well as cultural resource impacts inside these inventoried roadless areas in the Willamette National Forest. I will re-interate that Agency dollars be spent on maintaining and repairing existing trails to minimum safety standards instead of building new trails. I’ve seen and documented damage on every trail I’ve hiked in the Willamette National Forest over the last 25 years and beyond and all of them without exception are in need of repairs and basic maintenance. This need is only increasing not decreasing because of the huge increase of Mt bike and equestrian users.

Thank you for your time is this matter.

Shannon Wilson

League of Wilderness Defenders &

Eco Advocates NW


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