Trail Closures Proposed at Tellico!

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CandyPants

K9CRZ
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Yep...it's on now folks.

Please cross post all over the place.
OK folks, the Forest Service is on the move and has taken the first step to close three trails: Lower 2, 7 and 9. They have also taken the first step to closing all of Tellico over the winter months. Now is when we are going to need your help.
Here is the letter that was sent out:

Dear Interested Public,

I am seeking comments on two proposals to establish new Forest Supervisor’s Orders on the Upper Tellico Off-Highway Vehicle (OHV) Area in Cherokee County, North Carolina. This OHV area, located 15 miles north of Murphy on the North Carolina/Tennessee state line, includes approximately 38 miles of existing roads and trails that are managed for motorized recreation use. The following actions are being proposed:

1. A Forest Supervisor’s Order prohibiting motorized vehicles on Lower Trail # 2, Trail # 7, and Trail # 9, duration of order not to exceed one year or until a reasonable plan is in place to prevent adverse impacts to the aquatic resource.

2. A Forest Supervisor’s Order prohibiting winter-time motorized vehicle use on the Upper Tellico OHV Trail System from January 1 to March 31 each year. This would include all trails in the system except Trail # 1 and the upper section of Trail # 2 which would remain open as system roads used by vehicle types normally found on public roads.

The following persons would be exempted from these orders:
• Persons with a permit from the Forest Service specifically authorizing the otherwise prohibited act or omission.
• Any Federal, State, or local officer, or member of an organized rescue or firefighting force in the performance of an official duty.
• Owners or lessees of land in the Closure Area are exempt from the prohibitions listed above to the extent necessary to gain access to their land.
• Residents in the Closure Area are exempt from the prohibitions to the extent necessary to gain access to their residences.

PURPOSE AND NEED FOR THE PROPOSED ACTIONS

These actions are needed to correct and/or repair ongoing impacts to the aquatic resource caused by sediment entering area waters from the Tellico trail system.

Action # 1, prohibitions on Lower Trail # 2, Trail # 7, and Trail #9, is needed to provide immediate short-term resource protection measures. The greatest impact to area waters is coming from the movement of sediment off these three trails, as indicated by observation and on-site measurements of turbidity and suspended sediment concentrations.

Action # 2, winter-time closure of the OHV Area, is needed to provide resource protection. Forest Service personnel have observed that most of the damage to the trail tread occurs during the winter freeze/thaw period from January to late March, at which time soils are subject to increased rutting and displacement.

These actions would implement direction in the Nantahala and Pisgah National Forests Land and Resource Management Plan to emphasize protection of perennial and intermittent streams in compliance with North Carolina Forest Practice Guidelines Related to Water Quality.

The actions would be implemented pursuant to 36 CFR 261.50 (b) which states, “The Chief, each Regional Forester, each Experiment Station Director, the Administrator of the Lake Tahoe Basin Management Unit and each Forest Supervisor may issue orders which close or restrict the use of any National Forest System road or trail within the area over which he has jurisdiction.”

Before a final decision is made I welcome your comments. Please make your comments as specific as possible along with supporting reasons why you believe your comments should be considered. Please include your name and address in any correspondence.
Your comments may be sent to Tusquitee District Ranger, 123 Woodland Drive, Murphy, NC 28906. Comments may also be sent via email to comments-southern-north-carolina-nantahala-tusquitee@fs.fed.us.

We would appreciate receiving your comments by October 17, 2007.
Thank you for your time and interest in our management activities on the Tusquitee Ranger District.
Sincerely,

/s/ Tina R. Tilley, Acting District Ranger
TINA R. TILLEY, Acting District Ranger

So there it is. Now, let me explain the process they are following and what may or may not happen.

A "Notice of Supervisor's Order" is the first step in their process to enact new “Supervisor’s Orders” for an this action. The Letter is used to notify potentially interested parties of a proposed action and to solicit comments on the proposed action and its Purpose and Need. The action here is defined by them as:

“A Forest Supervisor’s Order prohibiting motorized vehicles on Lower Trail # 2, Trail # 7, and Trail # 9, duration of order not to exceed one year or until a reasonable plan is in place to prevent adverse impacts to the aquatic resource.

A Forest Supervisor’s Order prohibiting winter-time motorized vehicle use on the Upper Tellico OHV Trail System from January 1 to March 31 each year. This would include all trails in the system except Trail # 1 and the upper section of Trail # 2 which would remain open as system roads used by vehicle types normally found on public roads.”​

A proposed action is worthless if its purpose and need is not good. In this case, they are saying that these "closures" are "needed to correct and/or repair ongoing impacts to the aquatic resource caused by sediment entering area waters from the Tellico trail system." They go on to say:

“Action # 1, prohibitions on Lower Trail # 2, Trail # 7, and Trail #9, is needed to provide immediate short-term resource protection measures. The greatest impact to area waters is coming from the movement of sediment off these three trails, as indicated by observation and on-site measurements of turbidity and suspended sediment concentrations.

Action # 2, winter-time closure of the OHV Area, is needed to provide resource protection. Forest Service personnel have observed that most of the damage to the trail tread occurs during the winter freeze/thaw period from January to late March, at which time soils are subject to increased rutting and displacement."​

They can basically just say “close it” or “don’t close it.”

OK, so they have proposed their action and purpose and need and are asking for comments. We need to provide those comments to them. This is where you come in.

THE TEMPLATE LETTER IS DONE! CLICK HERE ---> https://forum.ih8mud.com/showpost.php?p=2576814&postcount=17

Drop me an email if you have any questions and I will try to help. If you don’t get a response from me, please don’t be offended. There are only so many hours in a day. I’ll do my best to help as much as I can. My email is Heather.Spivey at sfwda dot org

Let’s get it going folks. Don’t let them take our Tellico away from us!
 
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I did too.
 
Put it up over in the GA section of Yotatech
 
Soil erosion control measures are an important thing to consider if you wan to insure the long-term integrity of an ecosystem, especially a stream (riparian) environment. as much as I love to wheel, the proposed closures COULD be justified. I say could because one needs to take exactly what factors and data the forester/regulator has used and taken into account here. I like to fish as well as knock the s*** out of my truck in the woods but if 4 wheeling here is going to lead to severe or even moderate degredation of the environment it should be moderated or temper. stopped until a solution has been made. We don't want to lok like a bunch of hoodlems (even though most of us are:))
 
Soil erosion control measures are an important thing to consider if you wan to insure the long-term integrity of an ecosystem, especially a stream (riparian) environment. as much as I love to wheel, the proposed closures COULD be justified. I say could because one needs to take exactly what factors and data the forester/regulator has used and taken into account here. I like to fish as well as knock the s*** out of my truck in the woods but if 4 wheeling here is going to lead to severe or even moderate degredation of the environment it should be moderated or temper. stopped until a solution has been made. We don't want to lok like a bunch of hoodlems (even though most of us are:))

Um, you might want to search and read all the relevant posts.
 
Soil erosion control measures are an important thing to consider if you wan to insure the long-term integrity of an ecosystem, especially a stream (riparian) environment. as much as I love to wheel, the proposed closures COULD be justified. I say could because one needs to take exactly what factors and data the forester/regulator has used and taken into account here. I like to fish as well as knock the **** out of my truck in the woods but if 4 wheeling here is going to lead to severe or even moderate degredation of the environment it should be moderated or temper. stopped until a solution has been made. We don't want to lok like a bunch of hoodlems (even though most of us are:))

Agreed infojunky. And I understand what you are saying F-Junker. However, the Forest Service has NO information that supports their claims that erosion is coming from the OHV area specifically. And further, nothing that proves that the three trails named are the major sources of that run off.

While I agree in principle that erosion issues are somthing that we as a community need to be aware of and manage carefully so that we don't have an impact on our environment, this is a situation where a well known special interest group is bullying the Forest Service into unjustified, non-supported closures based on hearsay and allegations by that special interest group.

If you want to discuss erosion, best managment practices, and sediment control...bring it on. But in this case, it is clearly an action to attempt to avoid a lawsuit by said special interest group. This ain't only about dirt, its also about who has more support to get their agenda fulfilled.

I'll also add that we have been down this temporary closure road before. Do a little searching around the Georgia Cruiser's corner for Anderson Creek. The Forest Service decided to close it down temporarily to do an environmental analysis. That was close to 4-5 years ago I think. It's still closed and the study is not done. If the FS closes something for "analysis" you can kiss it goodbye. We've been there and done that and we are not about to let that happen without a fight.

Been a long few days, so this is pretty hot on my mind right now. Sorry if I am coming off a little strong. If you have questions about what is going on, please feel free to PM me.

Thanks.

*rant off*
 
erosion

Erosion happens just like something else that normally preceeds that line. How much, when, and exactly what are determined by parameters to numerous to eloborate on here. Hearther is corect, the presented data does not document where, how much, how much of an increase over "normal" bacground levels, or what is coming from the trails. Nor do they addressif this is having a detrimental effect on the aquastic systems. The just do not have the data needed to analyize if there is a problem and what the source of the problem is. So, ask them to provide that data. One way or another they will need to acquire it, so lets have some input on the how, where and when they get it from.

To that end, I sent the following to the FS:

Ms. Tina R. Tilley
Acting District Ranger

Ms. Tilley,

As a long time practitioner of ecosystem restoration and an off-road enthusiast I feel compelled to comment on the recent notice to establish a new Forest Supervisor’s Order for the Upper Tellico ORV area. I have followed the recent events and am concerned about the science and conclusions drawn. While there may be times when turbidity levels exceed State requirements, there was no direct data linking that turbidity to discharge from the Upper Tellico ORV area. The same is true of the “observed” increase in sediment load and deposition. To my knowledge, there are no sampling locations above the ORV area measuring inputs into the system therefore, any observations or conclusions drawn about effect within or below the area can not be attributed to the Upper Tellico ORV area or its use. Furthermore, turbidity measurements and regulations normally pertain to land disturbing activities, such as vegetation removal due to development. The ORV area is still in a “natural” state and it would be a very long stretch to conclude that vehicular activity is a land disturbing activity. The supposition that off-road vehicle tires carry dirt from the uplands or cause fall-back while crossing streams is not a land disturbing activity. Furthermore, there is no basis in the Clean Water Act for a permit for such activities. The use of fall back was dismissed by the US Supreme Court a few years ago, and the US Army Corps of Engineers would be hard pressed to validate the need for an Individual or Nationwide permit for these activities. Based on the above and the natural resilience of stable streams I question the data used to arrive at the need for trail closure.

Best Management Practices (BMPs) are a way of life for the Forest Service and other agricultural providers. The volunteers assisting in trail maintenance have provided hours of time and equipment to moderating any effect of the trails on the aquatic resources of the area. The few times I have used the area I did not notice any erosion control matting or other trail stabilization methods utilized, especially those proven to ameliorate erosive forces on foot and multi-use trials. With the vast resources of the user groups, several of these BMP’s and trail maintenance measures could be implemented. This would greatly reduce the potential of sediment transport into the aquatic resources of the area with out the need to close trials.

In summary I would request that the Forest Service revisit the need to close trails within the Upper Tellico ORV area. Further data gathering and assessment are needed in order to ascertain the source of any sediment influx. Site specific rehabilitation methods would then have to be developed to address these inputs.

As an active participant in the use of the ORV area, a member of Trout Unlimited and active outdoorsman I would appreciate being added to the list of interested parties receiving updated information on this very important issue. Thank you for you attention and the ability to comment on this issue.
 
Last I saw on the template...

SFWDA is working on a template letter that you can use to provide your comments. Of course, you don’t have to follow the template, but if you choose to provide your own comments, please do so with the following guidance in mind:
  • Be professional, courteous, and do not be angry or aggressive in your tone.
  • Please use the spell check feature on your computer. Misspellings make you look stupid.
  • Please address the action at hand. Do not go on a rant about the “greenies” who you think are forcing this action. Be succinct and to the point about how this action is going to effect you and why you think the Forest Service should not close the trails. Be persuasive and do not ramble.
  • Please provide them with alternatives to trail closure. The Forest Service did not propose any alternatives other than closure. What about temporarily rerouting trails? What about installing more erosion controls?
  • Please question their science and observations. The Forest Service did not provide any scientific data in their letter to prove that their “observations and measurements” are true. They also did not provide the analysis that they used to determine that there even is any “impact” to the area. They are assuming there is an impact.
  • Please be sure to be clear that you do not support this action and wish to be added to the list of interested parties to receive updated information regarding any action at the Upper Tellico Off-Highway Vehicle (ORV) Area.
Comments should be either emailed or mailed to:

Tusquitee District Ranger
23 Woodland Drive
Murphy, NC 28906
comments-southern-north-carolina-nantahala-tusquitee@fs.fed.us.
 
Here is what I wrote:
__________________________

Good afternoon,

My name is <your name>. I am a resident in <your state> who frequents the Tellico ORV area several times a year. I am writing with regard to a recent letter I have read regarding emergency closures of certain trails, as well as the consideration of an annual closure of all the trails at the Tellico ORV area. My intent with this letter is to show my distinct opposition of this course of action and to request my contact information (<your email>) be added to any further communications around the Tellico ORV area.

My opposition is not unfounded. I have read the proposals and letters that I have been able to find and comprehend the reasoning proposing these closures. I have concerns relative to the evidence used to justify these closures. My understanding is that there have been suspended sediment and other turbidity measures taken at these trails, but not before the trail system. How is it conclusive that the trails are the primary source of the sediment when there is no other control data to support this statement? I know there is development, logging, and other activity in the area that could contribute to these measurements as well.

Please do not take away the area that my children and I have grown to love. We camp, hike, and take out truck on the trails to enjoy nature, not destroy it. We tread lightly. We stay on marked trails. We contribute hours of our time to help put up signage, clean, and improve the area. I know of hundreds like me that do the same. Please do not allow this to happen!

I am willing to help in any way. Please feel free to contact me.

<Signature>
 
Thanks for putting that up Dan, but there is a lot more that we want people to say. The lawyers letter just went out yesterday, so we'll have something for you soon.

Hang tight.
 
Yep, I am happy to follow up with more detail, just wanted the letters to start flowing from me immediately :)
 
Write a letter to save Tellico!

FROM SFWDA, UFWDA, and BlueRibbon Coalition:
As you know, in response to the recent request of the Forest Service to comment on the two proposals to establish new Forest Supervisor’s Orders on the Upper Tellico Off-Highway Vehicle (OHV) area, Southern, United, and BRC have enlisted the services of Carla Boucher and Paul Turcke to submit a formal response letter. In addition to that, we think it is important that you comment on the proposals as well. The request for comment is located here http://www.sfwda.org/trails/tellico/tellico20070917.html for you to read. We are providing you with a template letter with the following suggested outline in preparing your letters and remind you to put it in your own words. We urge you to mail your letters in before the identified date of October 17, 2007.

Your letter should be mailed to:

US Forest Service
Nantahala National Forest
Tina Tilley, Tusquitee District Ranger
123 Woodland Drive
Murphy, NC 28906
  • Include the date
  • Include the file reference information (File Code: 2350-5/1950)
  • Include reference (Supervisor’s Orders on the Upper Tellico Off-Highway Vehicle (OHV) Area
  • Tell them who you are and why you are writing
  • Give your general and specific comments including:
  1. The importance of the Tellico area to recreation and surrounding communities and the effects the closures will have
  2. Tell them why you think the specific trail closures (Action #1) on Lower Trail 2, Trail 7, and Trail 9 is not justified
  3. Tell them why you think the proposed winter closure (Action #2) is not justified
  4. If you know the science, then talk the science
  5. Talk about how no data has been provided and ask for the scientific data on which the closures are being based
  6. Talk about all the mitigation/maintenance work you/your group/Southern has done and continues to do
  7. Talk about what Tellico means to you, why you and your family value it, how you practice Treadlightly!, how you participate in trail clean up, etc.
In conclusion, express your opposition courteously but strongly one last time
Include a statement of your support of the joint letter sent by Southern, United, and BRC.
Request you be added to further communications
Give your contact information
Signature

Please also remember to be courteous and substantive. In other words, “get it off my chest…” type comments are of little or no value. Finally, you need to keep a copy of your letter for future reference.
If you would like to use a TEMPLATE LETTER, here is one that you may cut and paste to use. PLEASE BE SURE TO ADD YOUR THOUGHTS IN THE LAST PARAGRAPH.
U.S. Forest Service
Nantahala National Forest
Tusquitee District Ranger
123 Woodland Drive
Murphy, NC 28906
INSERT DATE
RE: File Code : 2350-5/1950
Supervisor’s Orders on the Upper Tellico Off-Highway Vehicle (OHV) Area
Dear District Ranger,
My name is YOUR NAME HERE and I am writing at to express my concerns about the above-referenced Supervisor’s Orders addressing vehicle use of the Upper Tellico OHV Area.

My understanding of the September 17, 2007 letter is that the Forest Service intends on enacting two new Supervisor’s Orders that will close the Upper Tellico OHV Area during the winter months, and will close specific trails (Lower#2, 7 and 9).
Trails Lower#2, #7, and #9 should not be closed. From your letter and from the research that has been conducted, there is no scientific evidence that the Tellico trail system or any one trail in particular, have any impact on streams in the area. The streams that were sampled originate above the OHV area, and samples were only taken down stream of the OHV area. In order to demonstrate that sediment load is coming from a specific area, it is necessary to sample the stream/river both upstream and downstream of the area.
With respect to seasonal closures of the entire area, your agency did not provide and I have not seen any proof that demonstrates the time of year is directly tied to increase potential for impacts. There is no data provided by your agency to suggest that sedimentation from January 1 to March 31 occurs at a higher rate than sedimentation during other months of the year, which makes a winter-time closure unfounded.
[Write a paragraph here about what Tellico means to you. Talk about what you do to preserve the area, talk about how your practice Tread Lightly and how you participate in trail clean up, etc.]
The OHV community is willing to support reasonable management prescriptions, but the Proposed Orders are not rationally connected to the proposed riding restrictions. A well-conceived and thoughtful planning process should be conducted rather than hastily-prepared Orders in response to closure demands of anti-access special interests. My intent with this letter is to show my strong opposition to these and any trail closures and to request my contact information be added to any further communications regarding the Tellico ORV area.
YOUR NAME
YOUR ADDRESS
YOUR E-MAIL
YOUR PHONE NUMBER

Very truly yours,
SIGN YOUR NAME
TYPE YOUR NAME
 
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Awesome! :)
 

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