Thank you for sending us the Environmental Assessment for the proposed CDNST reroute from Lujan to La Garita Wilderness.
The mission of the Continental Divide Trail Society, established in 1978, is to help in the planning, development, and maintenance of the CDNST as a silent trail and to assist users plan and enjoy their experiences along the route. We have approximately 250 members, from all parts of the United States and several countries overseas. Many of our members hike the CDNST, including the area of the proposed reroute, every year. We welcome this opportunity to comment, with the hope that you will find our views helpful in your planning.
We entirely agree with your statement of the need as presented on pages 2-3 of the EA. Many of the existing segments, as you there recognized, are located well below the continental divide, and have little or no resemblance to a true continental divide scenic trail. "On many segments of the new trail the hiker will have a strong sense of remoteness from sights, sounds or indications of human development" (EA, p.23), consistent with the Comprehensive Plan's direction to locate the CDNST, where possible, in primitive or semi-primitive non-motorized ROS classes (IV.B.5.c.(1)).
We particularly acknowledge and appreciate your emphasis upon this facility as a national scenic trail, with special Congressional designation and goals, a trail envisaged as a simple facility for foot and horseback use.
Moving the route off of roads and close to the Divide will represent a great improvement.
We wish to comment, however, on three matters of concern that merit your careful consideration: (1) potential realignments of the proposed route in order to improve the hiking experience, (2) alternative opportunities for access to water, and (3) mountain biking.
Many factors come into play in selecting the best location for the CDNST treadway. Proximity to the Continental Divide is one of these factors: as stated in the Comprehensive Plan (IV.B.1.b.(3)), the trail shall be located as close to the geographic Continental Divide as possible. But the route is to be as far away as necessary to provide for "diverse recreation appeal" (Ibid.)
One aspect of this recreation appeal is enhancement of scenic viewing opportunities. So, if for example, the crest of the Divide is in a viewless forested setting, the location might well be adjusted to pass by a scenic outcrop at a somewhat lower elevation. In addition, from the hikers' perspective, it is important to avoid PUDs -- i.e. pointless ups and downs. Our experience, and feedback from hikers over the years, tells us that the use of contouring footways will often result in much enhanced recreation appeal. As the new trail passes "through predominantly forest cover" (p.23), with limited viewing opportunities, we believe this concern needs to be addressed. Opportunities for middle distance and background views of scenic features such as the La Garitas, the Sangre de Cristo Mountains, and Cochetopa Dome are to be welcomed, but there is no need to remain on the ridge of the Divide where subtended by forest vegetation (p.25).
We have reviewed the proposed reroute location with this in mind and call the following potential realignments to your attention.
[North to south]
USGS North Pass Quadrangle. Between Lujan and North Pass, contour west of hill 10989. This already appears to be your plan; if practicable, we would recommend that the Trail remain no higher than 10600 feet of elevation here. From North Pass to Luders Spur, try to avoid the tops of hills 10998 and 10684 unless they offer notable vistas. From Luders Spur to Cochetopa Pass, contour as practicable, particularly east of hill 10422. South of Cochetopa Pass, contour west of the Continental Divide, through the saddle east of hill 10165, in order to provide more convenient access to Los Creek (see comments on access to water).
USGS Cochetopa Park Quadrangle. Ascend gradually on the east side of the Divide.
USGS Saguache Park Quadrangle. Taking into account our comments below on access to water, we request reconsideration of the proposal to descend to Monchego Park (900 foot elevation loss) and ascend a similar amount to return to the Continental Divide. West of Saguache Park Road (787), the proposed route may minimize potential conflict with motorized users traveling on the mapped jeep trail; it might nevertheless be worthwhile to remain closer to contour if the blue spots on the map represent likely sources of decent water or if the open terrain offers greater scenic opportunities than would be the case for the wooded ridgeline of the Divide.
USGS Elk Park Quadrangle. No comments.
Access to Water
Southbound hikers, in most seasons, will be able to obtain water from Razor Creek, an estimated 7.1 miles north of Lujan Pass. There is also a small streamflow in Lujan Creek, a half mile west of Lujan Pass. There is an evident need for the new segment to be routed so users have access to water at one or more locations along the way, as reflected in the statement of issues on page 7 of the EA.
The EA (p.24) identifies two locations on the proposed new alignment that would afford direct access to live water: Monchego Park and Luder's Campground. We have questions about each of these.
Monchego Park. The EA provides very little information regarding the water here – only that it is "not very fast flowing and leads into a stock pond." For that reason, the water source here may benefit from some ... development/improvement." (There are some small springs about 3/4 mile to the northwest, but a detour of that distance is undesirable.) Let us assume that water of reasonable quality can be expected, with confidence, to be found here; we can only endorse an alignment to Monchego Park as a last resort. As indicated above, we would be displeased by the elevation changes that would be necessitated in order to access Monchego Park; following the ridgeline, through the openings depicted on the topographic maps, would be a more scenic and enjoyable way to proceed.
Luder's Campground. The EA provides little information regarding the water here. The USGS map shows the creek to be ephemeral. Information on the Forest website cautions "NO POTABLE WATER" ... "No drinking water for humans." We are not especially concerned about this (inasmuch as hikers must routinely purify or filter) so long as the stream always flows. But there are other drawbacks as well – camping would be in a developed area rather than an open space, and the schedule might not accommodate some early season hikers.
We believe that Los Creek is the best accessible water source between Lujan Pass and Cochetopa Creek. In the guidebooks that we have published, we have been advising CDNST users, since 1986, that Los Creek "though small ... should prove to be a dependable water source." In all that time, during which we have regularly monitored hikers' journals and other media, we have never received a report that Los Creek was dry. The guidebook mentions "a scenic view out over the grassy valley." (This description refers to the existing alignment, on the Cochetopa Park map; it would probably not be necessary to descend that far, as the headwaters on the North Pass map appear as a perennial stream.) To access Los Creek, realign the route south of Cochetopa Pass through the notch to the east of hill 10165 and intersect the Jakes-Los jeep trail; from this point, we estimate that water would be found no more than 0.5 mile down the jeep trail, with an elevation loss of 300 feet or less. And even if the proposed alignment along the Divide were retained, a spur to Los Creek would be more convenient that the Luder's Spur. Assuming that the Trail is realigned to bypass Monchego Park, the distance between Los Creek and Cochetopa Creek (at the southern end of the reroute) is approximately 19 miles – a longer interval than we like, but manageable.
[The guidebook mentioned above is: James R. Wolf, Guide to the Continental Divide Trail: vol. 5: Southern Colorado, 1986, and revised ed., 1997.)
The EA declares that "in general terms, bicycle use on the CDNST is not consistent with the overall objectives for the CDNST" (p.28). We entirely concur with this statement, which properly reflects the Comprehensive Plan's description of the nature and purposes of the CDNST -- namely, "to provide for high-quality scenic, primitive hiking and horseback riding opportunities and to conserve natural, historic, and cultural resources along the CDNST corridor." [referenced in FSM 2353.42]
The legislative and administrative record repeatedly speaks of the trail as a simple facility for foot and horseback use. In this regard, refer to the 1976 study report of the Bureau of Outdoor Recreation (quoted in the Comprehensive Plan) – "one of the primary purposes ... would be to provide hiking and horseback access to those lands where man's impact on the environment has not been adverse to a substantial degree and where the environment remains relatively unaltered.... . The Continental Divide Trail would be a simple facility for foot and horseback use...." The same understanding is confirmed in the Forest Service's adoption of a final environmental impact statement that refers to adverse impacts that would occur for some of the trail segments due to anticipated increased use by hikers, horseback riders, and pack animals. (46 Fed.Reg., 39867, Aug. 5, 1981)
Several potential adverse impacts associated with mountain biking are outlined at page 28 of the EA. We agree with the discussion there, but would elaborate on the social effects that are of particular concern. The survey data provided by Mr. Appel (p.22) shows that the current CDNST route already attracts significant, and increasing, mountain bike use. We consider it very likely that if the CDNST were realigned as proposed, with adoption of Alternative 3, mountain bike travel would mushroom. If it were once established, any efforts to limit or prohibit it might, as a practical matter, be in vain. (Consider the precedent of mountain bike use on the CDNST between Monarch Pass and Marshall Pass.)
It is extremely important to maintain the opportunities for solitude and unhurried appreciation of the scenery along a long-distance continuous Trail. For many – and probably most – users, it is these qualities that attract them to undertake the challenge of the CDNST. These are the qualities that offer the "maximum outdoor recreation potential" contemplated by the National Trails System Act. This route should be managed in a manner faithful to its special designation as a national scenic trail and as a component of the National Landscape Conservation System – not just as another Forest trail. An emphasis on the uses mentioned in the history of the CDNST and the Comprehensive Plan will encourage hikers and horsemen to enjoy the experience that the Trail offers; mountain biking (as well as other potential incompatible uses) might lessen its attractiveness, with the result that some of the intended users will be dissuaded from setting out on the CDNST.
We have in mind the relatively small, but growing, number of individuals who find a 3000-mile hike along the CDNST to be a challenging and life-enriching experience. But consider as well individuals such as a couple, members of our Society, who spend about three weeks each summer hiking south along the Trail. To date, they have trekked through Montana and Wyoming. They are seeking a particular kind of experience – as natural as possible. I doubt that they would choose this place to spend their short vacations if the route were to become a corridor for bicycles.
As a personal note, I hiked the Appalachian Trail nearly 40 years ago. That was an experience that changed my life, leading me ever since to work to promote the values of the CDNST. The remoteness and quiet setting of the AT (which is closed to mechanized as well as motorized travel) – are attributes that make it so outstanding and attractive. These qualities continue to inspire me. I believe the CDNST was intended to, and should, emulate the principles that have guided the AT. And, in so doing, it can live up to its potential.
The Forest Service can surely accommodate the desires of bicycle users, to a significant degree, while reserving the CDNST for foot and equestrian travel. To do so, the bike route would use the existing CDT alignment from Lujan Pass to the point along Cochetopa Creek that is intersected with the proposed new route (roughly, 38 4.099 N, 106 47.972 W). Here it would ascend Gunnison Forest trail 472(?) ["jeep trail" on Elk Park Quadrangle] and then on up to the Continental Divide [see road, just outside La Garita Wilderness, on Elk Park Quadrangle], then north along the Divide for four miles on Road 597 [Rio Grande NF map] , then descending north to Van Tassel Gulch ["jeep trail" on Elk Park Quadrangle], returning to start on existing alignment. There would be optional alternate routes available via roads 3D and 745 [Rio Grande NF map].
Although bicycle use may be allowed on the CDNST in certain instances, in this case it would substantially interfere with the nature and purposes of the CDNST, for the reasons set out above. It should therefore not be permitted along the Lujan to La Garita Wilderness trail reroute. FSM 2353.44b 10.
The Continental Divide Trail Society recommends adoption of Alternative 2, modified in accordance with our comments regarding alignments and access to water.
We would welcome the opportunity to review our concerns with you at your convenience. I can be contacted by e-mail (email@example.com) or as indicated below.
CONTINENTAL DIVIDE TRAIL SOCIETY 3704 N. Charles St. (#601) Baltimore MD 21218