Creative Fab
March 23rd, 2005, 09:49 PM
United Four Wheel Drive Associations
Director of Environmental Affairs
PO Box 1057
Lakeside, CA 92040
www.ufwda.org
March 17, 2005
To: Distribution
Subject: Rubicon Trail Master Plan, Second Draft
The below comments are submitted on behalf of the United Four Wheel Drive Associations (UFWDA) and its member associations, clubs and individuals. UFWDA is an international association representing over 30,000 motorized recreationists and their families. While the main focus of UFWDA is to advocate access to public lands for motorized recreation, many of our members participate in multiple forms of recreation; including but not limited to hunting, fishing, camping, hiking, horseback riding, bicycle riding, and gem and mineral collection.
We recognized the positive health and social benefits that can be achieved through outdoor activities. We also recognize that motorized recreation provides the small business owners in the local communities a significant financial stimulus. Our members are directly affected by management decisions concerning public land use.
The UFWDA members subscribe to the concepts of: 1) public access to public lands for their children and grandchildren; 2) condition and safety of the environment; and 3) sharing our natural heritage. The general public desires access to public lands now and for future generations. Limiting access today deprives our children the opportunity to view the many natural wonders of public lands. The general public is deeply concerned about the condition of the environment and personal safety. They desire wildlife available for viewing and scenic vistas to enjoy. They also want to feel safe while enjoying the natural wonders. Lastly, the public desires to share the natural heritage with friends and family today as well as in the future. How can our children learn and appreciate our natural heritage when native species are allowed to deteriorate and historic routes are routinely blocked or eradicated from existence?
UFWDA has reviewed the current second draft of the Rubicon Trail Master Plan. UFWDA supports the concept of the proposed master plan. Management with vision and strategy are key elements in providing a quality recreation experience. After careful review, UFWDA opposes the proposed second draft of the Rubicon Trail Master Plan. The proposed draft plan contains several fatal flaws that render it useless as a management tool. To be a useful management tool, the proposed master plan must be based on facts that are supported with valid data. The proposed master plan must also provide realistic goals and achievable criteria to measure the success of the plan. The draft proposed master plan does not provide realistic goals and achievable criteria.
Since 2001, recreation advocates (led by the Friends of the Rubicon) have been active in management efforts along the Rubicon Trail. Their efforts have resulted in mitigation of, or recommended solutions for, every problem federal, state, and local agencies have raised regarding the recreation experience along the Rubicon Trail. Those issues span a wide range, from erosion, to habitat destruction, to sanitation, to user conflicts.
The proposed draft Rubicon Trail Master Plan does not build off the success of these efforts. Issues remaining to be addressed include increased law enforcement, increased signage, and increased user education. The proposed draft master plan does not adequately address these issues. Nor does the proposed draft master plan address funding for these issues along with trail head facilities and campsite development.
To guide implementation, a "plan" requires goals and measurement criteria. The proposed draft master plan does not provide realistic goals and measurable criteria. For instance, the draft master plan proposes quotas and limits. However, there is no accurate data to support the proposed quotas and limits. There has been no validated study to determine the "carrying capacity" of the area. There has been no validated study to determine the "qualities" visitors are seeking along the trail. Yes, anecdotal information and crude estimates are available.
In October 2001, California State Parks OHV Motor Vehicle Commission, El Dorado County, and El Dorado National Forest staff commissioned a back country sanitation engineer to count trail use and human waste build-up that estimated 35,000 people days would be a reasonable figure for total annual use on the Rubicon Trail. In 2004, the county commissioned consulting firm, Environmental Stewardship and Planning, estimated trail use to be substantially less than this previous sanitation study.
There is no agreement (or consistent estimate) of Rubicon Trail users. Without accurate data, it is impossible to fashion a visionary master plan to guide trail management. Of interest, the proposed draft plan seeks to control human behavior issues with quotas and limits. Human behavior is a law enforcement and education process. As previously noted, the proposed draft plan is flawed in that it does not address defined issues with realistic solutions.
UFWDA adopts the position that adequate law enforcement on this county road, like any other county road or heavily used recreation area, would ease the problems addressed by the proposed draft master plan. Further, UFWDA endorses increased signage and educational programs. Those are logical management tools employed in any other heavily used hiking or Wilderness area, or even State, County, and USFS campgrounds.
Specifically, UFWDA opposes quotas, limits, and "blasting" the Little Sluice and provides the following recommendations and alternatives:
1. Little Sluice -- Sanitation was defined as a problem for which the recreation community provided a temporary solution. The management agencies need to define and implement a permanent solution that works in conjunction with the temporary solution. The proposed draft master plan does not adequately address this issue.
Human behavior at Little Sluice has been noted as offensive to some (party atmosphere and public drunkenness). Existing laws address these types of issues. With respect to the Rubicon Trail, law enforcement is not in place to address these issues. The proposed draft master plan does not adequately address education, law enforcement, and Volunteer Trail Patrol efforts as a solution to these problems.
2. Quotas and Limits -- UFWDA does not support quotas or limits on the Rubicon Trail until an accurate count of trail use is conducted and validated. The effort to determined trail use is critical to developing a visionary master plan. The accuracy of trail use numbers must be validated and are just as important as the "qualities" trails users expect from their recreation experience. The proposed draft master plan does not adequately address "recreational experience quality" for trail users. UFWDA recommends that a comprehensive trail survey be conducted to determine a valid daily user counts and the expectations of the trail users.
3. Perceived user conflicts are not documented -- If there are user conflicts worthy of inclusion in this report/analysis, they should be documented with surveys, user input, and law enforcement records. The proposed draft master plan alludes to "user conflict" as a premise for the proposed "solutions". Again, lack of accurate data hampers proposing a viable solution. UFWDA recommends that user surveys be conducted and law enforcement records be used in order to develop a plan of action to address "perceived user conflicts". In the mean time, increasing education, public outreach and law enforcement presence will determine, or deter, potential user conflicts. Again, the proposed draft master plan does not adequately address these issues.
UFWDA believes the recreational users of the Rubicon Trail are expecting a challenging opportunity. Many of the "problems" addressed within the proposed draft master plan are slanted towards controlling "extreme activities" along the Rubicon Trail. As previously noted, vision and strategy are key elements in a master plan. The credibility of this master plan would go along way if it provided for the range of users experiences the Rubicon Trail users expect. UFWDA supports efforts to develop a management plan that promotes the long term survival of the Rubicon Trail and preserves its historical challenge.
Sincerely,
John Stewart
Director of Environmental Affairs
United Four Wheel Drive Associations
(619) 390-8747
Distribution:
El Dorado County Board of Supervisors
Rubicon Oversight Committee, El Dorado County
El Dorado County Sheriff's Office
Forest Supervisor, El Dorado National Forest
--
Director of Environmental Affairs
PO Box 1057
Lakeside, CA 92040
www.ufwda.org
March 17, 2005
To: Distribution
Subject: Rubicon Trail Master Plan, Second Draft
The below comments are submitted on behalf of the United Four Wheel Drive Associations (UFWDA) and its member associations, clubs and individuals. UFWDA is an international association representing over 30,000 motorized recreationists and their families. While the main focus of UFWDA is to advocate access to public lands for motorized recreation, many of our members participate in multiple forms of recreation; including but not limited to hunting, fishing, camping, hiking, horseback riding, bicycle riding, and gem and mineral collection.
We recognized the positive health and social benefits that can be achieved through outdoor activities. We also recognize that motorized recreation provides the small business owners in the local communities a significant financial stimulus. Our members are directly affected by management decisions concerning public land use.
The UFWDA members subscribe to the concepts of: 1) public access to public lands for their children and grandchildren; 2) condition and safety of the environment; and 3) sharing our natural heritage. The general public desires access to public lands now and for future generations. Limiting access today deprives our children the opportunity to view the many natural wonders of public lands. The general public is deeply concerned about the condition of the environment and personal safety. They desire wildlife available for viewing and scenic vistas to enjoy. They also want to feel safe while enjoying the natural wonders. Lastly, the public desires to share the natural heritage with friends and family today as well as in the future. How can our children learn and appreciate our natural heritage when native species are allowed to deteriorate and historic routes are routinely blocked or eradicated from existence?
UFWDA has reviewed the current second draft of the Rubicon Trail Master Plan. UFWDA supports the concept of the proposed master plan. Management with vision and strategy are key elements in providing a quality recreation experience. After careful review, UFWDA opposes the proposed second draft of the Rubicon Trail Master Plan. The proposed draft plan contains several fatal flaws that render it useless as a management tool. To be a useful management tool, the proposed master plan must be based on facts that are supported with valid data. The proposed master plan must also provide realistic goals and achievable criteria to measure the success of the plan. The draft proposed master plan does not provide realistic goals and achievable criteria.
Since 2001, recreation advocates (led by the Friends of the Rubicon) have been active in management efforts along the Rubicon Trail. Their efforts have resulted in mitigation of, or recommended solutions for, every problem federal, state, and local agencies have raised regarding the recreation experience along the Rubicon Trail. Those issues span a wide range, from erosion, to habitat destruction, to sanitation, to user conflicts.
The proposed draft Rubicon Trail Master Plan does not build off the success of these efforts. Issues remaining to be addressed include increased law enforcement, increased signage, and increased user education. The proposed draft master plan does not adequately address these issues. Nor does the proposed draft master plan address funding for these issues along with trail head facilities and campsite development.
To guide implementation, a "plan" requires goals and measurement criteria. The proposed draft master plan does not provide realistic goals and measurable criteria. For instance, the draft master plan proposes quotas and limits. However, there is no accurate data to support the proposed quotas and limits. There has been no validated study to determine the "carrying capacity" of the area. There has been no validated study to determine the "qualities" visitors are seeking along the trail. Yes, anecdotal information and crude estimates are available.
In October 2001, California State Parks OHV Motor Vehicle Commission, El Dorado County, and El Dorado National Forest staff commissioned a back country sanitation engineer to count trail use and human waste build-up that estimated 35,000 people days would be a reasonable figure for total annual use on the Rubicon Trail. In 2004, the county commissioned consulting firm, Environmental Stewardship and Planning, estimated trail use to be substantially less than this previous sanitation study.
There is no agreement (or consistent estimate) of Rubicon Trail users. Without accurate data, it is impossible to fashion a visionary master plan to guide trail management. Of interest, the proposed draft plan seeks to control human behavior issues with quotas and limits. Human behavior is a law enforcement and education process. As previously noted, the proposed draft plan is flawed in that it does not address defined issues with realistic solutions.
UFWDA adopts the position that adequate law enforcement on this county road, like any other county road or heavily used recreation area, would ease the problems addressed by the proposed draft master plan. Further, UFWDA endorses increased signage and educational programs. Those are logical management tools employed in any other heavily used hiking or Wilderness area, or even State, County, and USFS campgrounds.
Specifically, UFWDA opposes quotas, limits, and "blasting" the Little Sluice and provides the following recommendations and alternatives:
1. Little Sluice -- Sanitation was defined as a problem for which the recreation community provided a temporary solution. The management agencies need to define and implement a permanent solution that works in conjunction with the temporary solution. The proposed draft master plan does not adequately address this issue.
Human behavior at Little Sluice has been noted as offensive to some (party atmosphere and public drunkenness). Existing laws address these types of issues. With respect to the Rubicon Trail, law enforcement is not in place to address these issues. The proposed draft master plan does not adequately address education, law enforcement, and Volunteer Trail Patrol efforts as a solution to these problems.
2. Quotas and Limits -- UFWDA does not support quotas or limits on the Rubicon Trail until an accurate count of trail use is conducted and validated. The effort to determined trail use is critical to developing a visionary master plan. The accuracy of trail use numbers must be validated and are just as important as the "qualities" trails users expect from their recreation experience. The proposed draft master plan does not adequately address "recreational experience quality" for trail users. UFWDA recommends that a comprehensive trail survey be conducted to determine a valid daily user counts and the expectations of the trail users.
3. Perceived user conflicts are not documented -- If there are user conflicts worthy of inclusion in this report/analysis, they should be documented with surveys, user input, and law enforcement records. The proposed draft master plan alludes to "user conflict" as a premise for the proposed "solutions". Again, lack of accurate data hampers proposing a viable solution. UFWDA recommends that user surveys be conducted and law enforcement records be used in order to develop a plan of action to address "perceived user conflicts". In the mean time, increasing education, public outreach and law enforcement presence will determine, or deter, potential user conflicts. Again, the proposed draft master plan does not adequately address these issues.
UFWDA believes the recreational users of the Rubicon Trail are expecting a challenging opportunity. Many of the "problems" addressed within the proposed draft master plan are slanted towards controlling "extreme activities" along the Rubicon Trail. As previously noted, vision and strategy are key elements in a master plan. The credibility of this master plan would go along way if it provided for the range of users experiences the Rubicon Trail users expect. UFWDA supports efforts to develop a management plan that promotes the long term survival of the Rubicon Trail and preserves its historical challenge.
Sincerely,
John Stewart
Director of Environmental Affairs
United Four Wheel Drive Associations
(619) 390-8747
Distribution:
El Dorado County Board of Supervisors
Rubicon Oversight Committee, El Dorado County
El Dorado County Sheriff's Office
Forest Supervisor, El Dorado National Forest
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