Piedmont Appalachian Trail Hikers
June 2003

Comments on Proposed Plan for Jefferson National Forest

Included here is some of the discussion on the Proposed Revised Land and Resource Management Plan for the Jefferson National Forest, currently under review. Documents included are:

Marianne Skeen's introduction to the ATC's response to the plan
A comment from Don Owen on commercial use permits
The ATC's response to the plan, including references to specific locations in PATH's maintenance area-- from Teresa Martinez

June 13, 2003

To: ATC Executive Committee, Senior Staff, ATPO, Southern Region Board Members, RDT Chair, TLC Chair

Attached for your review and comment are drafts of letters that we propose as the official ATC responses to the Land and Resource Management Plans for three national forests in the Southern Region that contain sections of the A.T. There are still a few kinks to work out, but we wanted to go ahead and send these drafts now to allow time for you to provide input.

FINAL COMMENTS ON ALL THREE FORESTS ARE DUE JULY 3, 2003

Morgan and Teresa are communicating with the affected southern clubs to ensure that our positions are mutually acceptable and to encourage official club responses to the plan. Don Owen is drafting responses from ATPO.

The response letters generally focus on three areas of concern:

The “prescription” for management of the A.T.
Thanks to a lot of preliminary hard work, most of our concerns have been satisfied and there is good consistency among the three plans. Please note, however, our proposed change in wording for the recreational special use section. This change has evolved from a number of conversations over the past several months among board, staff and forest service representatives. I can provide much greater detail if you’d like, but basically the language as proposed is designed to address several issues. We have acknowledged that there is increasing demand for commercial recreation use on the A.T., that there is considerable illegal commercial use now, that there are a number of day use groups (Elderhostel, for example) that want to use the A.T., and that the total prohibition of commercial use may not be defensible if challenged politically. There is an excellent review of this topic on ATC’s web site in the Board Background for Issue Papers: http://mail.atconf.org/bom/current/BOM_Fall_01/Background.pdf (Username: boardmember, Password: Startzell)
Recently we’ve found that permits have already been granted on several districts in more than one forest. Some forest managers are understandably unaware of the complexity of the issue. The language that appears in the draft versions of the forest plans does not really help either to highlight the issue or to dispel the confusion. In fact, the vague language reflects the ambiguity that surrounds this topic. If it were not for this issue, we would probably not have distributed these draft letters so widely.
In recent discussions, we again recognized (as did the Commercial Use Task Force) that the real concern with commercial use was the impact from overnight use. That resulted in the proposed change in wording that would restrict commercial use to day use only (see attached letters). There is still a statement indicating that permits should be granted “only when they do not adversely affect A.T. values and resources”. We then explicitly request that management partners be included in the evaluation of potential impacts. The proposed allowance of day use only would hopefully minimize impacts while allowing groups to use the Trail for a few hours or use it merely to connect to other trails for their overnight use. Group sizes, numbers of groups, and other requirements would be addressed in the permitting process.
Since the Board approved the concept of a pilot project to address issues such as impact analysis and administration of permits for commercial users, the group involved in these recent discussions did not feel that the language proposed for the forest plans was a major departure from our existing position. We wanted to ensure that all of you were aware of this, though, and make certain that that it was acceptable. Don Owen has expressed concerns in the past several days that the proposed language does in fact represent a significant change in ATC’s position on this issue. Since we had already come this far in the process, I proposed that we distribute the existing drafts. Don will reply to the recipients of this message with his concerns.
Proposed Wilderness areas and other special management designations.
We have made specific comments on areas relevant to the A.T. with respect to their special management designations. ATC and local clubs are in agreement on these positions. Details can be found in the individual letters.
Potential for OHV use on the forests.
This is an area of increasing concern for A.T. management and for recreation management in general. Our comments are based on the reality that national forests have been essentially mandated to provide some amount of opportunity for OHV use. This has been declared a valid recreational use of public land. We have requested some additional safeguards against abuse.

Please send any comments by June 25 so that the letters can be finalized and submitted by the July 3 deadline. If you have substantive issues, please respond to the entire group.

Thanks for your help.

Marianne

Marianne -

I agree with just about all of your memo. The only thing that makes me uncomfortable is the following statement:

"Since the Board approved the concept of a pilot project to address issues such as impact analysis and administration of permits for commercial users, the group involved in these recent discussions did not feel that the language proposed for the forest plans was a major departure from our existing position."

I respectfully disagree. I do think this is a major departure from our earlier position of a pilot study, in that we are no longer doing a study to decide whether or not commercial use should be allowed. Instead, ATC is clearly endorsing a position of allowing commercial use, even if it's only commercial day use, of the Appalachian Trail. My biggest fear is that by opening the door halfway (i.e., endorsing commercial day use on the Trail) that someone (probably a commercial guide) will try to force the door all the way open, and that if we haven't done a good job of documenting the rationale for our new position, we - and the Forest Service, if they adopt our position - will be extremely vulnerable.

I'm willing to defer to what others think, but I personally believe ATC should come up with a clear policy statement and have it approved by the Board before we take this leap into an endorsement of commercial use on the Appalachian Trail in the southern national forests. To be clear: I'd rather leave the suggested additional language out of the letters, thrash out a position/policy statement, and then proceed. The language that is currently provided in the three draft Forest plans (without the suggested additional language) is general enough to allow us to take the step of endorsing commercial use at some point in the future, once we've completed the policy process.

Don

Don Owen
Environmental Protection Specialist
Appalachian National Scenic Trail
(deliveries: Third Floor, Civil War Story Building)
Harpers Ferry Center
Harpers Ferry, W.Va. 25425
phone: (304) 535-4003
fax: (304) 535-6270

June 12, 2003

Jefferson National Forest
Content Analysis Team
P.O. Box 221150
Salt Lake City, UT 84122

This letter represents the Appalachian Trail Conference (ATC) official response to the Draft Environmental Impact Statement and Proposed Revised Land and Resource Management Plan for the Jefferson National Forest (DEISJNF).

The Appalachian National Scenic Trail (A.T.) is managed to provide a remote backcountry hiking experience consistent with the National Trails System Act (16 U.S.C. §1242). The Appalachian Trail Conference (ATC) is a private nonprofit organization composed of more than 33,000 members dedicated to protecting and promoting the 2,173-mile Appalachian National Scenic Trail. ATC also is a federation of 31 local A.T.-maintaining clubs whose members volunteer nearly 200,000 hours of their time and energy each year to protect this outstanding recreational resource for public enjoyment. The clubs that work on the Jefferson National Forest include the Natural Bridge Appalachian Trail Club, Roanoke Appalachian Trail Club, Outdoor Club of Virginia Tech, Piedmont Appalachian Trail Hikers, and the Mount Rogers Appalachian Trail Club. The A.T. is managed through a unique cooperative management system involving the National Park Service, USDA Forest Service, state agencies, local governments, ATC, and the local trail-maintaining clubs. The DEISJNF will dictate management along approximately 330 miles of the A.T.

Preferred Alternative

The ATC would first like to state its general support of the preferred AlternativeI, the “rolling alternative.” This plan reflects the public input provided over a period of 12 years, with much of this work having been done in the past four years. We would like to address Management Prescription Area 4.A, the Appalachian Trail Management Corridor, and specific areas that are adjacent to and surrounding or encompassing the A.T. Management Corridor.

Management Prescription 4.A: The Appalachian National Scenic Trail Corridor

ATC supports the general management direction provided under this prescription area. However, ATC would like to see the following changes/additions (in italics)

Standard 4.A-024:

Authorize recreational special-uses only when they do not adversely affect A.T. values and resources. Consult with the local Trail maintaining club(s) and the ATC when evaluating impacts. Restrict recreation special-uses of the A.T. to day use only. Prohibit overnight camping by permitted users within the A.T. prescription area. Limit contest events such as foot races or horseback endurance events to designated crossings only. Do not allow vendor or peddler permits.

These proposed changes in wording would allow forest managers to issue permits in appropriate areas to commercial groups who would use the ANST only for day hikes or for connecting to other trails. By prohibiting overnight use of the ANST by commercial entities, the greatest impacts to the resource could potentially be avoided. This proposed language was developed by consensus among ANST management partners.

An “Implementation Guide for the Appalachian Trail” is referenced in the introductory section of the 4.A prescription. This document was generated when Guidelines were separated from Standards in the forest plans. There are important guidelines for A.T. management in this document that should remain as part of the management direction for the Trail. We request that this document be finalized and incorporated either as an appendix to the Plan or as part of an overall Implementation Guide that accompanies the Plan. In either case, the Implementation Guide for the Appalachian Trail should be accorded a significant role for detailed guidance for A.T. management.

Although motorized use is prohibited on the A.T in standard 4.A-012, we recommend adding a standard in the Recreation section stating explicitly “This area is closed to OHV use.” This Standard would establish consistency with those in other prescriptions where OHV usage is explicitly prohibited. Furthermore, this clarifies that OHV usage is prohibited within the entire prescription area, not simply on the Trail treadway.

ATC is pleased that no 7.C (OHV Use Areas) allocations adjoin the A.T. prescription area. There are already significant negative impacts from illegal OHV use on the A.T. on the Jefferson in the area East of I-81 between Route 11 and Virginia 16. Increased access to the A.T. will only “invite” increased OHV abuse of the A.T. While we believe that limited OHV areas may be provided on National Forest lands, provided such areas can be utilized without significant resource impacts or impacts to other forest users and neighbors, we oppose designation of new OHV trails that may intersect or be in close proximity to the A.T. This is because of the resource damage OHV’s create, the significant auditory impacts from OHV’s, and the illegal insertion of motorized use into areas designated as non-motorized and the negative impact on the desired (and prescribed) primitive experience of the A.T.

Under standard 4A-019 we are pleased to see that all management activities occurring in the prescription area will meet a scenic integrity objective of high to very high.

Under standard 4A-021, new roads with in the prescription area are allowed only if entering the prescription area is the only feasible and prudent location. This standard needs to ensure that this is coordinated and implemented with local A.T. clubs and the ATC representatives.

We are pleased with the cross-referencing of the A.T. in the following prescriptions: 1.A, 1.B, 4.D, 4.K.1, 4.K.3, 4.K.4, 4.K.5, 6.A, 6.B, 6.C, 8.E.2, 9.A.4, 9.F, 12.B, and 12.C. We feel strongly that any standard or special and or congressional designation containing the A.T. foreground maintain consistency with the A.T. management prescription.

We would like to see a standard included in the management prescription addressing “no net loss”. The "No-Net-Loss" standard is the current policy of the Appalachian Trail Conference, having been amended and readopted in 2001 following numerous successful resolutions of land-use decisions involving public utilities, communication-tower interests, and other issues. It grew out of our decade-long work with the Roanoke Appalachian Trail Club, the NPS A.T. Park Office and the Forest Service on the George Washington/Jefferson National Forest, to reach an accommodation with the American Electric Power Company's proposal for siting of the 765 kV electrical transmission line across the Jefferson National Forest. We believe the "No-Net-Loss" goal was critical to our successful resolution of this very protracted issue. It is definitely possible to meet. As a goal, it is sound policy and principle, and a goal worth keeping in the A.T. Management Prescription.

Regarding land acquisitions for the A.T., we are pleased to see from the Forest-wide standard, FW –243, that they will remain a high priority. We are also pleased with FW- 180 regarding lands viewed in the middle ground from concern level 1 travel ways, which includes the A.T., that they will retain a scenic class of 2 or higher and will be managed for an SIO of moderate or higher.

Specific Areas of Concern:

North Mountain – we are glad to see a major portion of the management prescription of this area, in particular the area seen for the A.T. along Catawba Mountain and McAfee Knob, allocated to a 12.B prescription.

Brush Mountain/Brush Mountain East – In the current rolling alternative, all of Brush Mountain and three quarters of Brush Mountain East are 12.B. This management prescription provides adequate protection for the A.T. However, we would like to see the area of Brush Mountain be changed to at least a 12.C designation, and the area of Brush Mountain East be mapped as a 1.B area with slight modifications to the boundary. We would like to see a 1.B area mapped that includes the A.T., but excludes the road along the crest of the ridge and the Audie Murphy monument. This change in the prescription area allows more permanent and higher protection of this special and remote area. This would also allow continued access to the site by the Veterans of Foreign Wars and for maintenance of the wildlife areas along the ridge.

Mountain Lake Wilderness Additions – We support the additions to the Mountain Lake Wilderness Area as it affords even more protection to the A.T. in this unique and special area.

Peters Mountain Wilderness Additions – We support the additions to this existing wilderness area.

Mill Creek – In this area, the A.T. management prescription is surrounded by a 12.A designation (Remote Backcountry with Few Open Roads). While this offers protection, because no open public roads currently exist there now, we feel this should be upgraded to 12.B or 12.C.

Dismal Creek - This area has received no special consideration beyond the A.T. corridor. The area above the Trail corridor is in 6.C (Old Growth Areas Managed with a Mix of Natural Processes and Restoration Activities) and 8.A.1 ( Mix of Successional Habitats). We are concerned about the management activities that might be recommended under these prescriptions and would like to see protection of the old growth and the recreation opportunities in this area highlighted. We would also like to see continued protection of the visual and aesthetic resources potentially impacted by any management activities in this area.

Crawfish Valley/Bear Creek – This area is a unique are of the Jefferson National Forest. As an inventoried roadless area, it provides ample opportunities for a wide array of recreational uses. However, we do not feel the current land allocation provides adequate protection for the A.T. in this area. We would like to see this entire area protected under a 12.C management prescription, with the exception of the open field habitats along the access road FS 727. We would like to see the portion of this area in Smyth County be changed to a 1.B designation to protect the remote nature of that portion of the area. We would like to recommend that FS Road 6261 along Bear Creek be decommissioned beyond that point where public road access is prohibited. Finally, we would like to see a land allocation for the entire area that provides permanent protection for the land while also providing the Forest Service with the ability manage the lands in this area, and maintain access for all the recreational users of the area.

Brushy Mountain – We support the allocation of this area to a 12.B management prescription for protection of the A.T. corridor and the lands surrounding the A.T. However, because of its proximity to Kimberling Creek Wilderness area, we would ultimately like to see this area permanently protected. In the meantime, we recommend allocating this as a Wilderness Study, 1.B designation in the DEISJNF.

Hunting Camp/Little Wolf Creek - This is one of only two new wilderness study areas recommended by the USFS in the initial rolling alternative. We strongly support this designation. This area, in conjunction with the Garden Mountain area will permanently protect 10 miles of the A.T. in a remote setting.

Garden Mountain – This area is separated only by dirt VA 623 from Hunting Camp, and is the other recommended new wilderness study area supported by ATC. Combined with the Hunting Camp Creek and Little Wolf Creek areas, it creates a huge block of permanently protected land that is a truly unique and special addition to the National Forest.

Beartown Wilderness additions A and B – We support the prescription 12.C, but not 8.C in these two areas. We would like to see both of these as Wilderness Study areas, and recommend allocation, at minimum, as a 12.B for Beartown Wilderness B addition.

Chestnut Ridge - The area surrounding the A.T. is currently mapped as 8.C (Wide Ranging Area Sensitive Species - Bear). This allows the continued use of problematic roads that we don’t see as appropriate in this area. We would like to see this area be allocated as Wilderness Study, a 12.C or 12.B.

Raccoon Branch – This inventoried roadless area is currently under a 12.C management prescription and offers adequate protection for the A.T. We would however, support a wilderness study designation for this area.

Seng Mountain – This inventoried road less area is under 8.C and 12.C management prescriptions. Due to the remoteness and uniqueness of the wide array of non-motorized recreational opportunities available in this area we would like to see this area’s prescription changed to continue to these uses, but prevent further temporary or permanent road construction. We strongly advocate that the entire area be changed to a 12.C core area, with the 8.C area changed to a 12.B or 12.C prescription. This would protect the Appalachian Trail values in this area, but still allow all the current recreational uses in the area to continue, and the USFS to manage with the flexibility needed to adapt to the changing needs of the land.

Lewis Fork/Little Wilson Wilderness additions – We strongly support this land allocation.

James River Face Wilderness Addition - We strongly support this land allocation.

North Creek Special Area – The land in this area that is not allocated to the A.T. corridor has been placed under a 4.K.1 management prescription. We support this designation, but are concerned with the standards regarding the mix of suitable and unsuitable lands in this area. We would like to see further detailed mapping of the area’s suitability for timber harvest, and the proximity of those areas to the A.T. foreground. There is to be no timber harvesting occurring with in the A.T. foreground. Because the standards for this special area do include and acknowledge the A.T. standards, we want to ensure that the mapped foreground and middle ground of the A.T. meet Forest wide standard FW- 180 regarding these important scenic resources.

Crest Zone – As in other special areas, the land in this area that is not allocated to the A.T. corridor is allocated to the 4.K.3 prescription. This prescription and specifically standard 4K3-OBJ4 is acceptable to ATC. During the past four years, we have been engaged in the development of the Limits of Acceptable (LAC) Guidelines. We support the outcomes of this effective public process.

Whitetop Mountain Special Area – The land in this area not allocated to the A.T. corridor has been placed under the 4.K.4 management prescription. We support this designation.

Whitetop Laurel Creek Special Area – The land in this area not allocated to the A.T. corridor has been placed under the 4.K.5 management prescription. We support this designation. However, we are concerned with standard 4K5-037 regarding special use permits. We encourage that along the A.T. that special use permits only be allowed for day use only, and that they remain compatible with the goals and objectives of the A.T. standards and guides.

As always, ATC appreciates this opportunity to provide comment on the Draft Environmental Impact Statement and Proposed Revised Land and Resource Management Plan for the Jefferson National Forest. We also appreciate the positive working relationship the staff of the Jefferson National Forest has maintained throughout this exhausting planning process. We believe this process will result in protection for the A.T., and lands of the Jefferson National Forest.

Sincerely,

Teresa Ana Martinez,
Regional Representative
Southwest and Central Virginia
Regional Office
Appalachian Trail Conference

Cc: Joe Chavez, Bob Peckman, Parthena Martin, Zack Brock, Kitty Farley, Pam Underhill, Marianne Skeen, Morgan Sommerville, Dave Startzell