Comment on Nordic Trails around Lizard Head Pass

Comments Due June 19, 2015:  U.S. Forest Service Proposed Changes to Nordic Trails at Priest and Trout Lake and on Lizard Head PassA letter and maps have been released by Norwood District Ranger Judy Schutza. The letter requests public comment on significant changes proposed for trails at Lizard Head Pass, plus Priest and Trout Lakes.  Written comments via facsimile or email should be sent to FAX 970-327-4854 or to comments-rocky-mountain-gmug-norwood@fs.fed.us.  Oral comments via telephone can be made by calling the Norwood office at 970-327-4261.  Public comments must be received by June 19, 2015.Click here to see SMA's draft comments to the FS.Click the orange link to view San Miguel County's draft comments: 20150617-BOCC-Backup-4Consent (page 21). Comments from the Telluride Nordic Association are below.In 2012 Telluride Nordic Association requested approval to groom additional trails at Trout Lake.  The FS asked that TNA prepare a master plan depicting the long term vision for Nordic trails at Priest Lake and Trout Lake.   The first draft of the Master Plan was submitted to the FS February of last year.  Over the last year and a half, the Master Plan was revised multiple times to reflect FS staff input.  The changes now proposed by the FS for groomed trails at Trout Lake are “part of a larger (FS) vision to focus and encourage use of the Matterhorn (Priest Lake) Nordic ski trails.”Master Plan improvements envisioned for Priest Lake have for the most part been approved.  Two new trails were added last season and a third new trail is proposed in the current FS scoping letter.  A new 30 space parking area will be constructed prior to next season.    The proposed Hidden Valley trail is the only new Priest trail awaiting approval.The FS scoping letter does not reflect the plan for Trout Lake envisioned in the TNA Master Plan.  The TNA Master Plan for Trout Lake includes significant additional groomed trails (beyond those proposed in the FS scoping letter), a utility grooming access trail between Priest and Trout, expanded parking at the Trestle trailhead and does not eliminate access from Lizard Head Pass.The FS issued a scoping letter last November seeking public comment on expansion of parking at the bottom of the Trout Lake RR Grade (Trestle Parking Expansion). Unfortunately, the scoping letter made no mention of the FS plan to eliminate grooming of the RR Grade to the top of Lizard Head Pass, thereby eliminating trail access from Hwy 145.  Understandably, Trout Lake owners voiced concern about the traffic and road impacts along Trout Lake Road that might result from expansion of the Trestle Parking area.  On January 30, 2015, the FS issued a notice of decision to deny the expanded Trestle Parking area.While improvements at Priest Lake are certainly appreciated, we believe the FS underestimates the importance of the groomed trails at Trout Lake to the Nordic community and we believe the changes proposed by the FS for Trout Lake to be unworkable.  Trout Lake typically is the only groomed trail in southwest Colorado for much of November and December.  Enthusiastic early season skiers flock to the trail to enjoy the first skiing of the season.  Many Nordic trail users traveling from the south access from the trailhead at the top of the pass exclusively.  Eliminating access from Lizard Head Pass will result in unacceptable congestion at the Trestle trailhead.The FS lists three reasons behind the proposed Grooming Changes at Trout Lake, all of which are subject to challenge:

  1.   Impacts to Lynx Habitat: The FS maintains there should be no net increase in groomed trail at Trout Lake in order to mitigate impacts to the Canada Lynx: “Lizard Head Pass has been identified by the U.S. Fish and Wildlife Service (FWS) as a "lynx linkage", an area that connects known tracts of suitable lynx habitat. Groomed winter trails in this area may make it possible for competing predators, such as coyotes and bobcats, to occupy lynx habitat through the winter thus reducing the habitat's value for lynx. Consequently, in order to avoid impacts, the Forest Service will follow FWS guidelines which direct that there be no net increase in groomed winter routes within this suitable lynx habitat. This means that the new l .9K trail loop/connector in the Lizard Head Meadows cannot be added without reducing the trail mileage somewhere else in the Trout Lake trail system; specifically by discontinuing grooming the 1.9 kilometers of the upper railroad grade.”

FS lynx conservation policies were updated in the 2013 publication Canada Lynx Conservation Assessment and Strategy 3rd Edition (2013 LCAS).  The 2013 LCAS does not “direct” that there be no net increase in groomed winter trails. To the contrary the 2013 LCAS includes the following findings and guidelines:

  • “Snow in southern lynx habitats may be subjected to more freezing and thawing than in the northern portion of lynx range (Buskirk et al. 2000b), although this varies with elevation, aspect, and local weather conditions. It has been suggested that crusting or compaction of snow may reduce the competitive advantage that lynx have in soft snow because of their long legs and low foot loadings.” (2013 LCAS P-26)
  • “Studies of coyote use of compacted snowmobile trails have yielded variable results.” “Based on these studies, it appears that snow column density and the number of freeze/thaw events in different regions may influence coyote movements and habitat selection (Burghardt-Dowd 2010). That is, snow penetrability in the region may determine whether or not snowmobile trails influence coyote movement.” (2013 LCAS P-81)
  • “Existing information suggests that some low level of competition for prey could occur naturally between lynx and coyotes. However, this is apt to vary spatially or temporally depending on overall prey availability and composition. Research that could conclusively demonstrate and quantify the effects of competition would be challenging due to numerous confounding factors.” (2013 LCAS P-82)
  • “Minimize large-scale developments that would substantially increase habitat fragmentation, reduce snowshoe hare populations, or introduce new sources of mortality.” (P-93 Conservation measures to minimize habitat fragmentation).
  • “Recreation management:  There is little empirical information regarding the responses by lynx to recreational activities. Ongoing studies in Colorado are investigating the effects of snowmobiling, backcountry skiing, downhill skiing, and other winter recreation on lynx.Preliminary information suggests that some recreation use may be compatible, but lynx may avoid some areas that have concentrated recreation use.” (P-94)
  • “Consider not expanding designated over-the-snow routes or designated play areas in lynx habitat, unless the designation serves to consolidate use.” (P-94 Conservation measures for recreation management).

The proposed FS action limiting trail grooming to “no net increase” does not reconcile with the following facts:

  1. a)    The 1.9 kilometers proposed for deletion will remain as a snowmobile access and therefore will therefore experience continued use and snow compaction.
  2. b)     The proposed trail expansion at Trout Lake hardly qualifies as a “large-scale” development as clearly distinguished in the 2013 LCAS.
  3. c)    Unrestricted snowmobile use will continue on the south side of Hwy 145 in the San Juan forest beginning at the top of Lizard Head Pass.
  4. d)    The September, 2014 US Fish and Wildlife Service determination excluding the Southern Rockies as critical lynx habitat.
  5.   Snow Slide Risk: The FS cites the safety risk due to a 150-foot segment of the existing groomed trail passing through a snow slide area.  The snow slide area lies within the portion of trail proposed for deletion by the FS.

TNA has successfully managed the small slide area for the entire 20 year history of grooming at Trout Lake without a single recorded incident involving the public.  TNA groomers either ski cut the overhanging cornice or use the grooming cat to release the slope.  Skiers and snowmobilers will still use the trail even if it is not groomed.  The risk will be greater to the public if the small slide area is not managed by TNA groomers.

  1.   Conflict with Snowmobiles: The FS would like to reduce potential snowmobile – skier conflicts by separating groomed trails from the snowmobile open use area at Lizard Head Pass.

TNA supports the proposed signage intended to keep snowmobiles out of restricted areas east of the pass.  However, the overwhelming majority of reported snowmobile – skier “conflicts” in the +/- 20 year history of grooming the Trout Lake RR Grade have involved snowmobilers travelling the length of the RR Grade between the Trestle trailhead and the top of the pass. Eliminating the top 1.9 kilometers of groomed trail does not prevent future conflicts along the RR Grade.  Approval of expanded trails provides alternatives for skiers wishing to avoid snowmobile traffic.The TNA Board proposes a continued dialog with the Forest Service in the hope of reaching workable alternatives to the changes currently proposed at Trout Lake.  Specifically, TNA proposes the following:

  • Schedule a meeting with Forest Service and U.S. Fish and Wildlife Service biologists to thoroughly vet possible impacts to lynx habitat from expanded Trout Lake groomed trails in the context of the 2013 LCAS and the 2014 USFWS determination on lynx habitat for the Southern Rockies.
  • TNA will meet with a snow safety expert at TELSKI and create a slide mitigation plan and procedures.
  • Schedule a meeting with Forest Service, Trout Lake owners, CDOT, County Open Space and Rec and interested Nordic trail users to explore options for mitigation of traffic, safety and parking.

Telluride Nordic Association board of directors urge anyone concerned about the future of Nordic trails at Trout Lake to submit comments via the email, fax or phone number provided at the beginning of this letter.Sincerely,Telluride Nordic Association Board of Directors

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