Idaho Chapter - Lewis and Clark Trail Heritage Foundation

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Idaho Chapter –
                   Lewis and Clark Trail Heritage Foundation

On the following pages you will find the draft comments prepared for the Forest Service’s
Proposed Action. If you have suggestions, concerns or ideas please contact Idaho Chapter
President Chuck Raddon at idahoclarkie@gmail.com.
Idaho Chapter –
                    Lewis and Clark Trail Heritage Foundation

Draft –September 10, 2014.

Mr. Rick Brazel, Forest Supervisor, NezPerce – Clearwater National Forest

This letter is in response to a request for comments to: Proposed Action for Forest Plan
Revision Nez Perce-Clearwater National Forest dated July 2014.

The Idaho Chapter of the Lewis and Clark Trail Heritage Foundation is a group of individuals
interested in the history of the development of this country in it broadest sense. Our focus is
the Lewis and Clark Trail as it crosses Idaho and the subsequent history of the area that
followed the expedition.

In Idaho, a key event to the Lewis and Clark Expedition was the crossing of the Bitterroot
Mountains via what today is called the Lolo Trail. The Lolo Trail National Historic Landmark is a
broad swath of land that not only contains two National Historic Trails, but a variety of historic,
cultural and Native American religious sites. We believe the Lolo Trail National Historic
Landmark provides an incredible range of educational, recreational and cultural opportunities
not available elsewhere in United States. We see little management attention given to the
resource, to the significant educational and historic opportunities and to the national direction
given by Congress for managing this valuable resource.

I’ve attached five pages of comments for your consideration.

This statement was reviewed, edited and approved by our Board of Directors.

CHARLES H. RADDON
Chapter President
Idaho Chapter –
                    Lewis and Clark Trail Heritage Foundation

The National Historic Trails Act as amended by the National Trails Act, [16USC1241] states:

       (a) In order to provide for the ever-increasing outdoor recreation needs of an expanding
       population and in order to promote the preservation of, public access to, travel within,
       and enjoyment and appreciation of the open-air, outdoor areas and historic resources of
       the Nation, trails should be established (i) primarily, near the urban areas of the Nation,
       and (ii) secondarily, within scenic areas and along historic travel routes of the Nation
       which are often more remotely located. (Emphasis added)

       Section 3a states:

       (3) National historic trails, established as provided in section 5 of this Act, which will be
       extended trails which follow as closely as possible and practicable the original trails or
       routes of travel of national historic significance. Designation of such trails or routes
       shall be continuous, but the established or developed trail, and the acquisition thereof,
       need not be continuous onsite. National historic trails shall have as their purpose the
       identification and protection of the historic route and its historic remnants and artifacts
       for public use and enjoyment. ….

       Section 3 b. states

       (b) For purposes of this section, the term 'extended trails' means trails or trail segments
       which total at least one hundred miles in length…

With this information as background we have two kinds of comments about the proposed action.
They are (A) an “Overview Comment” about the opportunity of the Lolo Trail National Historic
Landmark and the approach the Proposed Action appears to be taking, and (B) Specific
comments on portions of the Proposed Action.

    A. Comments and concerns regarding the goals and overview
                    of the Proposed Action.

1. The Lolo Trail National Historic Trail Landmark nomination needs to be redone. The
   nomination was last amended by Merle W. Wells, Historian, Idaho State Historical Society in
   1989 and approved by the National Park Service in 1991. The nomination is defective in
   several respects.
Idaho Chapter –
                   Lewis and Clark Trail Heritage Foundation

       a. The Lolo Trail Corridor is the historic travel route across the Rocky Mountains. Its
          termini should properly be considered Missoula, Montana to Lewiston, Idaho. The
          portion under National Forest Management runs from Lolo Hot Springs in Montana
          to Musselshell Meadow, Idaho. The route is a braided route with sections of trail and
          road in a corridor which in some places is 20 miles wide. The nomination excludes
          both terminals and many sections of the corridor. When plotted on a map some
          critical areas are not included.
       b. The nomination was written primarily about the Lewis and Clark Expedition with
          little mention of the NezPerce National Historic Trail or of the many years of use by
          the Nez Perce Tribe. Also not included are the many other travel related events and
          crossings in recorded history, as well as the many features described in FW-DC-CR-
          01 and -02 which are an important and integral part of a visitor’s experience when
          visiting the Lolo Trail National Historical Landmark.
       c. A considerable amount of trail and historic site inventory was done in preparation for
          the Lewis and Clark Bicentennial. The current nomination documentation does not
          have the benefit of the considerable body of knowledge about the trails and the Native
          American uses of the area that was gained from the Bicentennial work.

Consequently, we recommend that the Lolo Trail National Historic Corridor nomination be
redone utilizing current views, values and data.

2. The Forest appears to be contravening the will of Congress in its lack of attention to the
   need for a cross forest trail utilizing the Nez Perce National Historic Trail within the
   Lolo Trail National Historic Landmark. From Lolo Hot Springs, Montana to Musselshell
   Meadow, Idaho there is an existing trail that meets the goals of a long distance trail
   envisioned in 16USC1241. The trail exists; it just has not been displayed to the public or
   maintained properly for many years. The trail meets the need and the standard expressed in
   16 USC 1241. Within one day’s drive are eight (8) Metropolitan Statistical areas (Boise, ID;
   Salt Lake City, UT; Missoula, MT; Spokane, WA; Seattle, WA, Tacoma/ Lakewood, WA;
   Billings, MT; and Portland/ Vancouver, WA.) Together they hold ten million Americans,
   many who hunger for the kind of educational experience they could find in the Lolo Trail
   National Historic Landmark. There is no other long distance trail in the nation that provides
   an equal opportunity for historical education with an adjacent road that allows support for
   youth groups and for stock users. It is a significant failure of the Nez Perce-Clearwater
   National Forests to display and provide this resource to the American public.
Idaho Chapter –
                    Lewis and Clark Trail Heritage Foundation

3. A major goal of the 1986 Lolo Trail Guidelines that was adopted into the 1987 Forest
   Plan was a cross forest trail utilizing the Bird-Truax/ NeeMePoo/ FS Pack Trail.
   Somewhere through the years that goal has been lost.

The Lolo Trail on the Clearwater runs from Lolo Pass on the east to Musselshell Meadow on the
west largely following the ridgeline north of the Lochsa River. That is more than 100 miles of
trail, most of which is associated with the Lolo Motorway, aka Road 500. In 1866 a trail was
built across the mountains, it was followed by the US Army chasing the Nez Perce in the 1877
war, was reopened by the Forest Service as a mainline pack trail in 1907 and served for many
years in that condition. The trail was cut and obliterated in some places by the 1930s
construction of the Lolo Motorway which parallels the trail. However, as much as 90% of the
old trail tread still exists. In the mid 1980s Forest Archeologist Karl Roenky (sp?) and
Recreation Specialist Duane Annis mapped most of the trail as part of the work for the 1986
Guidelines. Since then, some western portions of the trail have been opened to public use, but
little of the eastern portion of the trail is useable to any but a determined hiker willing to fight
brush and down logs. The fires since 2000 on the eastern portion have revealed that much of the
trail tread is still quite evident.
Consequently, a Cross Forest long distance trail within a National Historic Corridor does exists
that meets the standards and goals of the National Trail Act (16USC1241), but the Forest has not
worked to meet the goals of the National Trail Act. Further, we find little in the Proposed Action
that would indicate that the forest intends to follow the directions in the Congressional Act.

4. The National Trails Act directs the agencies to utilize volunteers whenever possible. The
Selway-Bitterroot Assn is already doing a good deal of wilderness and trail management. If the
forest is to utilize volunteers to accomplish the goals in the Forest Plan it may require different
strategies. We find the whole document silent on this matter.

5. Lack of maintenance of the “high clearance” portion of the Lolo Motorway will eventually
result in it being closed to passenger “high clearance” vehicles such as SUVs and Pick-ups.
When that happens it will deny this important historical and educational resource to a significant
segment of the American public. We sincerely hope that this is not a conscious management
strategy to discourage visitor use which would in turn justify why the Forest does not need to
make the area a management priority. Unfortunately, as the road deteriorates, fewer people will
use the area which in turn will reduce the public’s knowledge, interest and concern about the
area. It will also serve to violate the legislative purpose of the two National Historic Trails in the
Corridor, whose designations were for the use and enjoyment of the public and serve as a means
to educate the public about our history.
Idaho Chapter –
                    Lewis and Clark Trail Heritage Foundation

                        SECTION B.
           COMMENTS REGARDING SPECIFIC “DESIRED
              CONDITIONS” Objectives and Guidelines.

1. FW-DC-CR-02. (Pg. 43): Statement is ambiguous. Facilities, sites & etc “exist.” Is there a
   desired condition in which they exist or will exist? If a building is falling down from lack of
   maintenance it still exists. Is that all we want? If a trail exists on the ground but is so
   overgrown with vegetation it can’t be found by those seeking its history does it still exist?
   How will the Forest Service decide which sites can be allowed to slowly disappear and which
   sites will be maintained? Will it be a process open to public review?

2. FW-DC-REC-21. (Pg. 47): “Sites will not increase in size over time.” That implies that the
   population of the United States will not increase and that conditions of public use or changes
   in travel type will not occur. That is not facing reality. For example with the new off road
   vehicle types becoming popular some locations will become popular as a staging area for
   camping and trips in the new “toys.” Will the forest automatically prohibit that kind of
   change without considering the changing public need? As the Spokane and Missoula metro
   areas grow there will be more use of the forest, probably following modern trends of shorter
   weekend trips. The Clearwater, being just a few hours from those areas might be heavily
   impacted. Is the Forest Service’s answer to public need going to be: “public go away?” We
   suggest a rule that when sites are found to be growing an assessment of the reasons and
   alternatives be considered through normal decision making process.

3. FW-DC-REC-22 (Pg 47): Special Uses. No mention is made of using Special Uses/
   Outfitter Guides to meet public needs where National Forest Funding is decreasing. This
   seems like an opportunity to substitute private funding of recreation opportunities instead of
   public funding. What kinds of strategies are being considered to accomplish this?

4. FW-DC-ED-01 (Pg. 48). Having visitor information available on the internet is a great
   concept, but one that the forest is not currently following. For example, the Clearwater web
   site previously had a nice section about the Lolo Trail Historic Corridor, and most
   specifically about the road and what kind of vehicle is needed to travel the road. After the
   Lewis and Clark Bicentennial that section was removed. Today when traveling the Lolo
   motorway we regularly encounter visitors with little information on the motorway and who
   are driving a vehicle not suited for the road conditions. Somewhere they obtained a forest
   map that shows the 500 Road and they think it is a normal high standard logging road. One
Idaho Chapter –
                    Lewis and Clark Trail Heritage Foundation

   reason they are poorly informed was that they stopped at a visitor center when it was closed
   or after hours. Many people are turning to the internet for assistance. Much more should be
   done to build (or rebuild) the internet content about the Lolo Trail Corridor so that it is a
   better educational and travel planning tool. The current site is woefully inadequate.

5. FW-OBJ-ED-01. (pg 48). Objective calls for a minimum of one entrance portal per district.
   Unfortunately, National Forest work structure is not aligned with visitor use and visitor travel
   entrances. This objective needs to be rewritten to consider forest use patterns and visitor
   traffic patterns.

6. FW-DC-INF-01 and 02. (pg 49): The Lolo Motorway east of Pete Forks junction has not
   been maintained since the L&C Bicentennial. It’s deterioration in recent years is significant.
   Has this road been placed on the “Not Needed” category? Is there public review of the roads
   in the category? At what point will such a road be deemed “unsafe” for highway type of high
   clearance vehicles, closed to public use; and who makes that decision? Is it open to public
   review? It seems strange in this period of many SUVs & Pickups meeting the “high
   clearance” standard that the forest is following a policy that will reduce the road to OHV
   standard and thus deny access to many Americans.

7. Appendix D (pg 115). We question the miles in Table 30 and 32 for the Nee Me Poo Trail
   and the Lolo Motorway. Perhaps the tables are displaying short sections in their
   administrative nomenclature. However, the Nee Me Poo National Historic Trail from
   Musselshell Meadows to Lolo Pass is is more than 100 miles, not 24. The trail exists, was
   well mapped by former forest Karl Roenky (sp?) and Recreation Specialist Duane Annis
   when they prepared the 1886 Lolo Trail Guidelines. Displaying only the currently managed
   trails hides the true opportunities available to the public and is miss-leading.
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