December 16, 2005

Dennis Neitzke
Gunflint District Ranger
Superior National Forest
2020 W. Highway 61
Grand Marais, MN 55604

RE: South Fowl Lake Snowmobile Access Project

Dear Mr. Neitzke:

On behalf of Friends of the Boundary Waters Wilderness (“Friends”), please accept the following comments regarding the South Fowl Lake Snowmobile Access Project. The Friends supports Alternative 4 and strongly opposes Alternative 2. The southern route is a sensible option that has less impact on the wilderness, whereas Alternative 2 serves fewer people and unnecessarily harms one of the most beautiful vistas in Superior National Forest.

While the Forest Service is not obligated to provide a replacement trail for those snowmobilers who illegally created a trail in the 1960s through Superior National Forest, and after 1978 illegally rode that trail across the wilderness, we recognize that the agency will opt to create a new trail. Given that situation, the Friends supports Alternative 4 for the following reasons, described below. Meanwhile, our reasons for opposing Alternative 2 are also outlined below.

ALTERNATIVE 4

Provides Safer Access to South Fowl Lake

It is established that snowmobiles now ride on the Arrowhead Trail to reach McFarland Lake. While legal, it is an unsafe ride because snowmobiles share the road with vehicles. The EA’s Need for Action states the concern of the Forest Service and Cook County about snowmobiles and vehicles sharing a plowed road (p. 3). The EA also states that the goal of the proposed project is to provide “…a safer access route…for snowmobiles between McFarland Lake and South Fowl Lake” (p. 4). This concern is addressed by Alternative 4, which proposes creating a route parallel to the Arrowhead Trail, thereby removing snowmobiles from the roadway and eliminating the risk of accidents between snowmobiles and automobiles.

Requires Less Trail Construction

Alternative 4 would create just slightly more trail than Alternative 2; in fact, just one-tenth of a mile more (p. 21). This figure is even less when considering that almost two miles of Alternative 4 would exist on the shoulder of the Arrowhead Trail, an area already largely cleared of trees and brush. Most of the right-of-way on the Arrowhead Trail appears able to accommodate the new trail, in sharp contrast to Alternative 2 which is almost entirely through wooded and sloped terrain.

Preserves Wilderness Experience

Alternative 4 keeps the proposed trail farther away from the Boundary Waters and thus preserves the experience wilderness visitors expect: peace and quiet. It is important that people hunting, camping, snowshoeing, or cross-country skiing are not disturbed by the sound of snowmobiles passing on nearby trails.

Spreads Fewer Non-Native Invasive Species

Alternative 4 keeps intact most of the rare plants in the corridor and spreads fewer non-native invasive species (p. 34). Most of the route runs in an existing corridor – the Arrowhead Trail – and thus reduces the chance of introducing non-native invasive species. According to the EA, Alternative 4 “…would be on a corridor where weeds already occur” (p. 34). Conversely, Alternative 2 requires cutting more than two miles of new paths through the forest, and “…could have the most effects of weed introduction” (p. 34).

Serves More Snowmobile Riders

Alternative 4 provides more options to more snowmobile riders. For the estimated 30 riders living on McFarland Lake, they can safely ride five miles to South Fowl Lake via the new route along the Arrowhead Trail. For riders arriving via truck from the south who are intent on reaching South Fowl Lake, they can leave their trucks and trailers at the parking lot and enjoy a short ride up South Fowl Road. And for that same group of riders arriving from the south who want to reach McFarland Lake, they could leave their trucks and trailers at the parking lot and ride their snowmobiles safely along on the shoulder of the Arrowhead Trail.

ALTERNATIVE 2

Increases Illegal OHV Use

Alternative 2 will undoubtedly yield an increase of illegal off-highway vehicle use. The Tilbury Trail is already the site of illegal all-terrain vehicles (ATVs), as illustrated by the tire tracks observed in August 2005. This use occurs to some extent because of the compromised barricade, where logs near the metal posts have been cut, allowing enough clearance for ATVs to easily access the trail and ride through the wilderness.

As designed, Alternative 2’s steep slopes and great views will also lure new ATV riders. The route will be wide and challenging, something attractive for riders seeking different obstacles.

“Trail closed” signs are inadequate and will fail to stymie illegal riding on the trail. In the case “trail closed to ATV” signs are posted, they are typically ripped down or vandalized within days. It will be nearly impossible to replace these damaged signs and ensure that prospective riders are informed of the restrictions. Some of the illegal riders will come from outside the area and be unfamiliar with the ATV restrictions. Should they ride on the proposed trail (lacking “trail closed” signs), considerable erosion and trenches are bound to follow.

While the EA states the Forest Service has “…the option of closing the trail and restoring the area” (page 20) if motorized vehicles cannot be controlled, it will be a very difficult action for the agency to implement. No matter how many off-highway vehicle violations may occur in the area, once a trail is constructed and snowmobile use established, attempts to close the trail will be nearly impossible. Snowmobile riders will offer to help enforce the trail during warmer months and educate off-highway vehicle riders about the trail’s restrictions; however, these efforts will be fleeting at best and will never suffice in the absence of regular Forest Service enforcement.

Increases Erosion

As designed, the Alternative 2 trail would be shadowed by the bluff in winter and spring. This means that it will be one of the last areas to melt in the spring and dry in the summer. Consequently, the ice-covered trail will serve as an aqueduct for melting snow in the spring, contributing to erosion down the trail and at the foot of the bluff’s western and eastern edges (p. 36). Likewise, the delayed drying of the trail will make it vulnerable to deeper trenches and erosion (p. 36) caused by illegal ATV use.

Increases Noise in Wilderness

The bluff’s slope is steep enough that it will increase noise in the wilderness. As proposed, the trail reaches an elevation of 1,647 feet, nearly 200 feet higher than the surface of Royal Lake. The ascending slope (which surpasses 1,800 feet) will send the echo of snowmobiles into the wilderness rather than away (p. 51). In addition, the trail’s elevation will allow sound to travel farther into the wilderness than a trail at lower elevation. These factors are inconsistent with the intent of the 1964 Wilderness Act.

The EA states that the Forest Service should “choose preservation of the wilderness resource over human influence or activity” when making decisions (p. 49). It is peculiar then why Alternative 2 would even be considered as a “finalist” for the replacement trail. The experience of a wilderness visitor (no matter how few in a given period), should not be impacted by the whine of snowmobiles riding on the adjacent bluff. Wilderness areas should be free of human influences (whether sounds or sights), even when no humans are present to record that impact.

Fails to Address Safety Concerns

The EA’s Need for Action states the shared concern by the Forest Service and Cook County Board of Commissioners about snowmobiles and vehicles sharing a plowed road (p. 4). Under Alternative 2, however, this concern is not addressed. Any snowmobile rider wishing to ride north on the Arrowhead Trail to McFarland Lake would still be permitted to do so under this scenario. Such a situation would exist because Cook County has refused to close the Arrowhead Trail to snowmobile riding, despite the occurrence of snowmobile deaths on similar Cook County roads. This scenario would yield continued conflicts and risk of accident between cars and snowmobiles.

The EA states that there is a desire by snowmobilers originating at McFarland Lake to complete a loop ride (pgs. 53 and 54). It also states that “…there is some concern that dual use may continue on the Arrowhead Trail, regardless of which alternative is chosen” (p. 52). Assuming these statements are correct, Alternative 2 does not provide a legal and safe loop opportunity for such riders nor does it alleviate dual use riding on the Arrowhead Trail. Riders would only gain a trail running east-west but may be inclined to complete the loop by riding on the surface of the Arrowhead Trail, thus increasing their risk of an accident with cars on the road.

Harms Rare Plants

The Forest Service has identified 14 rare plants in the affected corridor. According to the EA, “virtually all the known sensitive species in the area occur on the cliffs between McFarland and South Fowl Lakes, on the north side of these cliffs, or in the Royal River drainage” (p. 32). Strangely, Alternative 2 would be constructed in the same area that is home to these sensitive species.

The EA states that if “…season trail closures are not effective…ATV use could create more ecological disturbance than would snowmobiles” (p. 32). This factor should receive considerable attention in the final decision, given the likelihood of illegal ATV travel on the route.

With illegal ATV riding on the trail, the spread of invasive non-native species is all but assured (p. 34). The plants and seeds that wedge themselves into the tire treads on an ATV are easily and regularly deposited on a trail. Many of the rare plants currently in the area will find themselves struggling for dominance in a terrain where the plant composition is drastically changed (p. 34).

Perpetuates Illegal Riding on Tilbury Trail

Alternative 2 intersects with that of the Tilbury Trail, thus heightening the possibility of snowmobile riders resorting to habit and opting for the shorter, illegal route through the Boundary Waters to reach South Fowl Lake. In the absence of sufficient enforcement and an obliterated Tilbury Trail, there is nothing to stop renegade snowmobile riders from continuing this illegal pattern.

Serves Fewer Snowmobile Riders

According to residents of McFarland Lake, an estimated 30 people would ride their snowmobiles from McFarland Lake to South Fowl Lake. This is a very small group to justify the costs of a trail that causes so many problems for the wilderness. Unlike Alternative 4, which serves people both north and south of the parking lot (intersecting at Arrowhead Trail and South Fowl Lake), Alternative 2 serves fewer people and requires those arriving from the south to drive their cars farther on Arrowhead Trail. Presumably, some of the snowmobile riders intending to reach South Fowl Lake would rather not have to begin their journey at McFarland Lake.

Conclusion

The Friends supports Alternative 4 and requests that a full Environmental Impact Statement (EIS) be conducted in advance of any construction. In addition, we ask that increased enforcement be implemented along both the Tilbury Trail and the new route, regardless of which alternative is selected. Please consider these comments during your final decision.

Sincerely,

/s/
Sean Wherley
Communications Director