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Old August 26th, 2007, 07:59 AM   #1
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Default M-37 Project EA Comments made on behalf of 4WD enthusiasts

Leslie E. Russell, District Ranger
P.O. Box Drawer D
Baldwin, MI 49304

July 21, 2007

Re. Comments on the M-37 Project, Environmental Assessment

On behalf of the Two Trackers Four Wheel Drive Club and the Great Lakes Four Wheel Drive Assn., I would like to advise you that we support alternative 3 with the following modifications.

Ref. pgs. 3-46, 3-47 and map #1 (1 of 5); Subject: FR9693 and the Karner Blue Butterfly

Request 1
Forest Road 9693 passes north to south through the western one/forth of the opening. We request that the boundary of this opening be moved eastward from the road to an appropriate distance and that debris be placed to form a physical boundary for the western border of this opening. This distance (as determined by the NFS) and the debris will act as a barrier to segregate FR9693 from the proposed Karner Blue Butterfly opening.

Reason
Forest Road 9693 intersects with 7 Mile Road directly across from Taylor Road. Taylor Road and Forest Road 9693 are both considered ‘rustic’ by the 4x4 community. Because of this continuity, FR9693 provides an important rustic connector for north/south travel through the Project Area. We feel this is an acceptable course of action when one considers that less than 10 Karner Blue butterflies have been observed in the six openings within the project area within the past five years (page 3-46). With this very low count per observation period, and because this is an important trail that passes through one opening, we suggest FR9693 remain open.

Ref. pgs. 3-39, 3-42, 3-94, 3-108; subject: Fire reduction efforts

Comment 1
We suggest that the closure of roads would not sufficiently assist in fire suppression/reduction efforts to warrant the closures and would hinder such efforts.

Reason
As stated on page 3-42, “This restricted access could also hinder emergency responders in their response time and may delay suppression efforts.” The “process of succession” (pg. 3-94), i.e. re-growth over roads, would hinder fire response efforts, in contradiction to statements that roads “can be used as fire breaks” (pg. 3-39) and on page 3-108, “This system also aids in wild land fire suppression efforts by allowing open access throughout the Project Area.”.

Ref. pgs. 3-108, 3-110, 3-112 and Road density standards

Comment 2
We suggest that efforts be made to increase the number of “open” road miles in the project area over either Alternatives 2 or 3.

Reason
It has been demonstrated (see – Informal Resolution, 21 Feb 2007, Appellant #06-13-0112, Participant Code 833331, Appeal and Statement of Reasons dated August 23, 2006, pg. 3) that the road densities within the subject area are significantly less than practicable. NFS Plan Road Density Standards are unattainable and were set arbitrarily and capriciously.

Other Issues in regard to Roads:

· NNIS concerns are moot. Per M-37 EA page 3-108, NNIS can be more easily controlled by mechanical and herbicidal methods with open access throughout the Project Area.
· In another statement, signage on a bucolic road system would be unsightly and undesirable by the users of the rustic roads within the Forest.
· It is the act of traveling through forests, not to forests that attracts motorized recreationists. The use of maintained roadways depreciates the user-desired experience when these roadways must be used to connect one forest area to another. Paragraph three, page 3-112, recognizes the increasing number of forest road users. A further reduction in road density would overburden the few remaining open roads and increase un-authorized user-developed roads. Furthermore, there are many Americans with disabilities whose physical handicaps due to age, physical trauma, or disease who are quite capable of and have great desire to operate a four-wheel drive vehicle into remote forest areas to enjoy all aspects of forest recreation that would otherwise be impossible for them to access with a two-wheel drive vehicle or on foot. It is common knowledge within the full size (over 50 “ wide), four-wheel drive recreationist community that many users find it necessary to travel out of state to achieve their desired forest experience.

Ref. figure 1, page 3-121, or Map 2 of 5

Request 2
A connector between the narrows of FR 9689 and FR 9722
needs to be made accessible to all types of traffic.

Reason
· Without this connector, a detour of four miles or six miles must be made on maintained roadways. This connector would provide an important, uninterrupted route on Baldwin Road from 6 Mile Road to 8 Mile Road.
· This would also provide an important firebreak (resistant to regrowth) for an otherwise very (overly) large block of forest. This route would bisect the area encompassed by 6 Mile Road, Crosswell Road, 6 Mile Road and Map 2 of 5’s eastern border.

Ref. Map 3 of 5

Request 3
The trail between 4 Mile Road and FR 5187 is shown as discontinuous. It is, in fact, entirely open and we request that the map be changed to show this. The portion of FR 9580 that crosses the private land in the NW quarter of the intersection of Baldwin Road and 4 Mile Road is gated shut and should be removed from the map and discounted from road inventory.

Reason
This road is also important to the user community for maintaining trail continuity through the Project Area.

Request 4
The extension of Baldwin Road north, from the intersection with FR 5771, forms a continuous inverted horseshoe or “U-shape” loop that connects with FR 9580. We would like to see this portion of the trail open for travel.

Reason
This is an integral loop through a particularly interesting area, closely approaching Minnie Pond, which would greatly enhance the user’s experience.

Ref. Map 4 of 5

Request 5
Temporarily close FR 9577 between 5 Mile Road and 6 Mile Road where it crosses NE to SW on private property. The owner has expressed his willingness to allow access across his property to four-wheel drive vehicles. We suggest that a temporary closure be made at Six Mile Road until arrangements have been confirmed with the owner for him to sell a permanent easement for that part of his property. The entire length, from Six Mile Road to Five mile Road, would be reopened to the public once the easement has been procured through the utilization of RTP funding and collaboration between the user community and the Baldwin Ranger district.

Reason
This segment also provides an extremely important route for continuity of rustic travel. It is more than just an important rustic connector, it is also the ONLY rustic travel way across Mena Creek.

Ref. Map 5 of 5

Request 6
FR 5182 provides a scenic route between the seasonal road intersecting M-20 and Ferris Road and should be reopened to provide a continuous route to the north.

Comment
· The road across private property bordered by M-20, 2 Mile Road and east of Wisner Road and crossing eastward from Bingham Road to NF land, does not exist and should be removed from the map and discounted from road inventory.
· Where FR 5183 intersects with Ferris Road and is shown as a route to the NE off Ferris Road does not exist and should be removed from the map and road inventory.

Request 7
FR 5184 intersects with Ferris Road at a point where 2 Mile Road would intersect with Ferris Road if it was extended to the east from Wisner. Where FR 5184 abruptly changes direction from northwesterly to southwesterly, we request that FR5284 be open in a northeasterly direction to connect with 3 Mile Road.

Reason
This would provide a continuous route to 3 Mile Road, which permits a short travel distance to Ferris seasonal road without the necessity of leaving the trail and using maintained roads from north on Bingham Road to, and eastward along, 3 Mile Road.
These comments are respectfully submitted by

Patrick J. Brower
VP, Great Lakes Four Wheel Drive Association
Chair, Land Use Committee, GLFWDA
VP, Two Trackers Four Wheel Drive Club, Inc.
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