August 2009 Featured Articles
BLM Tioga Bridge Project
Joe Ferguson - August 25, 2009 Jay Carlson, District Manager
Gregg Morgan, Recreation Planner
BLM Roseburg District
777 NW Garden Valley Blvd.
Roseburg, OR 97470
Comments on Tioga Bridge Project Environmental Assessment
Steamboaters have the following comments on the proposed Susan Creek Trail/Tioga Bridge/Parking improvements as described in the Environmental Assessment.
As we have stated before, Steamboaters recognizes some benefits for improving pedestrian, maintenance, and emergency services access to the trail on the south side of the River. However the need for this improved access has simply not been established. This EA provides no quantification of the problems to be addressed, nor whether this project is a cost-effective way of solving those problems. On the contrary, this proposal creates new problems, long-term impacts in the riparian zone, additional maintenance funding issues, and public hazards which aren’t addressed.
The largest concern we have is that the EA contains is no documented need for this project other than providing maintenance and emergency services access to the River trail, and this need is completely undefined. There will be significant impacts to riparian areas and no justification is provided for these impacts.
- There is no data regarding incidents that require emergency services, no estimate of this need or any evaluation of alternative methods of providing this access such as via the existing roadway and improvement of the 1.65 miles of trail proposed for heavy equipment access. This would be far cheaper and just as effective. What is the nature of previous EMS calls? Have they been able to provide assistance through other routes?
- Maintenance access is another justification, yet an admitted maintenance backlog exists. This project will create additional need for maintenance where existing maintenance obligations cannot be funded. Again, no discussion of alternatives to providing maintenance, perhaps through contracting. It’s difficult to believe that no contractor would bid to maintain this trail without the Tioga Bridge.
- The projected use increase appears to be entirely a result of this project, and appears to greatly overestimated. It’s not based on either need or current use patterns– sort of a “build it and they will come” philosophy. This does not provide sufficient justification for a major project in the Riparian Zone of an important anadromous fishbearing stream, or for the visual blight along the W&S River or the Scenic Highway.
In addition, the following specific issues have not been dealt with adequately enough to support a Finding of No Significant Impact. In fact the EA provides conclusive evidence of significant impacts.
1. The use of the bridge and trail by horses.
- Placing horses in close proximity to the North Umpqua Highway and the diverse traffic it carries will create an accident waiting to happen. Horses are spooky animals, and placing them close to motorcycles, bicyclists, chip trucks using their jakes, and people coming and going in the immediate area guarantees that sooner or later there will be a serious accident.
- There is no proposal for adequately removing horse waste from the edge of the road, parking areas, or the bridge itself. This waste, besides being a nuisance, will end up a point source for pollution in the River.
- There is an existing problem with horse waste and erosion along the trail from Swiftwater Park which provides an appropriate example of what can be expected with equestrian access to this section of the River trail or on the Emerald Trail. This issue and the obvious comparison is simply ignored.
2. The projected use is highly overestimated and unsupported by the explanations.
· The total estimated existing use for the Susan Ck Day Use Area and Falls trailhead combined is 22,100 people. Assuming that 90% of that use occurs during the 6 nicest months, that’s 110 people in this area every day from the middle of April to the middle of October. It doesn’t happen.
· The estimated increased use of the bridge and Tioga trail is 13,000 people per year. Where will these people come from? There are 4 shorter trails along the North Umpqua River, the first within 8 minutes by car. What is the level of existing use on these segments? (They are not overcrowded). Why not keep a longer alternative for those who desire it? With these segments and the Tioga segment, one can assume that everyone who wants to use a trail along the River can already find a location to suit their needs.
3. Expansion of the picnic area and accommodating double the number of visitors will place a great demand on sanitary facilities and water supply. Current facilities and water supply cannot meet existing levels of use. Inadequate sanitary facilities will concentrate human waste in the trail and parking areas. There is no discussion of Water Rights or the ability to meet additional demand; it’s simply not addressed.
4. There is no discussion of the possibility that the abutments are in fact historical structures which have been in place for 45 years and which provide ample testimony to the power of the River and natural forces. It appears they would indeed be eligible for Historic status.
5. Under Discussion of the Alternatives P8, Section 2 is entitled Modification of the North Umpqua Trail, but includes impacts and actions on the Emerald Trail. Consequently it’s unclear if the widening to 12’ is only for the North Umpqua Trail or the Emerald Trail as well.
6. There is a huge impact from creating a roadbed for heavy equipt to test drill at the east side of Susan Ck, and for placement of a 90’ long bridge. There is no evaluation of alternatives if drilling produces negative results. Perhaps the drilling is unnecessary; was drilling done for all the existing bridges on the River Trail system?
7. Discussion of alternatives (Pg 12) along the highway is inadequate and no preferred alternative is chosen although they have significantly different costs and impacts. Option A has a very large visual impact as well as damage to a narrow riparian area. What does ODOT say about the alternatives? Will they design/fund/build either alternative? Will they permit either alternative? You have two completely different alternatives, with different impacts, but no preferred alternative is selected and no cost comparison is included.
8. Section 7, Utility Upgrades, does not include an upgrade to the existing storm drain system for the trailhead parking lot. This drainage system currently drains untreated runoff directly to the River. This issue was raised before and should be addressed in the EA.
9. Section 8, Maintenance only discusses programmatic actions, not funding. There is no discussion of potential removal of trees that are hazardous to users of the trail (presumably as important as hazards to the structures). Without the Emerald Trail, none of the trees in the riparian area of two fishbearing streams would be classed as “hazardous” and require removal. The increase in public use will lead to more hazardous tree removal.
10. The Project Design Features for impacts to water quality and soils is inadequate.
- This action would expose significant area to the occasional heavy summer thunderstorm and typical winter precipitation. Footnote 1: “..many of the water quality PDFs are standard stipulations used in ODOT contracts.” These standard stipulations do not meet Clean Water Act requirements, but instead leave design and implementation up to the contractor. At the Honey Creek Bridge project for example, there were exposed soils left open to precipitation because there was no plan in place and ODOT didn’t want to assume responsibility for directing the contractor. BLM cannot leave this responsibility up to another agency or contractor. Specific erosion protection requirements must be included.
- An erosion prevention/mitigation plan should be required and material should be stockpiled on site which can be implemented on short notice in event of unplanned rainfall events which happen routinely in the summer.
- A final site stabilization and revegetation plan should be mandatory for any work done in the riparian area.
11. The need for the additional parking loop isn’t justified, and the analysis of the logical alternative to working in the Riparian Area (parking on the north side of the highway) is completely inadequate.
- This segment of the River is the least popular for rafters, and parking for rafters simply isn’t a problem. The great majority of rafters use the upper River, above Steamboat Creek. No justification is given for a permanent facility in the riparian area; no estimate of the parking problem, no discussions with rafting outfitters, and no alternatives to this parking area or other potential solutions are included. The use of the Falls trailhead lot is listed and rejected (Pg 19). However, provision of additional parking on the north side of the highway is not considered at all, nor is the option of delaying additional parking at any location until the need actually arises, which it may not.
- The concern about additional foot traffic across the highway a red herring. Parking raft vehicles at some location across the highway will lead to an insignificant number of people crossing the highway – one driver of the vehicle who will drop off the vehicle and presumably get a ride back up the River (Zero pedestrian crossing at that time); and one person walking up from the raft takeout to get the vehicle. This is perhaps 2/day, or less than the number of people currently directed to the toilets on the north side of the highway by the BLM.
12.The Recreation ORV impacts from construction of the Tioga Bridge (Pg 22)are questionable or downright wrong.
- This plan will create facilities requiring more maintenance (Pg 25: “construction of additional facilities….would result in an increased workload for recreation maintenance crews.”), yet maintenance isn’t done in a timely manner on the recreational facilities now. (Pg 21: “…a backlog of maintenance projects has built up on the middle of the Tioga segment due to the complexity of access and a lack of funding.)”(emphasis added)
- Improvement of emergency response times sounds good, but no details are provided. What’s the history of emergencies on the middle portion of this trail segment? How many per year? Summer (low flows) or winter (high flows)? We can’t eliminate risk from outdoor recreation. Why can’t emergency response come from the roadway and (improved) 1.65 mile segment on the south side of the River, a far cheaper solution with less impact? It is remarkably easy to launch a raft at the launch site at the Picnic Area.
- The analysis of impacts to flyfishers is poorly done and not accurate. These fishing locations (holes) are not small places but rather segments of the River up to ¼ mile long. The entire segment of the River from the rapids above the abutments to 100 yards below them is heavily fished, during the summer as many as 20 times/day (at least 10 times the use by rafters). The parking at the abutments for anglers fishing this part of the River is being eliminated; what’s left is to be shared with 5000 people/year (Table 8). While that estimate seems extremely high, it’s reasonable to expect some increase; this plan eliminates parking, increases parking demand, and has a profound negative impact on the fishing community’s historical use of this area. This is not acknowledged nor included in Tables 7 and 8.
- Flyfishers already have fantastic access to this River and a crossing won’t benefit the historical use on the River. While some use of the bridge by flyfishers may occur, the Tioga trail is generally far from the River and will not provide additional fishing opportunity. People will continue to cross the River by wading or swimming.
- The new trailhead will not increase the variety of recreation opportunities, it will reduce them. There are three other segments of 4-5 miles in length within minutes of the Tioga Bridge. There is no other long segment, where people might avoid other users for an overnight camp for example. This will convert the entire trail to day use.
- The Environmental Consequences from expansion of the parking lot (Pg 23) state that “…expansion would better accommodate the existing levels of use and future increases that may result from the construction of the Tioga Bridge (Table 8). Table 8 shows no projected increase in use by rafters.
- This section also states “The increase in available parking for trailers would be expected to result in increased use of the Susan Creek Raft Launch/Takeout (Table 9).” This is completely unsupported and highly unlikely unless parking is a problem which limits rafting use; this is simply not the case and no data is included which suggests that. The low raft use on this River segment is completely unrelated to parking facilities, and no parking problem exists or is documented in any of this analysis.
Visual Resources
Pg 26: “For retention, human activities must not be evident to the casual forest visitor (p.30).” This bridge and the loss in trees and vegetation would absolutely be evident to the “casual forest visitor.” While the existing abutments are visible, they don’t “dominate the scene” as claimed – they are muted by age, weatherization, and moss and provide a silent testimony to the power of the River. Suggesting that tearing out trees and vegetation, increasing the height of the abutments and adding a bridge will somehow “…not add to the number or extent of man-made facilities that dominate the view in the W&S River Corridor” (Pg 27) is patently false.
Steamboaters recommends that a more complete, accurate evaluation be conducted. Without some justification of the need for this project that outweighs the considerable environmental and visual impacts, this project is a huge waste of money. We ask that the No Action alternative be chosen, or the project be withdrawn and a more accurate evaluation and justification be completed.
Thank you,
Joe Ferguson, President
The Steamboaters
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