February 16, 2018

Gunnison Field Office

210 West Spencer Avenue, Suite A

Gunnison, CO 81230

Jim Lovelace and the entire planning team,

Gunnison Trails appreciates the opportunity to provide comment on the draft alternatives to the Signal Peak Trails Plan. We appreciate all of the efforts thus far to engage the public and clearly explain the process. We also want to acknowledge the open houses held at WSCU to better engage the public and provide an opportunity for members of the community to interact with the BLM in person and ask specific questions. These efforts go a long way in addressing issues up front in order to provide for a more robust plan in the long run.

While we are encouraged by many aspects of Alternative B, there are several areas that we would like to directly comment on and suggest changes. These areas pertain to increased seasonal closures, most specifically for mechanized use, the absence of trails on the northside of Signal Mesa and the lack of connectivity to Lost Canyon Rd. From the very beginning, we recognized the need for compromise in Signal Peak; to balance the desires of the recreating community with the wildlife concerns for the area. Gunnison Trails has a strong history of educating trail users on seasonal trail and road closures due to resource and wildlife concerns. We have demonstrated our commitment to such efforts, and believe we have strong compliance amongst our constituency. However, Signal Peak is recognized in the Candidate Conservation Agreement as a preferred location for concentrated recreation. An area that, due to its close proximity to the City of Gunnison and WSCU, provides a recreational outlet for City residents. We believe that Alternative B, while providing a significant increase to the trail mileage in the area, does not adequately provide for all needs defined by an urban interface recreation area.

Seasonal Closures

The majority of comments Gunnison Trails has received pertain to the seasonal closures, both for Gunnison Sage-grouse and wintering wildlife, that affect when and where trail users may recreate. There has been some concern over the area closure in the Ridge Trail West portion of the system, an area with the most historic use, due in part to the existing trails and its close proximity to town. However, we understand the concerns surrounding the active Sage-grouse lek in the area and why an area closure is the best option to mitigate recreational impacts to the lek. Gunnison Trails is committed to educating users on the reasons for the closure, while providing information on what trail opportunities exist elsewhere.


With that said, we feel it is important to provide additional trails for the recreating public when those closest and most accessible to the City of Gunnison are closed for 2 months of the year. While the majority of the system would be open to foot and horse travel (barring the a.m. restrictions for Sage-grouse), we feel it is important to recognize that many trail users are mountain bikers looking for close, accessible trails. Signal Peak, recognized as an urban interface recreation area, is meant to meet the needs of the recreation community looking for accessible trails. Therefore, we advocate for uncoupling mountain bike use from shed antler collection, instead utilizing a condition-based closure for mechanized use rather than a hard closure period that mimics the shed-antler restrictions.

Alternative B unfairly singles out mountain bike use (mechanized) by associating the impacts and restrictions with shed hunting. There is little precedent or data to suggest that the impacts from someone traveling by bike is comparable to someone shed hunting. Mountain bikers stay on defined trails, unlike shed collectors that canvas huge areas entirely off trail. Additionally, shed collecting offers an economic incentive and has grown from a low-impact hobby to the commercial endeavor we see today. Mountain biking, by contrast, has no commercial value. Placing mountain bikers under the increased shed antler collection seasonal restrictions, a period that was extended by 45 days earlier this year, prevents mountain bikes from accessing the trails in Signal Peak during years when the trails may be dry and animals no longer present on the landscape. We do not feel there is adequate rationale to couple the seasonal restrictions for bikes with shed antler collection, as the impacts associated with each are entirely different.  

Instead, we recommend a seasonal closure for mechanized use that is condition-dependent. We have an informed trail community that are aware of the wildlife concerns in the area and want to respect those efforts meant to protect wildlife. Mountain bikers are not looking to push and move herds struggling from the winter months. However, there will be many winters, similar to this one, when the trails in Signal Peak will be dry and lacking animals due to the low amount of snow. We advocate for an adaptive management approach, much like the Hermosa Creek Watershed Management Plan, where seasonal closures can be adjusted based on the severity of the winter, condition of the trails, presence of wildlife, or any other measure considered by the BLM. In the final Hermosa Creek Management Plan, seasonal closures for trails default to specific dates outlined in the plan, “but for the option of longer condition-based opening determined on a season-by-season basis...The exact criteria have yet to be determined, but will likely include factors such as snow depth, trail tread conditions, and big game utilization of the habitat” (Hermosa Creek Watershed Management Plan ROD). Using a similar approach, we feel compliance would be much stronger if trails were opened based on conditions rather than by a predetermined date each year.

In our initial proposal, submitted to the BLM in December 2016, we had recommended 4 different “experience zones” that could be opened at various times throughout the year as conditions provided. Much like the Ridge Trail West area, there are adequate roads and existing fence lines that could define an area south of Signal Mesa which could be opened when certain conditions were met. We feel it is important to recognize that many trail users are mountain bikers, and there is no reason to restrict trail use by user type when the concerns on the ground are no longer present.

Connectivity to Lost Canyon Rd.

We strongly advocate for single-track trails that connect the Signal Peak system to Lost Canyon road. While we understand the importance the north facing slopes of Signal Peak serve for mule deer habitat, we believe the current development on Lost Canyon road, the presence of a popular shooting range and the motorized roads in the area, many decommissioned, but several still in existance, do not warrant eliminating all trail options from the plan. BLM 3219 and BLM 3218 do not currently provide connectivity with the Signal Peak system. While Alternative B proposes the construction of the “Lost Sheep” motorized trail to provide for this connectivity, this does not change the fact that both BLM 3219 and 3218 are steep, loose, fall-line roads that do not provide for an adequate trail experience. Simply linking the proposed Sheep Gulch trail with BLM 3218 before the road intersects with Lost Canyon Rd. would eliminate the need for a defined trailhead along Lost Canyon road. In this way, there would be a sustainable single-track trail alignment in the north area of the system, but one that wouldn’t end on Lost Canyon road and lead to issues with parking or necessitate the development of a trailhead.  

While the vast majority of use will be confined to those trails closer to WSCU, there are members of the community looking for a longer loop option. Much like the Aberdeen trail at Hartman Rocks, longer backcountry loops provide for an entirely different experience, giving individuals on foot or bike the chance to explore the further reaches of Signal Peak and have a more intimate trail experience. Recognizing that use on more distant trails is significantly lower than those closer in proximity to major trailheads, we feel the wildlife concerns associated with the proposed Sheep Gulch and Lost Canyon trails are not warranted, especially considering the amount of current development in the area. We believe a longer loop option of this nature fits within the Signal Peak area, and aligns with those elements of an urban interface recreation area defined by the CCA.

North Woods Trail

The North Woods trail is a popular route on the northside of Signal Peak used for over 30 years. This trail, while originally a cattle or game trail, is remarkably sustainable, and offers a unique experience from other proposed trails in the system. We are encouraged that this trail remains in Alternative B, and want to express the importance of this trail to the connectivity of the entire system. The terrain on the northside of Signal Peak affords a break from the rolling sage hills on the southern side, where trail users can travel through stands of pine and aspen found nowhere else on the trails in close proximity to the City of Gunnison. The existing North Woods trail and the proposed North Woods Extension trail to the east would create much needed trail variability in the Signal Peak system.

Total Trail Mileage

While Alternative B calls for a total of 21.6 miles of new trail development, Gunnison Trails would like the final Record of Decision to adequately address the total mileage identified in the CCA as 28 miles, and to acknowledge the potential to further develop the trail system with appropriate connector trails and/or reroutes up to 28 miles. While we have always focused on quality over quantity in trail construction efforts, we understand that recreation habits and trail use are not static, but change over time. Therefore, it is important to leave open the potential to adapt with the inevitable change and plan for future trail connectivity.

Finally, we approve of the current layout and density of trails on the south side of Signal Mesa. As the map is currently drawn, there are multiple trail options to give users varied loops starting directly from Gunnison. The inclusion of the proposed Broadcaster trail leaves open the possibility of a bike-optimized trail that are quickly becoming the norm in many stacked-loop trail systems. Examples include Collar Bone trail at Hartman Rocks and the newly constructed Chicken Dinner trail in Salida’s Arkansas Hills trail system. These popular trails prescribe to the BLM’s Guideline for a Quality Trail Experience, and offer a bike-optimized experience compatible with the rest of the system.

We also approve of the camping restrictions in the entire area. We have witnessed the rise in popularity of camping at Hartman Rocks, where there is adequate infrastructure to sustain increased camping pressures. Due to the wildlife concerns in the Signal Peak area, camping would only increase motorized traffic on many of the system roads, and introduce further pressures.

We appreciate the opportunity to provide comments on behalf of Gunnison Trails and our membership base. We are encouraged by the level of public involvement and participation in this entire process, and look forward to working collaboratively moving forward. Thanks very much for your consideration.

Gunnison Trails Board of Directors

Tim Kugler, Executive Director