Wisconsin ATV Association, Inc. (WATVA)
5531B N. Hwy 42
Sheboygan, WI 53083
Phone (920) 565-7531
www.watva.org


To: Pat Murphy
Black River State Forest Master Plan Team Leader
1300 West Clairemont Ave.
Eau Claire, WI 54701

CC: Paul DeLong – Chief Forester Paul.DeLong@Wisconsin.gov
Peter Bakken – Superintendent Peter.Bakken@Wisconsin.gov

Re: WATVA Comments on Preferred Alternative and Options document for the March 28 Black River State Forest Master Plan Revision



The Wisconsin ATV Association (WATVA) represents a diverse membership across the entire state. Currently we have 94 local chapters and their many affiliates; we serve 146 various businesses that depend on positive ATV economics because those businesses supply their local communities with hundreds if not thousands of jobs. Our constituents also include tens of thousands of ATV family members across the state of Wisconsin who enjoy their chosen form of outdoor recreation, ATV pleasure riding.

WATVA certainly supports properly managed ATV trail systems and we understand that like other types of outdoor recreational endeavors, the citizens of our state expect the DNR to manage our property wisely and fairly. Our members understand public property management plans need to be adjusted from time to time to accomplish that goal.


It should be noted however that the WATVA membership is very concerned about some recent decisions and trail proposals on other state managed public property that we feel was unfairly depicted by some very biased anti-motorized zealots. Our concerns are obviously about discriminatory treatments toward decisions on the BRSF that would not be based on truth, logic, and common sense.




The Wisconsin ATV Association considers the Black River State Forest to be a very important motorized recreational area and is therefore very concerned about the alternate plans presented by the Department. The WATVA wishes to work with the Department of Natural Resources to seek better solutions in order to maintain the status of the BRSF as being a premier ATV recreation destination.

In order to make our input easier to review, we have made some general comments and then pose some pertinent questions. We then address each trail provision by number so all parties reading our comments can better understand our responses.

Comments

The social and economic concerns of the local community need to be taken into greater consideration. Tourism and positive economic impact in the Jackson County and surrounding areas revolve heavily around motorized recreation. Thousands of people and the general economy of Black River Falls and the greater Jackson County area will be affected by the decisions made in the final Black River State Forest Master Plan Revision.

Indeed the Executive Summary mentions the importance of the ATV trail system, it notes the high trail use and that this system is part of a major regional trail network. Also stated is that motorized trail users significantly contribute to the local economy and the DNR’s own analysis indicates that motorized recreation is growing in popularity.

It is emphasized in the summary that motorized recreation is a legitimate use of public lands and the Department is now going to manage by limiting ATV use to designated trails and areas.

The DNR revision plan is to respond to this huge ATV trail increase by proposing a drastic 30% reduction in total trail miles on the state forest?

This type of management response is not logical. At the very minimum the current trail mileage should be maintained and at best more miles of ATV trail should be considered.

The current alternative and options that reduce ATV trail mileage versus increase mileage does not balance the need of the growing number of ATV recreationalists seeking additional ATV opportunities?

We feel the DNR needs to develop a true range of alternatives and provide for future expansion based on the sports increased popularity.


The current alternative option is a very serious shortcoming in the planning process. We request that the DNR follow their own master plan guidelines by developing and investigating all reasonable alternatives in their proposals other than alternatives that eliminate loop trails.

Currently the plan says that “segregation of users” is being asked for by the non-motorized, silent sport community. We suspect that non-motorized users are not fully utilizing all of the existing areas that are now set aside for their exclusive use. The WATVA feels strongly that the comments received by the DNR may well be a “tactic” to achieve the objectives of several extreme anti-access advocacy groups who make it clear their goal is to displace the ATV trail rather than a true indication of recreational conflict. These groups will stop at nothing short of closing all motor vehicle access to the Black River State Forest and other public lands.

The responsible recreational community and hopefully a majority of the general public have grown weary of the distorted perspective offered by these “anti-motorized” groups. Separating all uses in all areas under all circumstances is a poor “last resort” option that we feel it is not a viable strategy.

The Wisconsin ATV Association feels strongly that ATV and motorized recreation in general is being discriminated against and in fact motorized trails are being displaced by some public land managers who allow these extremely polarizing positions and personalities to dictate unfair public policy. This stance leads to long-term ill-will and decreased support for the DNR in general. The Black River State Forest should be extremely cautious about enthusiastically embracing segregation of this type; it wasn’t good for this country in regards to race relations and certainly is not good public policy for all land management decisions.

In the past 15-20 years new outdoor activities such as mountain biking and ATVing now compete with what was once considered traditional activities such as hiking, cross country skiing, and nature trails. While all user groups lobby for their own trails or special use areas, DNR management strategies must change and adjust based on the public’s more diverse recreational demand. Unfair biases that do not treat motorized recreational needs on a fair and even platform with other types of recreation must be avoided. With today’s public budget challenges land managers should weigh heavy consideration for self-funded programs when making decisions such as moving existing trails or building other kinds of systems. None of the other non-motorized programs and users, except maybe campers, has such a strong, viable funding system to pay for their types of use.

On the funding topic, based on the Department’s lack of proper trail grooming maintenance equipment and personnel to do the necessary trail grooming with, the Wisconsin ATV Association recommends the Black River State Forest enter into an agreement with the Jackson County Forestry & Parks Department to maintain the ATV trails on the BRSF property. It is our opinion that Jackson County is better equipped and already has trained personnel currently taking care of the adjacent ATV trails on Jackson County lands. A county grant sponsor can add the additional trail miles into their grant-in-aid applications they currently administer. The county is not restricted to state line item budget challenges that the BRSF is when it comes to rehab, maintenance and other trail needs to keep the ATV trail system in a better condition. Jackson County grooms right up to the BRSF property line anyway, the county currently has the right grooming equipment on hand and has the trained staff already in place. That the county has a different monetary budget line with which to draw the state ATV program dollars from, WATVA contends it would be a winning solution for the BRSF, the Jackson County Forestry & Parks Dept. and ultimately for the ATV owners who pay for the program.

Exactly what type & frequency of noise conflicts exist between ATVers on trail T6 and silent sports area? Has any sound testing been done to back up these claims? Broad statements like these need to be supported with some type of data or information that can be evaluated by everyone. Again, the Department mentions noise impacts and impacts on nearby unique native communities. What exactly are these impacts and what are the unique native communities?

The proposal document states: “Bringing trails up to Department standards, and strive for sustainable trails that reduce impacts and require less maintenance” – “Upgrade all trail surfaces” – What does all this mean, what standards? More description is needed and clarification of the word “sustainable” before the public is mislead as to what the end trail product will be. Sustainable is often a misused and subjective term used when in discussions of the design and construction of new facilities or rehabbing existing ones. In our experiences to date we have found some of the Department staff using the subjective and nebulas term sustainable” to define or imply that a trail should be so over engineered it will rarely need routine maintenance. We contend that type of ATV trail is no longer a trail a rider would even enjoy riding; it is very likely unsafe due to flat and straight surface sight lines and is usually cost prohibitive to even consider funding. We strongly urge the Department to develop written trail standards for the design of new trail sections and for the maintenance of existing trail sections for inclusion in the Draft Master Plan. Without written standards agreed on with the public ahead of time, the application of “trail

standards” is extremely arbitrary and it’s difficult to comment on such
general terms in this analysis report.

In the Motorized Trails - Recreation Facilities Management Section, it states that upgrading trail surfaces may include crowning, culverts, and hauling considerable amounts of materials, (which we assume to mean gravel aggregate), and building possible bridge crossings. WATVA urges the DNR not to use these traditional road construction methods for ATV trails. The DNR needs to investigate newer trail design/construction methods that have been developed by professional trail builders around the country. The Bureau of Parks has hired one of these professional trail designers to train their personnel responsible for trail design & maintenance at another state property (Richard Bong Recreation Area); we urge the Division of Forestry to search outside the agency for new and innovative trails design ideas. We also suggest discussions with the adjacent county trail administrators, which Jackson County is the most obvious contact.

The Department proposes changes to the motorcycle use law to comply with the Jackson County ordinance to limit motorcycle trail use only to “dual sport” motorcycles. While we understand the Department’s desire to have complimentary trail regulations with Jackson County, one of the negative impacts is the elimination of a motorcycle riding area not only for adult off-road riders, but also for youth riders. The involvement of our youth in all outdoor recreation activities should be encouraged by the Department, not just limited to youth hunting & fishing programs. In the Draft Master Plan we urge the Department to consider future development of a single-track trail for off-road motorcycles, but especially to include a youth motorcycle riding area.

The Department mentions it is dropping the option of redesigning a portion of the Castle Mound campground for possible ATV camping. We feel that the complete elimination of any future ATV camping because of the Lake Arbutus camp development by Jackson County is not reasonable and assumes that the county can handle all future demands for the next 15 to 20 years. We urge the Department to at least mention the possibility of ATV camping at some future site if future demand may require some type of development in the Draft Master Plan. We request equal consideration for future unknown ATV camping, just as you present possible future options for horse riding camping, rustic camping, and group camping in your analysis. Once again we question why the needs of the ATVing public are thought of differently than our counter parts in other outdoor recreational types?





ATV trails should be designed to slow down traffic, avoiding long, straight sections of trails with moderate radius curves for maximum curve speeds of 25 MPH, along with hard bottom, shallow water areas where feasible. WATVA encourages the use of boardwalks designed to carry the weight of ATV’s only, not build large, expensive road bridges.


Motorized Trail Section 1

WATVA requests that the ATV/Snowmobile trail remains in its current location. If it is indeed necessary to designate a horse trail only segment, it would be more feasible to move the horse trail, than the ATV/Snowmobile trail. We recommend building the horse trail to the Bureau of Parks new standards.

Motorized Trail Section 4

WATVA requests that this section of trail remains designated for Snowmobile/ATV use and remain as a connector for the main Wildcat Loop route to the south.

Mitigate wetland travel with bridges, boardwalks and culverts or reroute slightly from the wetland area on higher ground. Boardwalks are the cheapest and least destructive structure to bridge wetland areas, plus most boardwalks do not require DNR wetland permitting. Culverts and bridges should only be used where a more permanent solution is necessary to cross flowing water or seasonally high water levels at specific locations. We urge you to contact the surrounding county forestry administrators and their staffs that have extensive experience working with DNR water management specialists to meet all wetland permit requirements concerning ATV trail construction.



Motorized Trail Section 5

WATVA would agree to the elimination and abandonment of Motorized Trail section 5.








Motorized Trail Section 6

WATVA strongly requests the Trail Section 6 / Wildcat Loop remains intact. The Wildcat Loop has been a less traveled trail but a perfect trail for families with young riders and it’s close to Millston that has a trailhead. The elimination of this loop will add more riders to an already heavily used system. Additional trail miles are needed to disperse the volume of riders over the entire trail system.

WATVA feels with more due diligence any impact on wetlands and unique native communities can be mitigated through some slight re-routing without closing this trail section. Our group understands and appreciates the need to protect the fragile resources on our state forests, but management by closure does not serve the public and is not the proper solution.

Motorized Trail Section 8


WATVA understands the complexity of this segment of the trail near the Village of Millston and endorses the preferred proposed reroute of the trail. These actions would complete the trail through the Village and enable trail users to access the village services.

WATVA would also offer their assistance in facilitating this difficult reroute.

Excerpts taken from Secretary Matt Frank’s memo dated April 11, 2008 addressed to the Natural Resources Board (NRB) related to his decision to recommend no ATV trails in the Northern Highland – American Legion State Forest reads as follows:

“The Department remains fully committed to working with partners to improve existing ATV trail opportunities and to expand opportunities in Wisconsin to address the demand for an increasingly popular form of outdoor recreation. ATV registrations increased 348% from 1996 to 2005. We are committed to doing so in a manner that is cost-effective and sustainable over the long-term. Over the last five years the Department has distributed nearly 600 grants to 34 counties totaling more than $13.1 million for ATV trail projects. The Department is currently evaluating existing ATV trails, over 30 miles, on the Black River State Forest as part of that master planning process.





WATVA is pleased Secretary Frank and his staff have acknowledged the dramatic increase in ATV use and has committed to working with partners such as the Wisconsin ATV Association and our many members. We certainly hope the Black River State Forest Preferred Alternatives and Options will fall within those same intentions.

The Wisconsin ATV Association and its Chapter Clubs, its many businesses and travel partners that provide an invaluable economic stimulus to the surrounding counties and areas thank you for this opportunity to present our view of the Preferred Alternatives and Options for the Black River State Forest. We welcome the opportunity of partnering with the Wisconsin DNR to provide enjoyable and safe trails for recreational users into the future.

Please feel free to call our state headquarters office for any clarifications or questions you might have about our input or our comments.

Sincerely,

Randy Harden Rob McConnell

Randy Harden – President Rob McConnell – Vice President

WATVA Trails Committee WATVA Board of Directors