Ventana Wilderness Alliance
NEPA & CEQA Comment Letters

John S. Bradford
District Ranger
Monterey Ranger District, Los Padres National Forest
406 South Mildred
King City, CA 93930

September 27, 2002

SUBJECT: Scoping Comments for a Comprehensive River Management Plan, Big Sur Wild and Scenic River Corridor.

Dear Mr Bradford:

The Ventana Wilderness Alliance (VWA) is a 501(c)3 non-profit organization that works to promote the conservation of resource values in the northern Santa Lucia Mountains. The VWA encourages the careful stewardship of our public lands in the Los Padres National Forest. We appreciate the opportunity to provide the following comments regarding the preparation of a Comprehensive River Management Plan (CRMP) for the Big Sur River.

We applaud the preparation of a CRMP that protects the unique environmental qualities that characterize the Wild and Scenic Big Sur River. Our general and specific comments on the CRMP Proposed Action include:

GENERAL COMMENTS:

1. The first paragraph on John Bradford's August 28, 2002 letter inviting scoping comments notes that the Comprehensive River Management Plan (CRMP) for the Big Sur Wild and Scenic River will amend the current Land and Resource Management Plan (LRMP) for the Los Padres National Forest. However, CRMP scoping and NEPA compliance are being conducted separately from the ongoing LRMP revision process. Please clarify whether the new CRMP will be automatically folded into the revised LRMP, or whether there will be further review of the final CRMP as part of a draft LRMP.
2. The VWA would like to note that the Big Sur River was declared a Wild and Scenic River in 1992 and that Section 3(d) of the Wild and Scenic River Act, 16 U.S.C. § 1274(d) reads that a River Management Plan must be prepared within 3 years following designation. Section 3(b) of the Act 16 U.S.C. § 1274 (b) reads that river corridor boundaries must be established within one year of designation.
3. We would like to highlight language specified in the Forest Service Manual that pertains to the preparation of River Management Plans. The CRMP for the Big Sur River should incorporate the following mandates:

2354.32 - River Management Plan. Prepare a management plan in accordance with section 3(b) of the Act within 1 year following designation or as otherwise provided by the designation language.

Management plans for designated rivers must:

1. Establish management objectives for each segment of the river. As a minimum, state the Recreation Opportunity Spectrum class featured (ROS, FSM 2310) and procedures for maintaining the ROS for each segment over time. To the extent possible, the management objectives should reflect the river's recreational relationship to nearby rivers.
2. Describe historical trends in use, demands, and needs of the river resources and likely future trends.
3. Include specific and detailed management direction necessary to meet the management objectives.
4. Establish detailed river area boundaries.
5. Determine wild, scenic, and recreation classifications that best fit the river or its segments, unless those classifications are prescribed in the designating legislation.
6. Establish appropriate levels of recreation use and developments to protect the values for which the river was designated. See section 3(b) and 10(a) of the Act and the guidelines.
7. Provide for public safety and refer to State boating laws, U.S. Coast Guard Regulations, and other applicable State and Federal Regulations.
8. Prescribe actions needed to manage development along the stream bank (sec. 6 of the Act).
9. Provide for monitoring and evaluating visitor use patterns, use impacts on the river, and visitor experiences.

2354.4 - Wild and Scenic River Management Activities.

2354.41 - Recreation Visitor Use. When necessary, develop prescriptions to manage the character and intensity of recreational use on the river.

Use specific management objectives for each segment. Consider the following factors in developing direction:

1. Capabilities of the physical environment to accommodate and sustain visitor use.
2. Desires of the present and potential recreation users and trends over time in the amounts, types, and distribution of recreational use and the characteristics of recreation users. These help identify what kinds of recreation opportunities to provide and how and where to manage and maintain such opportunities.
3. The diversity of river recreation opportunities available within the geographic region.
4. History of nonrecreation uses that are compatible or conflict with recreation use of the river.
5. Budgetary, personnel, and technical considerations.

Exhibit 01, showing the relationship of Recreation Opportunity Spectrum (ROS) categories to the river classifications and management activities, is an aid in determining if an adequate mix of recreation opportunities is feasible.

SPECIFIC COMMENTS ON SCOPING LETTER:

1. Item Number 1. Please clarify that the designated boundaries for the Big Sur Wild and Scenic River Corridor cover one-quarter (0.25) mile on each side of the center line of the river. Section B(7) of the March 2002 Settlement Agreement specifies that, "The river corridor is one-quarter (0.25) mile in width on each side of the river".
2. Item Number 2. The VWA would like to note that the Forest Service is the responsible party for any collaborative weed prevention and suppression projects undertaken on the Los Padres National Forest.
3. Item Number 3. Indirect Management Actions should include public education efforts along the Pine Ridge Trail, as well as at the trailhead and the Big Sur Station. The campaign to protect Wild and Scenic River values must be initiated in advance of public visits to the Big Sur River corridor. We encourage the Forest Service to increase wilderness information and "Leave No Trace" education by incorporating this component of river management into all outreach efforts in the backcountry, at the trailhead, and at the Big Sur Station. According to B(14) of the March 2002 Settlement Agreement, when responding to inquiries, the Forest Service should recommend trails and campsites in lieu of the Pine Ridge Trail and Sykes Hot Springs.
4. Item Number 3, Direct Management Actions: Please define what is being impounded at Sykes Hot Springs and describe impacts associated with those impoundments. We encourage the Forest Service to extend seasonal no wood fire restrictions to Redwood Camp.
5. Item Number 4: Baseline surveys and monitoring of camp areas should be conducted along the Big Sur River corridor to identify ecological impacts resulting from human activity in the riparian zone. Baseline data collection must have water quality parameters, including fecal coliform. We encourage the Forest Service to evaluate the distribution, quantity and condition of campsites and fire rings for possible remedial action, including campsite rehabilitation or closure. The installation of latrines should be considered to minimize impacts to water quality. According to item A.5(e) in the March 2002 Settlement Agreement, an assessment should also be made of mining claims, livestock grazing, water withdrawals, special use permits, inholdings, recreation, overflights and exotic species as these issues pertain to the protection and enhancement of Outstandingly Remarkable Values. Please note that an assessment of potential impacts from outside the Wild and Scenic River corridor should also be conducted if there are land use activities (grazing, oil and gas exploration/drilling, OHV use, etc.) within the larger Big Sur River watershed that could influence resource values within the designated area.
6. Item Number 6. Heritage resources should be aggressively protected, however signs and interpretive construction should be located outside the wilderness.

Please consider these scoping comments as also being submitted on behalf of the Center for Biological Diversity.

We look forward to the opportunity to provide further comments during the NEPA review of the draft Comprehensive River Management Plan. Please contact me if I can provide additional information.

Sincerely,

Jon Libby
President

Cc: Peter Galvin, Center for Biological Diversity