This is what we are up against .

Date submitted (UTC-11): 11/18/2016 10:24:06 PM
First name: Tom
Last name: Sobal
Organization: Quiet Use Coalition
Title: Director
Official Representative/Member Indicator:

( Please accept and consider these comments on behalf of the Quiet Use Coalition with regards to proposed
restrictions on camping in the Lake Irwin and Tincup areas on the Gunnison Ranger District, and related to the
information provided online at
http://www.fs.usda.gov/detail/gmug/n...d=FSEPRD521672 .
Our members have used and visited these areas. We currently use and visit these areas. We have
observed and noted increase negative impacts resulting from camping and especially dispersed motorized
camping in these areas over the past 30 years.
We support the proposed restrictions with the following comments.
It must be emphasized that there are existing designated public and private campgrounds near to these
locations that can more efficiently and responsibly accommodate and manage campers. There are also
numerous other opportunities to camp on other parts of the forest. Restricting camping in these two small
areas will not have a significant impact on the overall availability of camping on the Gunnison National Forest.
We agree with the determination on page 191 of the Final Environmental Impact Statement for Gunnison
Basin Federal Lands Travel Management, which states that loss of some dispersed camping opportunity would
result in some dissatisfaction, but that dispersed campers would likely find abundant other dispersed camping
opportunities on the forest and relocate to those. We also agree that not all forest visitors wish to stay on or
near the forest overnight, and other opportunities such as designated campgrounds and other forms of lodging
exist as alternatives to dispersed camping.
The proposed action will prohibit dispersed camping near designated campgrounds at Lake Irwin and Mirror
Lake. It will help focus and concentrate camping use and impacts into those designated campgrounds and
other locations designed and managed to more responsibly and appropriately accommodate camping. This will
help concentrate camping in the designated campgrounds, maintain desired experiences for campers in the
campgrounds, and help prevent use of campground amenities by non-paying dispersed campers.
We generally recommend that no dispersed camping be permitted within one half mile of any developed
campground. The GMUG National Forest currently uses a similar strategy to restrict camping near the Mosca
and Dinner Station designated campgrounds. The proposed action will help implement similar restrictions near
the Lake Irwin and Mirror Lake Campgrounds.
Dispersed motorized camping involves overnight use and occupancy, and additional impacts, which must be
fully considered. These are difficult to manage and monitor and they may include:
* human and other waste disposal
* fires and increased risks of human caused wildfires
* potential increased recreational target shooting
* noise and unnatural sounds
* unnatural food sources
* unnatural light at night
* unnatural odors
* increased/extended human presence
* potential impacts to riparian areas
* wildlife impacts
* Impacts to vegetation due to trampling, campfires, and firewood collection
* impacts to adjacent private land, trails or other existing facilities
* impacts of pets, horses, etc.
* additional visual impacts associated with human use and presence, vehicles, gear, etc. which can last
for days/weeks.
* impacts to grazing livestock
* impacts to historic and cultural resources associated with increased visitation, vandalism, etc.
With an unpredictable and relatively unmanaged activity such as dispersed motorized camping, these
impacts can quickly result in significant resource, social and management concerns.
Motorized dispersed camping also leads to the development and proliferation of unauthorized motorized and
other routes near the dispersed camp areas. The 300-foot allowance is confusing for the public as it is
sometimes difficult to discern which routes are designated system routes, how far 300 feet is, and which routes
are undesignated non-system routes. Some members of the public mistake undesignated routes for designated
routes, and develop and use additional routes which extend 300 feet beyond undesignated spur routes. This
results in motorized use extending 600 feet and beyond away from designated routes. This misperception can
result in the proliferation of numerous layers of unauthorized motorized use and camping well beyond the 300-
foot allowance.
We strongly recommend a restriction on all dispersed motorized camping that can be accessed off FR 826
in addition to the proposed restrictions in the Lake Irwin area. As the primary and only access road to the Lake
Irwin area, also restricting dispersed camping from this road will permit an opportunity for consistent area wide
management of camping in this area. Educational signage restricting camping could be installed at the
beginning of FR 826 at the intersection with CR 12 which would consistently apply to all lands which could be
accessed by FR 826 in that area. There is not a great deal of dispersed camping which occurs off FR 826 so
this restriction would not result in significantly modifying existing uses and conditions. Dispersed camping is
currently depicted as permitted along FR 826 according to the Motor Vehicle Use Map. This additional
restriction would help prevent the development and use of new dispersed camp roads and sites in this
immediate area which may result from new restrictions on roads beyond. This additional restriction would help
focus any and all camping in this area to the developed and designated Lake Irwin Campground, where it can
be better and more responsibly managed.
These proposed camping restrictions will minimize dispersed camping related impacts to adjacent private
land in these areas.
The restrictions near Tincup will help minimize dispersed camping related impacts to Willow Creek and East
Willow Creek. There are some existing dispersed campsites which are very close to this creek and associated
wetlands.
The restrictions will help with the management of the concentrated large volumes of public use near Lake
Irwin, Mirror Lake and Tincup. Limiting the overall amount of camping available in these areas ensures that
the majority of visitors will be day use only as opposed to overnight use.
The restrictions will help maintain and improve scenic vistas and views for those visiting these areas. Many
more people pass through and use lands associated with these areas than dispersed camp along the corridors
associated with roads in these areas.
We support allowing people to park a vehicle within one vehicle length of the edge of designated roads in
these areas, as permitted by FSM 7716.1 and 36 CFR261.54, where it is safe, appropriate and will not cause
or contribute to resource or facility damage.
We support a complete prohibition on all camping within these areas, as proposed. This will simplify overall
management, public education, and enforcement of the restriction. It will provide time and opportunity for the
Forest Service to objectively evaluate existing dispersed campsites in these areas for potential inclusion as
officially designated roads and dispersed camp locations and designated spur at some future point, if this is
desired and found to be appropriate. It will take additional time and effort for proper inventory, mapping, and
field evaluations of the existing dispersed camp roads.
Although the proposed prohibition on all camping in these areas is slightly different for the approved
sequence for addressing dispersed camping in the Kebler Pass/Lake Irwin area (as suggested on page 47 and
190 of the FEIS), we support the proposed full prohibition on dispersed camping in this area. The additional
costs of time and effort to inventory, map, analyze, designate, implement, and manage new designated spur
roads for dispersed camping are likely more than the recreation program budget can bear. Page 191 of the
FEIS suggested that funding may be limited, and recreation program trade-offs may be required. We believe
the proposed prohibition on dispersed camping in this area is an appropriate trade off, until the forest has the
resources to conduct an appropriate analysis of camping in these areas)