SLCA & Access Fund Comments: Proposed Action for the Grit Mill and Climbing Master Plan Project Lower LCC

Salt Lake Climbers:

Please read the final proposed action for the Grit Mill and Climbing Master Plan in lower Little Cottonwood Canyon put out by the Forest Service. This project affects the majority of the bouldering and roped climbing on Forest Service lands north of State Highway 210 between the Little Cottonwood Park and Ride lot and the Grit Mill (the derelect building on the left heading up Little Cottonwood Canyon).

The SLCA and Access Fund’s vision for the outcome of this project is the development of sustainable access to the crags and boulders that takes into account the needs for centralized, transit-friendly trail-heads, traffic safety, and watershed protection. We support the removal of the Grit Mill as it has become a target for vandalism. SLCA and the Access Fund would like to share the comments we submitted to the Forest Service. See below.

September 14, 2013

Dear Catherine Kahlow:

Introduction:

The Salt Lake Climbers Alliance (SLCA) and the Access Fund (AF) appreciate the opportunity to submit comments in response to the Salt Lake Ranger District’s Notice of Proposed Action for the Grit Mill and Climbing Master Plan Project (NOPA), dated August 17, 2013.  The SLCA & AF adopt in its entirety the SLCA & AF comment letter that was submitted on June 12, 2013 in response to the SLRD’s NOPA that was issued on May 14, 2013. The SLCA & AF, in addition, would like to raise the issues discussed below that should be fully analyzed in the Grit Mill Environmental Assessment (EA) in accordance with the National Environmental Policy Act of 1969 (NEPA).  Additionally, the SLCA & AF also would like to take this opportunity to publicly support the Proposed Action that has been proposed by the SLRD.

Statement of Standing: 

The SLCA is a non-profit 501(c) organization that works on assuring rock climbing access to climbing areas through advocacy and conservation efforts.  The SLCA’s members have actively used the area that will be affected by the Proposed Action or any of the alternatives described in the NOPA, and its members will continue to do so in the future.  For many SLCA members, climbing in Little Cottonwood Canyon (LCC) and specifically the potentially affected area under the proposed action is a weekly, if not daily ritual.

The Access Fund

The Access Fund is the only national advocacy organization whose mission is to keep climbing areas open and conserve the climbing environment. We are a 501(c)(3) non-profit supporting and representing over 2.3 million climbers nationwide in all forms of climbing—rock climbing, ice climbing, mountaineering, and bouldering. The Access Fund is the largest US climbing organization, with over 15,000 members and affiliates. Utah is one our largest member state, and Access Fund members across the country regularly travel to the Wasatch Mountains and areas statewide to climb at Utah’s several world-class climbing destinations including the Cottonwood Canyons. For more information, see www.accessfund.org.

Issues That Should Be Considered by the SLRD:

The issues raised in this section are presented in addition to the issues raised in the SLCA & AF’s letter, submitted June 12, 2013.  Since the SLRD proposes issuing a Final EA as the next stage in this NEPA process, the SLCA & AF cannot a priori comment on whether the issues raised in its June 12 comment letter have been adequately analyzed by the SLRD in this NEPA process.

Winter Closure of Grit Mill Parking Lot: 

The NOPA describes a winter closure for the Grit Mill parking lot under the Proposed Action.  The SLCA & AF request that the SLRD provide clarification on what is meant by a “winter closure.” The SLCA & AF reiterate its view that the Grit Mill parking lot should remain open during all of the winter months as climbers access these lands during all months of the year and cannot reliably utilize the Park and Ride lot during the ski season.

However, the SLCA & AF suggest, should such a closure be deemed appropriate after careful consideration through the NEPA process, a winter closure should not be based on strict dates but should be based on actual weather conditions.  Flexibility on the timing of a winter closure will become more important as the impacts of climate change become greater in the Wasatch-Cache National Forest.[1]

Summer Trailhead: 

Similarly, the NOPA references a “summer trailhead” being developed as part of the Proposed Action.  The SLCA & AF request that the SLRD clarify what is meant by a “summer trailhead.”  Would this trailhead be “closed” at certain times of the year?

Recreation Issues Related to Newly Developed FS Loop Trail:  

Under the Proposed Action and Alternative 3, the SLRD proposes building a FS loop trail.  In considering how to best site this trail, the SLRD should consider potential safety issues that may arise from having this loop trail too close staging areas for popular climbing routes.  Siting the loop trail too close to staging areas may expose non-rock climbing recreational users to hazardous conditions such as inadvertent rock fall from rock climbers.  Adequately buffering the loop trail from these staging areas will also deter potential theft, which may occur as rock climbers often temporarily leave packs and other equipment at the base of rock climbs while climbing.  Related to the points raised in this paragraph, the SLRD should consider what factors, such as signage and actual siting of the FS Loop Trail, will provide for the most efficient multi-use of the trail by recreational users while avoiding conflicts amongst recreational users.

SLCA & AF Support of Proposed Action:

Notwithstanding the SLCA & AF’s desire that the Grit Mill parking area remain open year-round, the SLCA & AF support the Proposed Action, because the SLCA & AF believe the Proposed Action is the alternative that most conforms with the Final Environmental Impact Statement-Wasatch-Cache National Forest Land and Resource Management Plan Revision  (2003 Forest Plan; Forest Service 2003) while meeting the present and future needs of the SLCA & AF & AF membership.

Regarding the implementation of the Proposed Action and future maintenance, the SLCA re-presents its desire to enter into a Memorandum of Understanding (MOU) between the SLCA and SLRD to better coordinate trail work projects and climbing management issues as those issues arise.

Conclusion:

Again, the SLCA & AF wishes to express its gratitude for being able to comment in this NEPA process.  If there are any questions in regards to comments raised in this letter, please do not hesitate to contact the SLCA at Julia@saltlakeclimbers.org 415.695.4502. Lastly, the SLCA & AF again offer whatever help the SLRD may need during the NEPA process to better understand how climbers currently use or would likely use the Project Area under the various Alternatives discussed in the NOPA.

Kindest Regards,

Julia Geisler

Executive Director

Salt Lake Climbers Alliance

and

Jason Keith

Senior Policy Adviser

The Access Fund


[1] See Climate Change Considerations In Project Level NEPA Analysis (Forest Service, January 13, 2009) available at http://www.fs.fed.us/emc/nepa/climate_change/includes/cc_nepa_guidance.pdf (last visited on Aug. 28, 2013).

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