When to Let a Road Go

While I agree with much of what you stated above Andrew, I still support re-opening the Dosewallips Road. While I welcome the decommissioning and transitioning to trails on hundreds of miles of logging trunk road marring our public lands, I don't favor decommisioning major access roads to our national parks and forests. Along with balancing environmental protection, we need to have ample and adequate access to our public lands for recreation. And while I support virtually no new roads into our parks and forests, I believe we can't allow major roads to simply vanish. I fully support reopening the Dosewallips, Suiattle, and White Chuck Roads. We can rebuilt them in environmentally sound fashions. Its a matter of funding. What really bothers me about the arguement to not open the Dose road is the constant alarm about the road endangering salmon. I believe that much of this talk about salmon endangerment is nothing more than a red herring (pun intended) by many elitist hikers who really just want to limit access. If we really are that concerned about protecting salmon habitat in Puget Sound as these opponents constantly contend, then we can do a lot better than stopping a road. How about decommissioning all the second homes along Hood Canal (many no doubt owned by hikers)? Getting rid of all that wall-to-wall development along this waterway will certainly enhance the salmon population more than a small section of park road. How about stopping (or at least limiting)the incessant urban sprawl spewing out of Seattle? The impact on salmon from reopening the Dose road is minimal compared to the housing tracts and development sprouting all over the sound. Really, in the big scheme of the sound, re-opening the Dose road will have a minute impact on the greater Puget Sound ecosystem. I believe strongly in allowing Americans to enjoy thier parks. And how does this effect me? I bike the road and still day hike the trails in the Dose. But I know that is not an option for most people. We are limiting their exposure to wild America and in turn missing out on opportunities to green bond them. If we really want to protect the region, get more people out on the trails, then we have to have more trails for them to get out on and have access roads for them to get to those trails. Hopefully then, these new converts will rally for more protected lands and better funding, which in turn will do a heck of a lot more to protect salmon and other wild critters.

In regards to my comment above about getting rid of second homes on Hood Canal,by no means am I advocating that. I'm just making a point. I do however would like to see more land protected on Hood Canal, particularly on the Kitsap Peninsula before it is all turned into a second home tract. Undeveloped shoreline does wonders for salmon recovery!

Thank you for providing a brief summary of WTA's decision-making process in this case. Has WTA considered the Mountaineers' process? They are (1):
1) waiting for the draft Environmental Impact Statement, so they'll have the facts, and
2) soliciting the input of their members (and WTA does call itself "membership driven"), BEFORE
3) taking a position.

Otherwise, WTA risks taking a position which is unsupported by the facts, and which is not supported by the majority of its active volunteers in the Olympics. Both are indeed the case here.

Your posting is very confused about the question of salmon impact. First, you note that in the NMFS objected to placing the road back into the new river channel, and that ONF has officially dropped this proposal, so that objection is now irrelevant.

Then you hypothesize that "decommissioning the upper road can be part of a larger effort to restore salmon habitat all along the river." What is your basis for this hypothesis? The NMFS has adopted as official Federal policy the Chinook recovery plan formulated by the Shared Strategy for Puget Sound (2). It is based in part on a detailed salmon habitat study of the Dosewallips conducted by the USGS, WDFW and Port Gamble S'Klallam (3,4). This study provides no support for your hypothesis, and considerable information which refutes it. I sent this information to you months ago, and would be glad to summarize it again (5), and we can expect this will be covered in the DEIS. In short: there IS a larger effort to restore salmon habitat, and decommissioning this road has no part in it. You have not done your homework.

Finally, how do you propose to get the equipment in to decommission the upper Dose Road without first reopening it, anyway? There are dozens of culverts and two bridges that would have to be removed. Most of the roadbed is insloped to ditches that drain through culverts, and should be outsloped to become a stable trailbed that sheds rain rather than collecting it. How do you propose to accomplish this, and what source of funding is available? It makes no sense to advocate a solution with no means, either physical or fiscal, of accomplishing it.

WTA should take no position on political issues, which are based not on facts but on philosophical positions or beliefs sincerely held by any of its members, and which need not and may never be reconciled. The Dose Road is such an issue. It is needlessly divisive and damages WTA. WTA should take no position on it.

For the good of WTA, Andrew, your title should be revised to "When to let a position go".

(1) http://www.mountaineers.org/main/pubarchive/Mtr8-07.pdf
(2) http://www.nwr.noaa.gov/[…]/PS-Chinook-Plan.cfm
(3) http://wa.water.usgs.gov/[…]/PE_RS_highlight.pdf
(4) http://www.pgst.nsn.us/[…]/Dose-Habitat-Assmt-12-6-05.pdf
(5) http://www.nwhikers.net/forums/viewtopic.php?p=321485

A few brief replies:

WTA's current position on the Dose is based on the Forest Service's most current proposals and information. WTA will closely review the new draft EIS and any other documents as they come to light.

Ever since the 2002 washout, WTA has listened to its members, published many articles and letters to the editor both for and against rebuilding the road. Our position has been carefully considered, and member input has always played a crucial role in shaping our positions. And forums such as these continue WTA's commitment to soliciting and engaging its members on this and other roads issues.
 

"Most current proposals and information"???

WTA's position is based solely on taking two words out of context from the August, 2005 NMFS letter. The context, reiterated SIX times in its two pages, is concern about placing road material "INTO THE RIVER". But in May, 2007, Olympic National Forest officially announced in the Federal Register "a low-water crossing has been DROPPED from further consideration. Instead, the ONF and WFLHD proposed to reestablish road access previously provided by FSR 2610 to ONF and Olympic National Park (ONP) recreational facilities by rerouting the road above its former location along the hill-slope above and to the north of the washout" (1).

Further, in January, 2007, the NMFS has adopted the Chinook Recovery Plan (2) as official Federal policy. This plan is based on findings that most chinook spawn primarily in the lower 6.7 river miles (3) and that no spawning pools are found near or above the washout because "higher stream gradients and narrow floodplain areas limit the development of critical salmon habitat features" (4). The recovery plan therefore presents a detailed, prioritized list of actions for restoring habitat where salmon are PRESENT: in the lower river, estuary and Hood Canal shoreline, not where they are ABSENT (on a hillside far above the upper river!). This plan, by complete omission, effectively dismisses what the 2005 letter itself said was only a "preliminary analysis".

If WTA's position were actually based on the "most current proposal", it would have been dropped 8 months ago. If WTA's position were actually based on the "most current information", it would have been dropped a year ago.

The Dosewallips Road has proven more controversial and engendered more letters to "Washington Trails" than any other recent issue. Andrew, may I humbly suggest that your position ought to include the responsibility to ask yourself "What would Greg Ball do?" He rescued WTA from the brink of oblivion by providing it with a new, unifying mission. Please do not compromise that mission by dragging divisive political issues into WTA. In WTA, it has been my privilege to work alongside retired professors and retired loggers; alongside an employee of a nonprofit from Seattle and a Weyerhauser manager from Hoquiam. We may be Democrats or Republicans; we may be members of Friends of Olympic National Park or of Olympic Park Associates (which disagree on this and every other issue). It is quite irrelevant when we're all making sawdust together.

Please strengthen Greg Ball's legacy by living up to his example: drop the politics, and pick up a pulaski.

(1) http://www.epa.gov/[…]/i2333.htm
(2) http://www.nwr.noaa.gov/[…]/PS-Chinook-Plan.cfm
(3) http://wdfw.wa.gov/[…]/1236.pdf
(4) page 64 of http://www.pgst.nsn.us/[…]/Dose-Habitat-Assmt-12-6-05.pdf

Rod,
I don't think there's anything "humble" in you invoking my dead coworker to further your incessant campaign to add five miles to the Dose Road. What would Greg do? I tell you what he'd do...he'd give WTA staff the benefit of the doubt and trust that they were making decisions with care and intellectual honesty. That's something you are apparently unwilling to do.
WTA has always been involved in politics, Rod. And it will continue to do so. That's how folks like Ira Spring protected so much land in this state so people like you could go hiking. If WTA weren't involved in politics, well...we wouldn't have protected places like the Alpine Lakes, halted rampant ORV use in the high country, or found federal funds for trail maintenance so you can lift your Pulaski on the weekends.

Andrew, I sincerely apologize if I have offended you.

I stand in great admiration of Greg Ball, as all WTA members should. We all have a WTA to care about solely because of him. I hope that, at some point, you might come to thoughtfully consider the question I posed.

My concern about the Dose Road arises solely within WTA. Other members raise it on most Olympics work parties. There is obviously a disconnect between WTA's position and that of most active volunteers here, and bewilderment among members about its basis.

I am confused by your reference to Ira Spring. As I assume you must know, he strongly favored reopening the Dose Road.
http://brinnonprosperity.org/[…]/ira_spring_letter_dose-repair.gif
If that was your point, yes, there are sincere conservationists, just as there are active WTA volunteers, on both sides of this issue. Realizing this, I would hope WTA might seek to build consensus by addressing members' questions about its position. Is that unreasonable?

I do question, from my own observations, whether any position on this divisive issue is good for WTA. Is that itself not an important question to ask?

I do not, and have never, advocated that WTA support reopening the Dose Road. My concern for WTA far outweighs my interest in this road, and do I hope we agree on that. (WTA's position primarily affects WTA - it will have little effect outside of WTA, unless WTA intends to take part in legal proceedings against the Forest Service, which I pray is not your intention.)

Again, please allow me to apologize.

Like Andrew, I found Rod’s reference to Greg completely inappropriate and offensive. That said, I want to address a contention that Rod has raised that is factually inaccurate.

Rod contends that WTA did not consult with our members on the Dosewallips River Road Washout. That’s just not true. The Dose washed out in January of 2002. We initially supported reopening the Dose, but after very careful consideration decided to oppose reopening the road. That decision was made in September of 2005. The months prior were spent consulting with members on the Peninsula, including crew leaders and volunteers to whom we reached out and individual members who contacted us. Rod started volunteering and became a member nearly a year after we reached our decision, so he may be unaware of the extent of our member consultation on this issue.

Jonathan Guzzo

May I reiterate my apology to you as well, Jonathan?

The question is then: what happened in that year? Did the position of most volunteers change? You, in the office, have the tools to easily do a "reality check". Simply create a poll webpage, script a list of all the volunteers on Olympics work parties for 2007, and mail a request that they each register their individual opinion on the poll. For an objective result, the question would be posed neutrally "What is your personal position: Reopen Dose Road or Convert to Trail?" (not "do you support WTA" or "do you support WTA's position").

I shall embrace the results of this poll. If the majority support your position, I shall never question WTA's position again, period. (However, I expect its going to be more than 2:1... and may surprise you. That's precisely why it's worth doing this poll.)

I am not suggesting that WTA policy be driven solely by vote of its membership. However, WTA is a "membership driven" organization, so polls should be considered. It is now so easy to do on the web!

Polls could be very useful to WTA's Board and staff in determining areas where education and consensus-building are needed. I believe this is one such issue, and very much hope you will participate.

It's good to see that Andrew has recognized that there are legitimate competing values at stake here to be weighed against each other, and that they have to be wrestled with. He recognizes also that the Dose is not unique, but is part of a wider and bigger problem, and that not all failed trailhead roads can or should be reopened. It is always good to see people get beyond the anger-and-denial phase, which commenters Rod Farlee and, to a lesser extent Mr Romano are mired in.

One of the important drivers of the wider problem, not mentioned by Andrew, is money, or more precisely the lack of it. There is no likely or probable future in which there is enough money for the Forest Service to repair and indefinitely maintain appropriately its existing large road network. And the shortfall is not small. As things stand now, the problem worsens year by year. Just as with leaky roofs on houses, an undermaintained road is more likely to sustain cascading damage from water than a well-maintained one. One can of course, deny or dismiss this conditioning fiscal environment with a statement like "We can rebuild them in environmentally sound fashions. Its a matter of funding." But that actually doesn't make the problem go away.

It is also undeniable, at the wider level, that the existing National Forest road network is harmful to aquatic habitat values. Although all roads are aquatically harmful, there is at the individual road level a clear hierarchy of harm, from roads that are relatively benign, to roads that pose unacceptable risks and unacceptable levels of harm. Speaking generally, worse-maintained roads are more harmful than better maintained roads; steep sidehill roads, particularly those with many water crossings, are more harmful than roads on flatter terrain, and roads which closely parallel rivers and streamcourses are more harmful than those which maintain a respectful distance. Although it is possible to reduce much of the risk and chronic damage which roads give rise to by use of specific construction, engineering, and maintenance practices, most national forest roads do not reflect these standards. They were constructed too long ago, and there is insufficient money to upgrade them, or to maintain them.
 
These are some of the conditioning factors which have led to a consensus among state and federal agencies, and knowledgeable people generally, that the functioning national forest road system needs to shrink, preferably by means of intentional removal rather than simply by means of neglect, and that the remainder needs to be aquatically upgraded and subsequently better maintained.
 
There are, of course, a lot of roads-to-nowhere on the national forest road system, and few recreational users are going to complain much about getting rid of those. But it's unrealistic to suppose that roads to trailheads are not going to be affected as well, particularly if one recognizes that some trailhead roads are real stinkers from the perspective of maintenance costs, aquatic risks and failure vulnerability.

Is the Dose road one of those real stinkers? Any river-level repair would certainly belong in the aquatic stinker category. The alternative would be to re-route the road away from the river for an entire mile, going up and down a steep escarpment, cutting a swath through old forest. That may be aquatically preferable, although there are certainly issues about road stability on the steep escarpment section. But from my perspective it's a stinker of another sort. We do not need to be building new roads through our remaining old forests. The road beyond the washout, and beyond any re-route, I'd probably put in the aquatically middling bad, rather than the stinker category. It's a parallel road. The river would certainly be better off without it. But much of the road traverses slopes of only moderate steepness a good ways from the river. Some of the worst portions of the upper road are actually in the national park.

My personal calculus on this issue--I oppose rebuilding-- is certainly influenced by the fact that I like the lower valley. I like the mellow walk up the old road, and I enjoy watching nature encroach on in, year by year. Given the rapid rate at which we are paving over and carving up the living skin of our planet, it's nice to see just a little bit of it recaptured by natural forces. Does that make me a selfish elitist? Are those who want to build a mile of new road irrespective of environmental and monetary cost, so that they can drive a bit more and start their hikes a bit farther upriver some sort of noble china-reconstructs peasantry? I don't see the logic, frankly. Nor do I see the logic that "green bonding" can only occur at the former, rather than the current trailhead. I think that many people who participate in this and similar debates, are prisoners of status quo thinking. Mr Romano, for example, does not want to see any new roads, but wants all existing trailheads maintained. Why? A very large proportion of existing trailheads are essentially accidental. The former Dose trailhead, for example, is just where the money ran out when they were trying to build a cross-Olympic tourist road which would have gone all the way up the W Fork Dose, over Anderson pass, and out the S Fk Quinalt. Such a road, had it been built, would undoubtedly be very popular and open up lots of day-hiking opportunities. What is his argument against building that road? Had it been built, Mr Romano would undoubtedly regard it as a sacred resource, to be maintained open at all costs, but since it has not been built, he opposes its construction; he might even be horrified by the idea. This is logically inconsistent. And doomed to failure. The world is changing. It will not be as it was, and adaptation, rather than opposing all change, is a more successful strategy.

Getting back to the issue of financial and environmental costs of trailhead roads, I think it behooves the hiker community in general, and the WTA in particular, to scrutinize current trailheads for such issuess, and such vulnerabilities and to start thinking about ways in which the trail system can and should adapt to a smaller, more aquatically and financially defensible road system. Don't just get blindsided by the next winter storm, and plead plaintively to get your roads back. Be proactive. Want an example? The Three Fingers trailhead is reached by nearly twenty miles of travel on a decrepit dirt road, which has repeatedly failed, and which remains acutely vulnerable to new failures. The Canyon Creek basin, which this road traverses, has been severely degraded by landslides originating on roads. Could lower portions of this trail be re-routed to reduce the length of needed road, and hence the vulnerabilities? There are many other such examples.

First of all Mr Geraghty thanks for your "analysis" on my thinking. I don't believe there is any "anger and denial" on my end. Perhaps the anger and denial comes from organizations like yours, the Olympic Forest Coalition, which seems to have a hard time understanding that not everyone agrees with all of thier positions. Ironically, I believe with many of your group's stands but according to you I'm "a prisoner of status quo thinking" if I don't agree with you on this one issue. So much for logical consistency as you would point out.Let me reiterate my stand-I am very concerned with the accelerated loss of our trail network. Losing major access roads to our trails only exarcerbates this loss. The Dosewallips Road is sort of a line in the sand for me and I believe for many others too. How many more trails and access to trails are we going to lose? I am all for decommissioning 95% of the trunk logging roads on our forests. I am 100% for more wilderness areas-100% for better park and forest funding- 100% for restoring the south flank of the Olympic National Forest- 100% for increasing the size of the Olympic National Park-my track record as a conservationist, educator and writer speak for these commitments. But I'm afraid Mr Geraghty we won't see eye-to-eye on this one issue. So, please spare me the personal attacks and lets debate the issue. I welcome this dialogue and this forum and am not afraid to take a stand, be passionate about it and listen to other's pointsof view.

Kevin, thank you for your thoughtful comments. The question of road vs trail costs can be broken down into two areas: the one-time cost of trail conversion, and the recurring cost of annual maintenance. Could we try to flesh this out?

Annual maintenance costs: road vs. trail.
Olympic National Park's trail maintenance budget was $522,923 in 2001 (1) (not counting SCA, VIP, BCH and many other volunteers) divided by ~450 miles which are actually maintained each year (of their 611 mile trail network), giving us a ballpark figure of ~$1200 per trail-mile per year.
Annual maintenance costs of an unpaved, unplowed, seasonal-use only, single lane gravel road (e.g. the Dose Road) appear to vary over a broad range centered around that same amount. Trails are far more labor-intensive (as any WTA member can attest!). Seasonal trail crew pay is ~$15/hr plus benefits (and they more than earn it!), trail crew supervisor is double that, plus provisions, stock, stock handlers, trailers, trucks, equipment, travel time, per diems, etc.(2)
Is a trail cheaper to maintain? It is not clear that is actually the case. I hope others here might contribute firmer numbers.

Trail conversion costs.
In 2003, the Western Federal Lands Highway Division estimated the costs of upper Dose Road trail conversion at $485,000, or $170,000 more than re-opening the road (3). (Both numbers have doubtless escalated considerably since then.)
The Federal Highway Administration has agreed to pay 100% of the costs to reopen the Dose Road (from our gasoline taxes in the Highway Trust Fund) (4). So this does not compete with Forest or Park Service road budgets. But where would the money come from to convert the upper Dose Road to trail?

If you have better numbers, or further insight into available Federal budget resources for trail conversion, please do share it with us here. Thank you again.

I completely share your broader concern on road budgets, which you've expressed eloquently in this forum and elsewhere several times in the past. Bravo, sir. (May I mention our (WTA's) identical, deep concern for trail budgets?) Your analytical skills are evident, so I'm sure you keenly appreciate why answers to these, and the other questions in postings above, might do much to sway many WTA members. And why the lack of answers is so troubling...

You are admirably eloquent, but where is the concrete plan of action on the proposed trail conversion? Can it be done, fiscally and physically? If you're serious, let's get specific.

(1) http://www.nps.gov/archive/olym/busplan/bp3c.htm
(2) L. Gunther, ONP, pers. comm. 9/12/07.
(3) http://www.americanwhitewater.org/archive/article/488/
(4) http://www.wfl.fhwa.dot.gov/about/

Boosters for reconstruction of the Dose road are at least implicitly endorsing the simultaneous loss of several dozen trees dating from the peninsula-wide 1701 fire, contiguous to the Buckhorn Wilderness. There's no getting around this fact. If one's moral compass fails to yield an appalled reaction to this proposal, then by all means continue to revel in that heightened self-interest. A hiker who would willfully degrade wild nature in favor of motorized travel is a strange beast.

Then please join me in trying to specify a concrete alternative.

1) How can the upper Dose Road be decommissioned and converted to trail without first reopening it to get equipment in?
You have previously endorsed the conclusion that it cannot be abandoned in place (indeed, it turns out doing so would be in violation of an agreement between Olympic National Park and the WA State Dept. of Natural Resources, and in violation of several State and Federal laws).
The culverts must be removed, drainages remediated, etc., etc.

2) Please provide an alternative to cutting any trees which is both legal and physically possible.

3) What is the funding source (see thread above)?

The sermon is indeed inspiring, but please, what actions do you propose?

Regarding funding for road decommissioning, ERFO money, (the Dept of Transportation fund which would pay for the repair) can be used for decommissioning, as well as repair, of flood-damaged roads.

Forest Service people habitually quote figures like $10,000-$20,000 per mile for National Forest road decommissioning. Roads with many or particularly deep culverts (not the case with the Dose) are generally more expensive to decommission. Rod Farlee quotes a DoT figure of nearly $500,000 for decommissioning. That is between five and ten times as great as what one would expect based on these general per-mile figures. Without knowing more about how they arrived at this figure, or what work it includes, I can only say that it doesn't seem consistent with road decommissioning costs generally. Insofar as trail conversion might impose extra costs above and beyond simple decommissioning(constructing footbridges bridges across former culverted streams, for example), I imagine such a project would compete well with other trail projects for outs.

Regarding moving equipment past the washout, the obvious choices are helicopter, or using the riverbed at summer low flows. The appropriate choice would be a matter for study, but it is clear there are options. This is not a new problem, and has been confronted before. Consider, for example, the NPS's recent decision to decommission the upper Stehekin road, above significant washouts. My guess is they will be using helicopters in that instance. They will certainly not be constructing a new temporary bypass road to move equipment.

Would trail maintenance cost as much per mile as road maintenance? Not clear. Rod Farlee is conjecturing based on National Park, not National Forest expenditures. We know the Park Service can bring a lot more resources to bear per mile on both its roads and its trails, than the Forest Service, and most of this would be a FS trail. What I *do* know is that if the FS neglected this trail after it were built, it would with high probability remain usable--it is an old road grade, after all, and if water crossings were dealt with beforehand, it is a very durable surface, with gentle grades--, and the failure mode would be aquatically benign, whereas road failure would not be. A neglected trail is, aquatically speaking, a very minimal problem compared to a neglected road.
 

I must leave on family business for a few days, and will reply at length when I return. Meanwhile, brief comments:

1) ERFO? Please read about prohibited "Betterments" (e.g. moving a road up out of floodplain). It's not listed as ERFO. Isn't this an FH project?

2) Decommissioning costs? To get the equipment in must require first reopening the road (and cutting trees in the process), then decommissioning the whole thing. The net cost of decommissioning is $170,000 divided by 6 miles (including the reroute) = $28,000/mile. Not at all unreasonable.

3) Helicopter? Bulldozers up the riverbed? Egad. I'll try to describe what should be apparent to any serious student of this question what scope of work would be involved in decommissioning when I return. Key topics to consider: culverts, bridges, insloped roadbed, slide east of gabions above Dose Falls, Dose RS & residence & shop, Dose CG shower building, propane tank, etc. Have you thought this through?

4) Trail maintenance costs. This was in response to your broader concern about road maintenance budgets. That, and your goal of converting the road to trail, means we should consider those economics, too. Your view of the Park trail maintenance budgets as relatively lavish, or even adequate, is quite opposite the harsh reality! I'll provide an overview when I return. The larger question, whether road to trail conversion saves money, is dubious, and must be examined on a specific case-by-case basis. In the Dose Road case, it appears to fail.

Kevin writes "Without knowing more about how they arrived at this figure, or what work it includes..." Clear communication can seem blunt, so please accept my apology in advance if this offends you, but has OFCO done any homework on this for the past 4 years? One is left wondering what just what alternative OFCO has been studying for the past 4 years they have opposed this project. None? What's your goal? What do you actually want to see done? Haven't you tried to answer this question before now??? Apologies, but I remain baffled.

WTA opposes reopening the Dosewallips Road, favoring decommissioning. This posting attempts to list what work would be involved, what equipment it requires, and how it might be gotten in and out. The only practical alternative identified is to reopen the road to decommission it. Decommissioning thus makes no sense.

There is no "no action" alternative for the upper Dose Road. It cannot simply be abandoned. Already, one culvert has failed, and a stream is seasonally running across the road, and if not maintained, will ultimately wash it out. If the dozens of other culverts are not removed, this will happen at many more locations along the upper Dose Road. The road must be either reopened for use, or decommissioned properly as a stable trailbed.

The actions involved in Forest road decommissioning (with or without trail conversion) are listed in Forest Service regulations (1) and management rules (2), required to comply with a variety of Federal environmental laws. In 2003, the Western Federal Lands Highway Division prepared a scoping estimate (3) of the costs involved (although the costs cited will have increased substantially since). Let's review the steps involved in this decommissioning, starting at the top of the road.

What of the Olympic National Park buildings at the end of the road? The Dosewallips Campground shower and restroom building, the Dosewallips Ranger Station, residence and shop, a 1000 gallon propane tank to provide heat and hot water for these facilities, etc.? Are they to be abandoned, becoming decaying ruins which will be an eyesore alongside the trail for the next century? In ONF's original trail conversion alternative, they would be demolished and the debris removed at an estimated cost of $31,500. This requires that an excavator and a series of dump trucks be brought up to the site. That in turn requires that the Dose Falls section of the road be repaired, as described next.

At Dose Falls, the 2002 flood moved boulders that had held several large deadfall which had retained a filled gravel bank supporting the roadbed just beyond the east end of the gabions. (The gabions did NOT fail, as claimed by OFCO (4), as anyone can go see for themselves. They've not moved an inch.) The edge of the road is sliding into Dose Falls. This section is about 50 feet above the falls and is about 100 feet long. It is still passable for cars, but is now too narrow for heavy equipment needed for the work described above. The WFLHD plans to extend the gabions east, as part of the project to reopen the road. This would have to be done to decommission the above Park facilities, as well.

There are two bridges, over Constance and Bull Run Creeks. Each has four steel I-beam stringers between concrete abutments, and is decked with two rows of pressure-treated 4x12" planks. Pressure treated planks are impregnated with chromium, copper and arsenic. They are stable for many years, but eventually, will decay and these heavy metals would end up in the Dosewallips. The only legal means of disposing of pressure-treated wood at the end of its lifetime is in a licensed landfill. This has to be removed as part of the road decommissioning, as there's no practical means to get them out afterwards. And does OFCO propose to leave the rusting steel beams and concrete abutments as a scenic trailide attraction? The bridges should be removed when the road is decommissioned.

The 4 miles of road from Dose Falls to Elkhorn Campground is on steep hillside, high above the river. The roadbed is insloped to ditches, which drain across the road through culverts. Culvert removal requires an excavator and will produce several dump truck loads of crushed culverts. To become a stable trailbed, the roadbed should be outsloped to shed, rather than collect, water. Resloping requires a bulldozer.

The total estimate for all the above road decommissioning work on 5.2 miles of FS2610 was $260,000.

Next is the big question of the FS2610-040 spur road and concrete bridge at Elkhorn Campground. If the road is decommissioned, it will be permanently inaccessible, cannot be maintained, and will eventually fail, with unacceptable consequences for aquatic habitat. WFLHD estimated the cost of removal of this bridge at only $50,000, but this would require very heavy equipment and its demolition would produce dozens of dump truck loads of concrete debris to be removed. Removal of the -040 spur road was estimated to cost $30,000.

Finally, construction of a one acre trailhead parking lot and installation of vault toilets were estimated at $60,000 and $25,000, respectively. Total decommissioning costs were $482,330, or $170,000 more than simply reopening the road.

In summary, a large tracked excavator, bulldozer and dump trucks must be moved to the site above the washout. Many truckloads of fuel and supplies will need to be brought in. Workers will need to be able to commute into the work site. Dozens of dump truck loads of debris must be brought out.

How can this be done without first reopening the road? Kevin Geraghty of Olympic Forest Coalition says above "Regarding moving equipment past the washout, the obvious choices are helicopter, or using the riverbed at summer low flows." Let's examine these in turn.


Helicopter?
The scope of the above decommissioning work requires equipment which is likely too heavy to be transported by medium-lift helicopters (5), without disassembling it and reassembling it on site, and then reversing the process when the work is completed. That would be extremely expensive. A heavy-lift Chinook (6) might be required.

The use of heavy lift helicopters within forest is highly dangerous to spotting crews. Downwash in excess of 100 mph can easily topple trees. This is particularly true of shallow-rooted, fast growing alder and poplar which exist in the vicinity of the washout. It is likely that landing areas of an acre or so will have to be clearcut both above and below the washout to provide for worker safety. These areas are riparian reserve, where clearcutting is prohibited.

In addition, empty gabions and perhaps rock fill need to be brought in to repair the Dose Falls roadbed section, demolition debris from the campground shower building, ranger station, residence and shop airlifted out, and debris from bridge and culvert removal airlifted out. Finally, hundreds of tons of debris from the demolition of FS2610-040 concrete bridge would presumably be airlifted out, as well?!

Marbled murrelet and spotted owl nesting seasons exclude helicopter flights during the period April 1 through Sept. 30 (7). Bald eagle nesting excludes flights between Nov. 15 and March 15 (8,9).
Practicality aside, how could this work possibly be accomplished within the narrow time windows available in early spring and fall?

This proposal appears to be completely impractical and would be unimaginably expensive.


"Using the river bed?"
The Dosewallips River occupies a new bend, hard up against the base of the road washout. At low summer flow, dry river bed is available on the SOUTH shore, opposite the washout. If the proposal is to utilize it, the river must be crossed twice. This section of river is home to steelhead (ESA listed as endangered), reportedly contained a Chinook salmon redd (also ESA listed as endangered), and contains healthy populations of coho and cutthroat.

In past years, a narrow footpath along the base of the washout did become usable in late summer. This is no longer the case; it has been washed away. In September only, one can make it, albeit by hopping from rock to rock in places. If the proposal is to widen a path along the north shore at the base of the washout sufficiently for heavy equipment, all of the objections to the abandoned "low water crossing proposal" apply.

In either case, isn't driving heavy equipment a hundred times or more up and down a riverbed a blatant violation of the Aquatic Conservation Strategy of the Northwest Forest Plan? This proposal would require consideration through a full NEPA process (EA and/or EIS), would likely be opposed by the state and tribes, and by any responsible environmental group.


Re-opening the road.
This appears to be the only practical and legal means of decommissioning the upper Dose Road. But if it is reopened, it makes no sense to decommission the road and demolish the Ranger Station and campground to which it leads, irreplacable National Park assets worth over a million dollars.

Conclusion.
OFCO has proposed "trail conversion" for 4 years, but apparently has never paused to ask themselves "how"? The Forest Service's proposal to reopen the Dose Road across the hillside north of and above the washout appears to be the most practical and least environmentally intrusive alternative, certainly compared to OFCO's trail conversion proposals above.

Acknowledgement.
Several other WTA volunteers have reviewed this thread and contributed comments. All agree that there are many unanswered questions about WTA's advocacy position for trail conversion which WTA's Advocacy Director, Jonathan Guzzo, has failed to address.

(1) National Forest System Road Management rule, 36 CFR 212.5(b)(2).
(2) Forest Service Manual, Road System, Title 7712.01(b)(2).
(3) Available from Timothy E. Davis, Olympic National Forest, 1835 Black Lake Blvd. SW, Olympia, WA 98512-5623.
(4) Photo 9 in http://www.olympicforest.org/gallery-3.htm
(5) Erickson S-64 Air-Crane, maximum hook weight 11,000 lbs. http://www.ericksonaircrane.com/Index.asp
(6) Boeing 234 Chinook, maximum hook weight 26,000 lbs. http://www.colheli.com/media/specification234.pdf
(7) section 3.4 of http://www.nps.gov/archive/olym/ea/shelter_repair/sec3.htm
(8) page 13 of http://wdfw.wa.gov/hab/phs/vol4/baldeagle.pdf
(9) http://apps.leg.wa.gov/WAC/default.aspx?cite=232-12-292