These are the comments we submitted to the US Forest Service Flagstaff Ranger District today regarding the FBO’s Comment Letter for the Mount Elden Dry Lake Hills Recreation Planning (MEDL) Proposed Action.

PDF Document is here.

November 27, 2014

Dear Brian-

Thank you for the opportunity to comment on the Mount Elden/Dry Lake Hills Recreation Planning Proposed Action, (MEDL).


Flagstaff Biking Organization (FBO) is a group of cyclists who came together to “promote bicycling as a safe and attractive means of transportation and recreation in Northern Arizona.” Our initial project was to put on a Bike to Work Week for our community in May 2002. Building on the success we started to expand our efforts to keep people informed of cycling related issues and galvanize support for better and safer facilities, trails, and trail access. We have a successful and ongoing 10+ year relationship with the Coconino National Forest, Coconino County and the City of Flagstaff, including a Memorandum of Understanding to work cooperatively to provide for non-motorized trails opportunities in the Flagstaff area. Please see for more information on our organization.

We strongly support the purpose and need for this Proposed Action, (PA), “to respond to resource impacts from increasing and changing demands for trail use and other non-motorized dispersed recreation on National Forest System lands, to provide managed parking and trails that are sustainable, and to improve the safety of visitors within MEDL area.” We appreciate that we were involved in the preliminary scoping and that much of our early input was incorporated into the PA.

The best management strategies are those that address the needs of the recreating public in a manner that is both environmentally and socially sustainable. In fact environmental sustainability cannot be achieved in recreation management without social sustainability.  In order to achieve social sustainability, it is important to recognize the quantitative and qualitative needs of the various user groups. It is relatively easy to measure quantitative needs, as surveys can readily assess how many people participated in a given activity within a time frame. Qualitative needs are far more difficult to measure and address but potentially more important. Please recognize that this project’s success is extremely dependent upon the details inherent in recognizing and providing for an exceptionally diverse array of recreational needs, and that the details of those needs are difficult to express.

It is important to recognize the substantial number of user-created and historic trails and routes that are part of the existing condition, and what these trails represent. (Most of these routes are shown in the maps accompanying the PA.) We understand that the any action the District takes will result in a net reduction in route mileage. We want to be sure that the District recognizes that this is a quantitative net loss in recreational opportunities as well as a substantial and quantitative reduction in environmental impact. Our hope is that this loss in quantity will be accompanied by a substantial qualitative improvement that will encourage users to eschew using and constructing unauthorized routes, leading to continued minimization of environmental impact as a result of the implementation of this planning.

Please carefully consider our input on the specifics of the MEDL Recreation PA. We have formally and informally surveyed hundreds of cyclists and attempted to distill this into concepts that will address this diverse user group’s needs while addressing more universal concerns such as user conflicts, erosion, wildlife and sustainability.

Comments on the components of the Proposed Action

New Trail Construction

We strongly support the District citing the use of the Forest Service Trails Handbook Best Management Practices. We also strongly recommend that District seek the input of professionals such as IMBA Trail Solutions and Gravity Logic and trail users especially when implementing some of the more technically challenging downhill and all-mountain style trails. Consulting with professionals particularly on more specific aspects such as trail flow and the incorporation of challenging features will assure that these trails best address the qualitative needs of these riders.

Where the District is choosing to convert road to single-track trail, in particular in coordination with the Flagstaff Watershed Protection Project, (FWPP), please bear in mind the fact that only closing one side of a two-track does not yield “single-track” trail. Better management strategies incorporate deviating trail tread from the road within corridor, moving large objects such as boulders into the obliterated roadbed, ripping and re-seeding. Please coordinate with the road construction personnel in advance of the construction of new roads as part of the FWPP to implement strategies that will lead to the best trails as part of the MEDL implementation later. For example, if imported materials are to be used in the roadbed, consider using the City of Flagstaff’s “FUTS Mix” rather than other looser gravels where the road will be converted to Flagstaff Loop Trail class 4 trail.

We would like to be closely involved in the specific corridor layouts of most of these new trails.

Equestrian Trail System

We support the need for this system. It is our understanding from conversations with our friends in the horseback riding community that opportunities for riding that minimize interaction with cyclists are better than riding on trails with lots of cyclists. Although we do not support this system being closed to bicycles, we feel that the location of these trails will organically lend itself to low levels of bicycle use. Its proximity to the Elden Springs Horse Camp and away from the multi-use Flagstaff Urban Trail System and other multi-use trailheads is ideal for these users. We also see this trail system as directly beneficial to cyclists seeking more remote opportunities for exploration of the mountain. (This does not imply that these trails would attract a substantial number of cyclists in any way, as this is a relatively small number of riders.)

Downhill Mountain Biking

These trails are long over due! We first approached the District nearly a decade ago with a proposal to adopt these trails onto the Forest Service system. This a growing aspect of mountain biking and it appeals to young riders. As we have commented in the past, implementation of these trails directly assists the Forest Service in its More Kids in the Woods program, and perhaps some of the funding for the implementation of these trails could come from this program.

There is strong demand for this opportunity amongst adults and a tightly knit community of trail users ready to help construct and maintain these trails. We strongly recommend that the District rely upon these riders, as well as the professionals we mentioned above, when laying out, constructing and building these routes. The riders involved in this aspect of the sport are extremely preferential to the types of features and flow of the trails.

Providing ample opportunities for this use that are separate from the rest of the multi-use system will greatly alleviate user conflict concerns as these riders will be able to ride nearer their limits without potentially startling or colliding with other users.

Please consider adding some additional routes within the general area proposed for downhill mountain bike trails. Additionally, and/or alternately, consider using wider corridors that would allow for multiple options along these trails. This approach could provide for multiple experiences with minimal impact, as well as provide options for various skill levels.

Trail on south face of Mt. Elden

This is a great opportunity to help disperse hiking use onto an additional route and provide for a long day-hike option when combined with Elden Lookout Trail. Although we support this as a trail with a Designed Use for hiking, we do not think bicycles should be prohibited from using it, although perhaps bicycles should not be included as a Managed Use. Our observation is that the face of Elden is such that constraints in trail design alone would prevent most people from taking their bicycles on this trail, but should someone want to “hike-a-bike” and ride some of it, this should be allowed.

West Elden Climbing Access Trail

Well-managed recreation has fewer impacts to environmental resources. We support this.

Scenic Loop Trail

Although we fully support this as Designed Use for hiking, we think that mountain biking should be recognized as a Managed Use on this trail. The location of this trail and the “scenic” aspect of it would make for great exploration opportunities using the new alignment, as proposed, for Upper Oldham Trail and Sunset Trail. Additionally, part of this Loop would provide access to the downhill mountain bike trails. We recommend prominent signage advising riders that mountain bikes should yield to hikers and equestrians along the parts of the Scenic Loop Trail that would be used for access to the Downhill Mountain Bike Trails.

Dry Lake Hills Trail System

We strongly support this, as these loops were part of our proposal submitted during preliminary scoping. However our vision included additional routes that helped to address user conflict, additional needs and other changes to the Forest Service Trail System. We will discuss the need for those additions later in these comments.

Trail Relocation and Improvement

We strongly support the need for reroutes in order to improve many of the existing system trails. We have helped to coordinate hundreds of hours of volunteer time to repair trails that are unsustainably built or aligned on old roadbeds just to see these trails decimated yet again by monsoon rains. As an example we have worked at least three times with the Forest Service trail crew on Lower Brookbank in the past decade. Currently that trail is badly rutted and covered in loose rock. The current alignment cannot be repaired in a permanent way because it was established on an ancient roadbed at an unsustainable grade. Trail maintenance is a normal part of any system regardless of how well trails are aligned and built, but many of the current MEDL System trails require an inordinate amount of maintenance because of their poor initial layout.

We would like to be closely involved in the choosing of the realignment corridors for these trails.

General Trail Signage


We support this action, but we suggest that it could be expanded. The Red Rock District has implemented signage strategies that assist in route finding as well as “informing the public on current and proposed trail use restrictions.” These signs include area maps showing system trails in the immediate proximity. This strategy has been implemented in various other higher recreational use areas and adds a stronger sense to trail users that they are present on a managed system, which can help better achieve “increase(d) compliance and safe, sustainable use of system trails and decrease unauthorized trail construction.”

We would also like to see more signage informing trail users of proper trail etiquette. We believe strongly that education and reinforcement of proper trail etiquette is one of the best tools to minimize user conflict issues. We have been surprised that many mountain bikers have never been properly educated on yielding to other trail users and yielding to uphill traffic, in spite of our efforts and the efforts of IMBA, the US Forest Service and others. Signs informing cyclists of areas of higher levels of equestrian use would also be helpful. Well-placed signs, at the top of long descending sections of trail for example, could improve trail user experiences for all.

We would like all of this signage to be implemented in a manner that is not overly intrusive to the landscape.

Brookbank Trail

As may be apparent from our comments above, we strongly support the realignment of Brookbank Trail to improve sustainability and user satisfaction.

We have a different recommendation than that shown on the map for the PA. (Please see our attached map.) We have hiked this area extensively and based upon our substantial history working with the Forest Service laying out and constructing trails, we ask that you strongly consider our proposal as it would place the trail in better soil, in better trees for a more desirable experience and address some substantial issues with rock outcroppings in the vicinity of this trail.

Upper Oldham Trail

This trail suffers from a significant lack of use and terrible erosion because of its poor alignment. Cyclists who wish to access the top of Sunset Trail are more apt to climb Elden Lookout Road than to hike-a-bike up Oldham, leading to potential for conflicts between people driving Elden Lookout Road and a less than desirable riding experience. Realigning this trail would make it useful for climbing or descending on a bicycle and we think far more palatable for the average hiker, trail runner or equestrian as well.

Please note that there are minor differences between the alignment shown in the PA and what we are showing on our attached map. Extending the overall length of this trail will reduce the grade substantially, which will improve its sustainability and usefulness. Additionally, moving the alignment away from Elden Lookout Road as much as possible, especially on steeper slopes, will help to address the runoff from the road that has repeatedly damaged this trail in the past.

Additionally we propose that this trail connect to Red Onion Trail, a user-created route that we are recommending for adoption onto the Forest Service system. We will discuss the need for this addition later in these comments.

Little Elden Trail


Sections of this trail were initially poorly aligned on existing fall-line roadbeds. We have looked at other solutions for these sections and can offer no other good solution besides realignment to single-track built on contour.

Lower Oldham Trail relocation/ Flagstaff Loop Trail (FLT) Improvements

We are exceptionally enthusiastic about these changes to the trail system! Re-designating these trails as class 4 and improving their connectivity to the Flagstaff Urban Trail System, (FUTS), and Buffalo Park will be instrumental in highlighting the Flagstaff Loop Trail’s mission as a gateway between the City of Flagstaff’s FUTS and the Forest Service trail system. This trail will serve as a de facto part of the FUTS system because of its location and connectivity while at the same time providing access to the rest of the MEDL Trail System. This trail will serve beginner mountain bikers and kids, bike commuters, after work dog walkers, joggers as well as all of the usual Forest Service trail users.

It is very important that the realignment of the Flagstaff Loop Trail along the base of Mt. Elden follow the basic corridor of the pipeline, although along contours rather than in a straight line, as shown in our attached maps. Re-designating the class 3 Forces of Nature Trail and the eastern section of the Pipeline Trail as Class 4 will substantially change the character of the Environmental Study Area. The location of these trails would also make rebuilding to a more developed trail classification virtually impossible. Many of our members value the current, more rugged characteristics of these trails. Moving the FLT along with the re-designation as class 4 as we are suggesting would better address the need for a “neighborhood trail” since it is closer to the City. Keeping the more traditional class 3 designation of Forces of Nature and Pipeline Trails in conjunction with this new class 4 trail will provide for a more diverse array of recreational options.

It is our understanding that the alignment for this section is shown incorrectly in the PA because of what was essentially a clerical error in the mapping. We hope that this is the case. Please consult our included maps and contact us for any clarification.

Trailhead Improvements

We are generally in favor of most of the trailhead consolidations.

Consolidate Schultz Tanks and Sunset Trailheads


Although these trailheads are located very close to each other, they serve very different purposes. Many people park at Schultz Tank to hike Weatherford Trail. Parking at Sunset Trailhead would add another mile to an out-and-back hike on Weatherford. With that in mind, it may make sense to add a connector trail from Schultz Pass Road and Secret Trail across to Weatherford Trail to shortcut this access. We recognize that technically this trail would fall outside the geographic scope of the PA. This trailhead should have good signage informing cyclists descending Little Elden and riding Sunset Trail that the trails in this area are more apt to have equestrian traffic than other trails on the system. Please consider the feasibility of adding a pit toilet to this trailhead.

Relocate Little Elden Trailhead; West Elden Trailhead; Elden Scenic Trailhead; Elden Lookout Trailhead expansion

We support all of these as necessary improvements. Please see comments above regarding signage for trail etiquette. This is especially important for the Elden Scenic Trailhead as it will serve as a staging area for the downhill mountain bike trails and cyclists riding Sunset Trail.

Special-Use trail events

Our strongest concern regarding special-use events is than an adequate number of options for routes is offered. Most mountain bike events require routes for varying race categories. Events usually require loops so that participants are not running into one another. Some of our recommended additional trails below will be helpful in providing for special-use events while providing alternative routes to minimize conflict for other users during events.

Please consider allowing the use of the downhill mountain bike trails for special-use events.

Any limits on seasonal use, specifically the limiting of events in June and July for fire danger, should be guidelines and not hard restrictions. Similarly, limiting to one event per month and 4-6 events per year should also be a guideline. Allowing for more events may be appropriate based upon the size and impact of any given event. Also, please do not prohibit staging events on Forest Service land, although limits may be appropriate.

Mount Elden Environmental Study Area improvements

We strongly support better management for the ESA as the value of this area as an educational tool has suffered because of the lack of signage and interpretive improvements. Better alignment of many sections of these trails will make them more apparently part of a trail system and discourage users from finding their own way leading to more unauthorized trails.

Please consider adding some of the user-created routes in this area and adjacent to this area to address the demand for additional access that is expressed by the proliferation of routes in this area. An expanded and better-signed trail system will help to reduce the continued expansion of user-created routes.

“Through-routes” in the ESA should be signed so that cyclists seeking to use trails to make longer rides will be directed to the best routes.

Unauthorized trail and road decommissioning

We support this action as part of a comprehensive plan that establishes an adequate quantity of trails with a diverse range of experience and challenge. Please note our recommended additions to the trail system below. We view these additions as vital and necessary to appropriately addressing the recreational needs for the foreseeable future. Recreational demand and population will continue to grow in the Flagstaff area. Decommissioning of non-system routes will not be effective if not accompanied by proper provision for system routes. The lack of enough trails will compound user conflict issues and can foster discontent amongst some trail users leading to substantial proliferation of unauthorized construction.

Please implement trail and road decommissioning after the construction of new routes that are meant to address the demand currently being met by the user-created or historic routes.

Additionally please consider managing administrative roads as routes for non-motorized access. Although these roads do not substitute for the experience provided by well-built trails, they can provide access to interesting places in the Forest and some variety when tied together with other trails.


Hang Glider Launch Site

Well-managed recreation has fewer impacts to environmental resources. We support this.




Proposed Design Features

We strongly support, and we are excited to participate in, well-planned recreation projects.

There are laws that the Forest Service must abide by and there are varying degrees of direction that guide the actions of the agency. There is no administrative action that will have absolutely no impact on resources and conversely very few actions will have completely negative impacts to resources. Please use the latitude provided in “guidelines” to provide for the best recreational opportunities.

The list of Proposed Design Features in the PA stresses methods that will minimize the impacts of recreation to other resources. We reiterate that one of the best tools for accomplishing this is to provide enough of the right opportunities for recreation. Please include language in your Environmental Assessment that recognizes that qualitatively and quantitatively addressing recreational demand is a best-practice design feature.

Recommended additions and changes to the Proposed Action

During preliminary scoping we brought forth several additions to the trail system that were not incorporated into the PA. These recommendations were a compilation of our formal and informal surveying of mountain bikers and our own observations regarding where user-created trails have been established. Recognizing that the proliferation a several user created routes in an area can indicate an unmet need is vital to addressing demand. Establishing a single, well-built and desirable trail and connecting it in a well-signed manner to system routes is an extremely successful way focus user impacts to a substantially smaller footprint.

Please refer to our attached maps. Pink lines on the map are trails that we are recommending adding to or changing from the Proposed Action. Yellow lines are existing trails that we support decommissioning if appropriate additions are made. Red are trails that we proposed in preliminary scoping that did make it into the Proposed Action. Blue are downhill trails that we proposed in preliminary scoping that did make it into the proposed action. Numbers on the map correspond to the list below. Some of the recommended changes are reiterations of input made in our Comments on the components of the Proposed Action above.

  • Please work with the City of Flagstaff to relocate Schultz Creek Trail Head to the “Schultz ‘Y’” City Parcel, thereby providing a 4-season accessible trailhead. Seek an Intergovernmental Agreement with the City of Flagstaff to manage and protect this property as open space and a trailhead. As was evidenced by attendance at the October 28th, 2013, Flagstaff City Council meeting, there is very strong public support for this action. Please note that several very important trails intersect at this location: the Arizona National Scenic Trail, the Flagstaff Loop Trail, the Flagstaff Urban Trail System and Schultz Creek Trail. There may be opportunities to cooperatively manage this area with a trailhead with pit toilets, an interpretive loop trail highlighting environmental and historic features in the area, a mountain bike skills area and/or event staging facilities. We have sent a letter to the City requesting that they partner with the Forest Service.
  • Add a trail between the Schultz Creek Trail Head and the newly proposed Dry Lake Hills Loop. This will add an alternative to both Schultz Creek Trail and Rocky Ridge Trail to help disperse use and minimize user conflicts as well as maximizing the “stacked-loops” concept in the Dry Lake Hills. Additionally, as changes are made to Rocky Ridge trail per its class 3 designation as part of the Arizona Trail and Flagstaff Loop Trail, this trail will serve to replace the challenge opportunity formerly provided by Rocky Ridge. Please note that this trail would serve to replace multiple user created routes in this area, resulting in a net reduction of any environmental impacts. (#1 on our attached map)
  • Move Lower Brookbank Trail from its currently proposed re-alignment to the east. We have hiked this area extensively and our alignment would make for a much better trail. (See above Comments on the components of the Proposed Action.) (#2 on our attached map)
  • Add upper Red Onion trail into the system in the Preferred Alternative in the Draft Environmental Assessment. Red Onion is a vital connection to the MEDL trail system as it shortcuts the need to climb all the way to the top of Mt Elden to make loops. With the realignment of Upper Oldham, this connection becomes even more valuable. Red Onion is one of the oldest non-system trails in the MEDL area and has a very large amount of support amongst all trail users. Note that Red Onion would need connection across Elden LO Road to Upper Oldham. (#3 on our attached map)
  • Add Ginger and Jedi Trails to the system. These trails provide an intermediate to advanced experience that is otherwise not available on the system. These trails appeal to a diverse array of riders as they are not built to the same degree of challenge as the downhill mountain bike trails. The Red Rock District has recently incorporated several trails with a similar degree of challenge, (Highline and Hangover for example), which has helped to address this demand in that area. Adding these two trails while eliminating other user created routes nearby will result in a net reduction in impacts in these areas. (#4 and #5 respectively on our attached map)
  • Add a trail connecting the lower section of Sunset Trail to the top of Lower Brookbank to add further connectivity and versatility to the trail system. When coupled with the Dry Lake Hills Loops and the trail connecting from the DLH Loops to Schultz Creek Trailhead, this will provide an alternative to Schultz Creek Trail which will help to alleviate user conflict issues that continue to grow on Schultz Creek because of its popularity. Although Little Gnarly is a fine route, it is not single-track, it is an exceptionally challenging climb and it connects from a different place from this suggested trail. This trail travels through an area that has several old roads that are frequently used by cyclists. This route would be a better experience than those roads and provide access to this part of the Forest, potentially allowing for a net replacement should these old roads be decommissioned. (#6 on our attached map)
  • Align the re-designated Class 4 Flagstaff Loop Trail along the foot of Mount Elden on contours along the Pipeline corridor rather than where it is shown in the Proposed Action along Forces of Nature and other trails in the Environmental Study Area (the current FLT alignment). This will minimize impacts to the ESA and is a more appropriate placement for this trail type at the Forest-Community interface. (See above Comments on the components of the Proposed Action.) (#7 on our attached map)
  • The Doney Park Multi-modal study completed in 2011 recommends a FUTS type extension from the end of the FUTS at Snowflake, across Forest Service land to the intersection of Townsend-Winona Road. The analysis for this folds perfectly into the MEDL planning. (#8 on our attached map)

Thank you for taking the time to thoroughly review our input. We look forward to helping to shape this planning and to eventually assisting in any way that we can with the implementation of this project.

Should you have any questions, please feel free to contact us.


s/Anthony Quintile

For the Board of Flagstaff Biking Organization