November 28th, 2010
Darrell Vance, Williamson Rock ID Team
Angeles National Forest
701 North Santa Anita Avenue
Arcadia, CA 91006
Subject: Comments on Williamson Rock Critical Habitat Closure Environmental Assessment
Dear Mr. Vance:
This letter is written in response to the Environmental Assessment (EA) for the Williamson Rock Critical Habitat Closure. Friends of Williamson Rock (FoWR) sincerely appreciate this opportunity to comment.
Friends of Williamson Rock (FoWR)
As you know, Friends of Williamson Rock (FoWR) is a non-profit corporation [501(c)(3)] dedicated to preserving climbing access and activity in the Williamson Rock area and protecting its natural environment. FoWR is an Access Fund affiliated local climbing organization. Indeed, the Access Fund has entered into a Memorandum of Understanding (MOU) with the Forest Service to work cooperatively on climbing access and management issues.1
FoWR has actively worked with the ANF U.S. Forest Service to help resolve the access issues at Williamson Rock by submitting comments to the ANF U.S. Forest Service initial Scoping Letter, attending numerous public scoping meetings, and facilitating Forest Service meetings with the climbing community. Additionally, with grant funds from the Access Fund, FoWR commissioned a trail study of the Williamson Rock area. You can learn more about us at http://williamsonrock.org/
Williamson Rock is the premier sport climbing destination in Southern California. Since the 1960s, climbers have been enjoying its mild summer temperatures, proximity to Southern California’s urban centers, and excellent rock quality.
We believe that the ANF’s preferred alternative to close the area for three more years is unnecessary, and instead the ANF should implement the more reasonable Recreational Development Alternative under which facilities would be constructed to route recreational use away from MYLF Critical Biological Habitat.
It is the Access Fund’s experience that virtually all potential threats or actual impacts to natural and cultural resources associated with climbing can be eliminated or reduced to acceptable levels through a combination of education, cooperation with the climbing community, and site-specific prescriptions. This Recreational Development Alternative is the correct management direction for Williamson Rock because it protects sensitive biological resources while allowing appropriate public access to a unique and popular recreation site.
Friends of Williamson Rock supports the comment letters submitted by the Access Fund (http://accessfund.org) and the Allied Climbers of San Diego (http://www.alliedclimbers.org)regarding this public land access issue which is consistent with our position.
Balancing Habitat Protection with Recreational Access
Providing outdoor recreation opportunities is a stated objective in the US Forest Service’s National Strategic Plan (NSP), and the Angeles National Forest Land Resource Plan requires that “conservation education, perimeter control, and management presence” be implemented before restricting public access. While the ANF’s preferred three-year closure alternative is inconsistent with the NSP and ANF Forest Plan, the Recreational Development Alternative is closer to the guidance outlined in these authorities.
Obvious mitigation measures will appropriately balance MYLF habitat protection with recreational access at Williamson Rock. For example, all user-created trails could be replaced by a single maintained trail (the “Long Trail”), and any climbing routes affecting MYLF critical habitat may be closed. Also, climbers can use “wag bags” to dispose human waste and an education program by the ANF promoting Leave No Trace Practices and the specific rules in the planning area will ensure compliance with these measures. The climbing community is a key resource for the ANF to promote, implement, and enforce these actions.
As you know, in 2005 the Access Fund’s Conservation Grants program funded a trail study by the Rocky Mountain Field Institute (http://www.rmfi.org) to analyze access options at Williamson Rock that avoided the critical habitat of the MYLF. The ANF’s Recreational Development Alternative for Williamson Rock is consistent with the findings of this trail assessment which found that once riparian areas, buffer zones, and the necessary critical habitat are determined, an alternative trail could solve the trail-wildlife conflict:
The majority of the rock is located outside the streambed corridor and several hundred feet away from where the Mountain yellow-legged frog has been located to date. In the event that a trail from [the main] parking lot is established to provide access for climbers, a stream crossing can be easily constructed to avoid any disturbance to the streambed.
The establishment of a single access trail to Williamson Rock and the closure of all other existing ‘social’ trails at the site would . . . reduce [direct climber interaction with] the Mountain yellow-legged frog and the Johnson’s buckwheat.
Like the RMFI study, the ANF Recreational Development Alternative includes a map indicating that a trail could be built that avoids the streambed critical to the health of the MYLF. We believe that this analysis serves as an effective guide for designing climbing access to Williamson Rock that minimizes resource impacts.
Recreational Development Alternative
The Access Fund supports the Recreational Development Alternative because we believe it will accomplish the goal of allowing limited recreational access to Williamson Rock while protecting and restoring critical MYLF habitat within the upper Little Rock Creek drainage. We support the following elements in the Recreational Development Alternative:
• The development facilities along Angeles Crest Highway. A parking lot, toilet, trailhead and informational kiosk will allow climbers and hikers a place to park and a toilet to mitigate human waste issues. Importantly, parking facilities will also allow for an informational kiosk that highlights restrictions and closures at the rock itself.
• Designation and development of a single access trail to Williamson Rock to protect the quality of the visitor experience, promote human safety, and promote the recovery of species. The designation of a “Long Trail” as the single access trail to Williamson Rock will steer climbers and hikers away from critical MYLF habitat towards the designated staging area. Signage and barriers should be strategically placed to encourage use of the trail. We also support the closure of all other “user-created” braided trails and paths along scree slopes at Williamson Rock which have historically provided access across MYLF habitat to Williamson Rock.
• Designation and development of a primary staging area. By directing climbers to a specific staging area—preferably on a hard, durable surface—potential impacts at the base of the rock beneath specific climbing routes will be minimized. The ANF should also provide an additional informational kiosk at this staging location to highlight “eco-friendly climbing principles” (plant and animal avoidance, packing out all garbage, etc.) to aid in public understanding of conservation and recovery needs for the area.
• Closure of areas on permanent and seasonal bases, as necessary, to protect the habitat and reproductive success of species. The Access Fund supports an area closure for a distance of 50 feet from centerline of Little Rock Creek for the duration of the MYLF critical habitat designation. This closure area includes all stream-based rock climbing routes (e.g. the “Stream Wall” and “London Wall”) to reduce the potential for human/frog interaction. While climbers would prefer an alternative that maintained access to the London and Stream Walls, the Access Fund appreciates the importance of stream habitat to the MYLF and agrees to the closure of these specific areas.
•The production of a Williamson Rock Area Management Plan. A management plan is critical to outline what areas are permanently closed, what areas have temporary closures (and why), where the trail and staging area are located, and a process for amending and improving management policies in the future at Williamson Rock. In order to ensure the effectiveness of management, this plan should monitor access restriction compliance, adjust access and use protocols, guide stewardship projects, and provide for biological enhancement activities to provide species recovery. As funding permits, ongoing tri-annual surveys by the USGS of the MYLF populations in the ANF and annual supplemental condition surveys should be conducted for all sensitive species in the planning area.
Friend of Williamson Rock stands ready to assist the ANF in accomplishing the various elements of the Recreational Development Alternative. This effort should include the production of educational material regarding environmentally sensitive and low-impact climbing practices for the proposed staging area kiosk. We can also provide valuable assistance for drafting of a management plan.
CEO / Friends of Williamson Rock
Cc: The Honorable Diane Feinstein, US Senate
The Honorable Barbara Boxer, US Senate
The Honorable Howard McKeon, US House of Representatives
Jody Noiron, Forest Supervisor, Angeles National Forest
Brady Robinson, Access Fund Executive Director
Jason Keith, Access Fund Policy Director
Jim Pincter-Lucke, Access Fund California Regional Coordinator
Randy Vogel, Esq.