Berry Creek Trails Impact – Public Comments Needed!

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A Few Quick Notes to Set the Stage:

  1. The Berlaimont Estates development area is private property which means that the USFS legally has to provide access to their property.
  2. Eagle County approved Berlaimont’s zoning request which ultimately means that they can build on their property if they wish to do so.
  3. Therefore, Berlaimont Estates has the right and option to decide whether they want to pay for improving the current dirt road or paving the road.
  4. In conclusion, the VVMBA is focusing our efforts and comments on identifying how recreational trail use is going to be affected with the changes to the roads in Berry Creek.



Basis and purpose of VVMBA comments

Should the Berlaimont project proceed and upgrades to FSR 774/780 occur in accordance with alternatives proposed in the DEIS (Draft Environmental Impact Statement) , VVMBA believes that impacts to recreational use in this community-treasured location are inadequately addressed by the proposed mitigation actions.  Addition of a paved, year-round road will fundamentally change the nature of recreation use in the area by both increasing the number of recreation users in the area and significantly shifting the typical access patterns of recreation use.  The Berry Creek and Mesquite trail networks within the project analysis area will transition from an already heavily-used WUI (Wildland-Urban Interface)/semi-backcountry character, to something more reflective of a near-urban or front-country recreation area character.

VVMBA believes that due to these inevitable changes to use levels, the DEIS falls short in addressing recreation impacts to within the project analysis area. We describe a number of these shortcomings in the proposed mitigation plans below. Because all proposed Alternatives share a similar impact type to FSR 774/780 and a similar proposal for mitigating trail access to upper Berry Creek Trail and the surrounding public lands, these comments are equally applicable to all proposed alternatives.


The above map sums up the VVMBA’s recommended recreational multi-use trail alignments and identifies the reasoning why these trails are needed in addition to the proposed trail in the DEIS.  (Click on the map to enlarge)

How to Comment

After reviewing the map and comments below we urge you to submit your comments to the USFS on the Berlaimont Estates road improvement project page via the link below.

Comment on the Berlaimont Estates Project

Further information and all documentation related to the Berlaimont Estates road improvement project can be found via the link below.

Berlaimont Estates Road Improvement Project Information

Issue 1: Section 3-C, pg 102.  Recreation use in the area is significantly underestimated by the little available data, and is likely to continue to significantly increase as a result of Eagle County demographics and the establishment of paved access.

We believe the small amount of quantified user data available to WRNF (2009) significantly underestimates use.  Partly because use has increased since 2009 when data were collected, but also because the time period (3/17-6/1) only included 9 days of motorized use (Seasonal restrictions on FSR 774 exist until 5/21) and collected infrared pedestrian and biker data primarily during late winter to late spring, a time when Berry Creek is used at levels far lower than summer and fall seasons.  

During March and April, system routes are frequently still snow-covered, or passable only on foot due to mud conditions.  Anecdotally, several dozen cars are regularly observable at the lower signed trailhead and the Moonridge Drive pull-outs, just on weeknights in summer and fall. Weekends regularly receive even higher use.  VVMBA believes that if traffic surveys had occurred during high use months, from early June to September, pedestrian and bike use estimates alone use would easily tally several hundred per day on weekends, and cumulatively tally in the multiple thousands across a full season.  VVMBA does not suggest a particular solution to address this data gap, but feels it is strongly important to recognize this area is much more heavily used than suggested in the DEIS, which lends further importance to the issues and mitigation measures described below. VVMBA is also interested in working with WRNF to establish user surveys and updated counter statistics to more-accurately describe use levels in this zone and other trail systems.

Issue 2: The DEIS description of recreation use patterns and the proposed recreation mitigation underestimates significant changes to use types and frequencies due to 2wd road access.

Based on observations in many other nearby locations, such as the West Avon Preserve, Tennessee Pass/Camp Hale Colorado Trail, Snowmass Village municipal trails, etc., car-shuttled biking will potentially become a normal use type.  This will increase pressure on existing lower Berry Creek trail tread, as well as increase the potential for undesirable socially-damaging user conflicts.  Although measures such as not permitting pull-offs or parking, and establishing guardrails near the middle trail and upper Berry Creek Trail access points, these often fail in practice to fully prevent the activity.  While Upper Berry Creek Trail tread has already been designed to accommodate heavy bike use, lower Berry Creek may potentially experience tread degradation and increased maintenance needs from this type of use.  Additionally, shuttle-riders often employ more downhill-oriented equipment and higher speeds, greatly increasing potential for user conflicts on the multi-use, bi-directional lower Berry Creek.  

Implementation of an additional trail in the lower Berry Creek zone on the ridge line west of the existing trail would mitigate these impacts more successfully [Trail 1-B on attached map], this trail should be designed with lower gradients and tighter turn radius, in a manner that accommodates uphill riding, two-way pedestrian traffic, and slows rider speeds if open to bi-directional riding. Completion of this trail in a sustainable fashion would also aid in more-successfully decommissioning the erosive fall-line 4wd road that continues to be heavily used by pedestrian traffic.  In the long term, although not part of this action, it may be also desirable to consider a secondary one-way downhill use trail connecting between the grave site junction at 7800’ on lower Berry Creek and the Moonridge Drive parking area.  This will further serve to preemptively decrease user conflicts, increase the recreational opportunity spectrum, and discourage additional unsanctioned routes in the area.  

Issue 3: Proposed mitigation trails will not fully address the current level of unauthorized use routes and user patterns and likelihood for increased unsanctioned trails due to year-round 2wd access.

WRNF (White River National Forest) cites the existence of unsanctioned trails in the area and ad-hoc parking areas while discussing use patterns (pg 106).  Unsanctioned trail establishment has occurred variously from all user groups (i.e. the continued frequent pedestrian use of the decommissioned 4wd road on the ridge line directly west of lower Berry Creek trail; the former bike trail segment above the upper Berry Creek trailhead, restored in 2016; the various moto-established singletracks in the upper analysis area).  

VVMBA interprets this heavy use and continued establishment of unsanctioned routes in the analysis area as evidence that recreational needs and the Recreational Opportunity Spectrum continues to be mismatched to existing use levels and contemporary front-country/WUI recreation user patterns, which commonly include the desire for multiple shorter routes, variable difficulty levels, and looping options.  VVMBA believes that the increased access to the area provided by the year round road will further increase this pressure, and is only partially mitigated by the proposed trail system additions in Alternative 2.  We believe that the routes described [1-B and 1-E] on the attached figures would more-appropriately accommodate current increased uses, thus improving safety and user experience by better-preventing user conflicts and decreasing the likelihood for additional user-established, unsanctioned trails.  Once sustainable re-routes and new segment designs are established, VVMBA will work with WRNF and Berlaimont project proponents to further decommission additional degraded and unsanctioned user routes in the zone.

Issue 4: Proposed recreation mitigation does not account for the most-common use pattern for hikers and runners on the lower portion of the trail system and places users on the paved road in the middle portion of the trail system.

While mountain bike users most frequently begin Berry Creek at the top access on FSR 780, a highly common use pattern for hikers, trail runners, and dog walkers is a shorter loop that utilizes only the lower half of the trail system by connecting lower Berry Creek to FSR 780 at the 7800’ saddle.  Under all proposed Alternatives, users who climb the new mitigation trail to the 8000’ intersection with FSR 780 will need to proceed either on the road or on a road-adjacent sidewalk or travel way to reconnect to lower Berry Creek.  This provides a highly undesirable user experience aesthetically and safety-wise, placing recreational users close to road traffic with an increased chance for interactions with traffic, including potential problems with off-leash dogs, which are a common occurrence in the area.  

VVMBA believes an additional connector trail segment will most-appropriately mitigate these impacts [1-E on attached figure]. This trail should proceed from the 8000’ level where the proposed trail intersects the dog-leg turn on FSR 780, and head south to connect to Lower Berry Creek Trail in order to maintain the existing use pattern for lower loop recreational acces.  The trail should remain on the east side of the ridge crest as it connects south in order to maintain a significant buffer distance from the road until a designated and high-visibility road crossing point to connect to the lower system.

Issue 5: Section 3-C, pg 110  The proposed trail design and tread width for the parallel trail beside FSR 774 connecting between the existing lower trailhead and the newly proposed upper parking area beyond the 780/774 junction is insufficient to accommodate existing and future use patterns

The DEIS proposes a 24” trail from the existing WRNF kiosk up to the new motorized trail head, then climbing west to access the upper Berry Creek trail system (Section 3C, pg 110).  This trail is comprised of three distinct segments: a portion parallel to FSR 774, a portion climbing between the new parking lot and the 8000’ dog leg turn of FSR 780, and a portion climbing from this turn to connect to the upper Berry Creek trailhead.  This 24” tread design is appropriate for the two portions climbing above the new parking lot and remains consistent with the singletrack character of the existing trails in the area. However, lower FSR 774 currently receives very heavy out-and-back traffic by dog walkers looking for creek access, short-distance walkers with children and older-demographic users, and bike users accessing FSR 780 and further up FSR 774.  The 24” tread width proposed for this lower connector segment will be completely inadequate and likely lead to significant user conflict, since this 0.8 segment receives a much wider user mix than upper trail systems.  

To safely and sustainably accommodate this use, the mitigation trail here should reflect a ‘beginner’ design, similar to an urban recreational trail, with a much wider tread pattern to accommodate safe bi-directional passage of users, and occasional ‘control features’ such as boulder styles or chicanes to maintain rider/pedestrian speed differentials at a safe level.  VVMBA suggest this trail should still strive to maintain a natural tread surface, but might be similar in width and grade to front-country multi-use designs in Jefferson County Colorado or other high-use areas.  A tread width of at least 48”, and potentially approaching 72”, may be most appropriate for this segment.

Issue 6: MA 5.41 designation no longer reflects the contemporary character of the lower Berry Creek and Singletree-adjacent  analysis zone.

Upon the establishment of the subdivision with Berlaimont’s inholding, and road improvements to paved year-round access; Management Area 5.41 designation will poorly reflect the actual on-the-ground conditions of resource use.  We propose that the areas of MA 5.41 designation south of the the utility corridor (MA 8.32) would more realistically reflect contemporary use levels and conditions with a MA 7.1 Intermix designation.  This designation most-accurately reflects existing conditions as well as likely future use trends, and in light of a number of unsanctioned use routes that are unlikely respond successfully to decommissioning, would be allowable of a an increased travelway density.

Because the Forest Plan must already be amended to accommodate Berlaimont’s proposed use; VVMBA asserts that the most realistic long term management paradigm for the area would be to redesignate to MA 7.1 the lower portions of the analysis area as part of this action. This area includes lands south Berlaimont’s inholding and east of Beard Creek down to the forest boundary at Cordillera, as well as the zone between the Edmund’s Pole Road (FSR 774) and the Singletree neighborhood, eastward to the boundary with the West Avon Preserve.

Issue 7. Maintenance needs and long term costs for trail system and trailhead changes described in the DEIS and here should be explicitly shared by the Berlaimont project proponents and the local community partners, and not maintained as the sole burden of WRNF EHX district.

The proposed increased trail system would require the VVMBA, Berlaimont, and perhaps other community partners in Edwards, and our community to take more responsibility for the system.  The proposed trail system will be adopted into the Adopt A Trail program with the hope that Berlaimont will provide support monetarily and through volunteer hours.  Additionally, the VVMBA and Adopt A Trail program would provide trail crew leaders, trail crew volunteers, and regular maintenance of the trail system.

Figure 1 – Proposed Trail Alignment