McGrew Trail Petition Summary The Siskiyou Project and others are petitioning the Forest Supervisors of the Siskiyou and Six Rivers National Forest to close the McGrew Trail (FS Roads 4402-019 and 4402-450) to motorized vehicle traffic. The McGrew Trail traverses the inventoried South Kalmiopsis Roadless Area, which is proposed for Wilderness designation by over 100 organizations throughout Oregon. This closure action is needed immediately because motorized vehicle use on this route and off-route is causing unacceptable and significant damage to (1) National Forest lands and resources, (2) habitat of Arabis macdonaldiana, an endangered plant listed under the Endangered Species Act ("ESA"), and other rare and endemic plant species (3) important recreation and scenic values, and (4) has a high risk of introducing the non-native pathogen, Phytophthora lateralis, also known as Port Orford cedar root rot disease. Currently, most motorized vehicle use on or in the vicinity of the McGrew Trail is unregulated. The McGrew Trail is increasingly being used, both on and off route, by four-wheel drive, off-highway and off-road vehicles ("ORVs" or generally "vehicles"). Both regulated and unregulated use is causing unacceptable and significant damage or may cause irreversible impacts through the introduction of P. lateralis into an area or watershed containing Port Orford cedar. Introduction of the pathogen has many ecological consequences such as adverse impacts to stream, riparian, and rare plant habitat and to biological diversity. Many vehicles are being driven off the designated route and onto sensitive ultramafic rock outcrops, serpentine barrens, fragile serpentine soils, and sensitive forest and rare plant habitat. Accordingly, we hereby petition you to immediately close the McGrew Trail to motorized vehicle use. Motorized use of the McGrew Trail is increasing significantly. The Forest Service ("USFS"), in partnership with 4-wheel drive organizations, has increasingly promoted the motorized use of the McGrew Trail. However, until this year no plant surveys had been conducted on the Trail. The USFS has also failed to heed concerns expressed by their own scientists about the risk of high risk of introducing P. lateralis. The USFS has not done an adequate job protecting the Forest against inappropriate motorized vehicle use. As a result, motorized vehicle use has caused and continues to cause unacceptable and significant damage to National Forest lands and resources. Motorized vehicle use is also destroying the natural resource values along and adjacent to the McGrew Trail. The attached photographs document some of the damage that has occurred. Increasing Off-Highway/Off-Road/4x4 Vehicle Use Increasing use of off-highway, off-road and 4x4 vehicle use off roads and in sensitive areas represents one of the fastest growing threats to the natural integrity of our National Forest lands. The increased popularity of ORVs/OHV and 4-wheel drive vehicles has coincided with technological advances that have enabled these machines to travel cross-country and on rugged trails at an alarming rate. While the use grows and the range of vehicles increases, the Forest Service has largely ignored resulting resource damage and user conflicts. The McGrew Trail is no exception. The trail is listed and/or described on more than 20 ORV websites. (Some excerpts from a few of the websites are attached to this petition as Appendix B.) Many of these sites show photos of vehicles climbing rock outcrops and huge boulders along and adjacent to the road. The narrative on these websites provides documentation of user-created routes and the widening of routes to get around certain "hazards". In addition to documentation from the Internet, hikers on the trail report encountering as many as twelve vehicles in a group. Hikers have also noted areas where vehicles have left the main track. USFS records document that groups of 100 or more vehicles use the McGrew Trail annually. The Oregon Creek Trail is an example of high volume use that has occurred for many years. Currently, at least 100 high-clearance, 4-wheel drive vehicles travel the route in an annual event, testing their driving skills as they crawl over huge boulders and other "obstacles". However, it was not until 2002 that the Forest Service undertook surveys for sensitive and endangered plants along the route or documented impacts to these plants from motorized use. This organized event is but one example of the ongoing and increasing use of the McGrew Trail by motorized vehicles. Although some mitigation measures were put into place for the Oregon Creek Trail in 2002 (like driver education and staking around sensitive plants), there is no mitigation for the hundreds of other motorized vehicles that travel on and off the route each year. Additional organized events are planned in 2002, including a Labor Day event for 50 vehicles, and the number of vehicles traveling the route is likely to increase in the future. Habitat for the endangered Arabis mcdonaldiana and Sensitive and Endemic Plants The McGrew Trail traverses rocky peridotite/serpentine soils, much of it habitat for rare and endemic plant species that are unique to the Siskiyou/Klamath range. Such serpentine environments are globally rare. Their distinctiveness and the high concentration of rare flora warrant special management considerations. A recent botanical survey of the trail by a Siskiyou National Forest botanist conclusively determined that several sensitive and/or endemic plant species occur within the McGrew Trail road prism or within site distance from the roadside. These plants include: Bolander's Onion (Allium bolanderi), Waldo Rock Cress (Arabis aculeolata), Oregon Bleeding Heart ( Dicentra formosa ssp. oregana), Opposite-leaved Lewisia (Lewisia oppositiolia), Howell's Microseris (Microseris howellii), Howell's Streptanthus (Streptanthus howellii), and Siskiyou Mountain Pennycress ( Thlaspi montanum var. siskiyouense). Of these, Opposite-leaved Lewisia, Howell's Microseris, Howell's Streptanthus, and Siskiyou Mountain Pennycress were found along areas of the trail that have been impacted by motorized vehicle use or in the roadbed itself. McDonald's Rock Cress (Arabis macdonaldiana) was listed as endangered under the ESA on September 28, 1978 for its entire range. This plant prefers serpentine soils and rocky habitat, but it is also found in dry, open forests. During the 2002 botanical survey, approximately 40 plants were found in crevices on a serpentine rock outcrop and along the road edge. Rare, sensitive and endangered plants have been or will likely be adversely impacted as motorized vehicle use continues and increases on the McGrew Trail and as technological advances allow more motorized vehicles to travel off the trail. The 2002 Botanical Biological Evaluation notes that without consistent management, we may lose sensitive species like Streptanthus howellii, as well as members of Arabis macdonaldiana, however, the Forest Service has yet to prevent off road vehicle damage even in designated Botanical Areas with road access. In fact, damage to rare plant habitat in Botanical Areas such as Eight Dollar Mountain and Days Gulch by vehicles off roads is increasing. Risks to Port Orford Cedar Port-Orford-Cedar, Chamaecyparis lawsoniana (POC), is an important component of forest ecosystems in Southwest Oregon, Northwest California, with inland populations in the Sacramento and Trinity River basins of California. POC is a coniferous tree species that is endemic to these areas. It is found along the McGrew Trail and the watersheds below the trail including the National Wild and Scenic North Fork Smith River and its tributaries, Baldface and Diamond Creeks, and Rough & Ready Creek, a candidate Wild and Scenic River, along with Baldface Creek. POC is extremely susceptible to a fatal, non-native pathogenic root rot fungus, Phytophthora lateralis, a disease that has spread through much of the northern and western extent of the POC range. P. lateralis is a water mold that infects POC by dispersing through water and contacting root hairs. P. lateralis quickly kills POC trees of all sizes. Seedlings often die within a few weeks of infection, while saplings die within a few months, and larger trees in one or more years. No known genetic resistance or chemical control has been identified once a tree has become infected with this disease. A recent study, conducted in 1998-1999, in the Page Mountain area of the Siskiyou National Forest, found infection along 46% of the 63 km of creeks with POC. 72% of the infections began directly at locations where roads cross creeks. Even Non-Road infections (those in creeks without road crossings) were in creeks that had a road uphill, above the creek. Only creeks above the entire road system remained uninfected. The consequence of the introduction of P. lateralis is ecological disruption in sensitive habitats, including riparian areas, wetlands and other rare plant habitat, and loss of biological diversity. On ultramafic soils, POC may be the only riparian tree species. Its loss may have an immediate and drastic effect on stream ecology. Once introduced, there is no practical means to eradicate P. lateralis, and there are fewer and few large, disease-free watersheds. The Baldface Creek and Rough & Ready Creek Watersheds are two such large watersheds, which are almost entirely free of roads except for old mining tracks or travel routes such as the McGrew, Biscuit Hill and Chetco Divide Trails and road 4402-112. The McGrew Trail provides access to uninfected POC stands through infected areas. The North Fork Smith Watershed Analysis lists the McGrew Trail (section 4402-450) as one of four roads in the area that present a potentially high risk of disease spread for the North Fork Smith Watershed. The Watershed Analysis also notes that POC is abundant in the Baldface Creek Watershed and that the risk of root disease introduction is increased by the high percentage of four-wheel drive vehicles and motorcycles using the area. In addition, the West Fork Illinois River Watershed Analysis places particular importance on preventing the introduction of P. lateralis into the Rough & Ready Creek Watershed noting that most low elevation drainages are already infected. The McGrew Trail also drains into uninfected tributaries of Diamond Creek and Whiskey Creek. Most experts agree that permanent road/motorized trail closures are the best way to prevent the introduction of Port Orford cedar root disease. A 1993 inter-agency report prepared by experts from the BLM, the Forest Service, and other federal natural resource agencies, found that restricting further road construction and closing roads in watersheds that contain uninfected stands is critical for the conservation of POC as a species. Therefore, the McGrew Trail should be closed to motorized vehicle use in order to protect POC along the route and throughout the watersheds that are traversed by the trail. Photo Documentation Attached as an appendix to the petition are 25 photos and a narrative is included in the body of the petition. These photos show impacts to rare and sensitive plants, user-created spurs along the trail, off-route "playgrounds," and other types of damage on the McGrew trail in California and Oregon. Legal Authority for a Closure The Forest Service has the legal authority and the responsibility to issue an immediate closure of the McGrew Trail. This authority, as well as the responsibility, is provided by the National Forest Management Act, Rangeland Renewable Resources Planning Act, the Siskiyou and Six Rivers Land and Resource Management Plans, two Executive Orders, 36 CFR 295, Forest Service Manual 2355, the Endangered Species Act, the Organic Act, the National Environmental Policy Act, and a number of court decisions. Therefore, the Forest Service should fulfill its responsibility and use its authority to protect National Forest lands and public resources from damage caused by motorized vehicles by closing the McGrew Trail to such use.