Action Alert: Comment on the Lemon Gulch Trails Project

Blue Mountains Biodiversity Project Action Alert:
“Lemon Gulch Trails Project” mountain bike trail system

Please send your comments by December 19th at the latest to:
Beth Peer, Environmental Coordinator, Ochoco National Forest, 3160 NE 3rd Street, Prineville, OR  97754, or use the Forest Service online comment system at: 

Madeline, Cai, & Matthias at a rocky scenic overlook in the west side of the trail system area

The  Ochoco National Forest is proposing a mountain bike trail system on the Lookout Mountain Ranger District about 20 miles northeast of Prineville, Oregon, adjacent to Mill Creek and near the Mill Creek Wilderness Area and the Steins Pillar rock formations.  The Forest Service’s intent is to meet the demands of mountain bikers for a trail system on the Ochoco specifically designed for mountain bike use.  However, there is significant opposition to the location of the proposed trail system from many local residents.  Local resident concerns include conflicts with traditional recreational uses of the area, including equestrians; safety hazards posed by mountain biking in active cattle grazing allotments; and displacement of elk and deer from mountain bike disturbance.  

Blue Mountains Biodiversity Project’s main concerns include:  

  • There would be spring, summer, and fall disturbance of already declining Mule deer, as well as elk.  Mountain bike disturbance can cause both species to expend more energy, losing summer fat before winter cold and storms, and to abandon fawning and elk calving habitat in the spring, directly impeding reproduction.
  • Proposed mountain bike trails are currently planned for location on steep slopes directly over Lemon Creek, a major perennial creek directly reaching Mill Creek trout habitat in the area, with trail crossings of the creek and drainages.  This could increase soil erosion and sedimentation of Lemon Creek, with downstream excess fine sediment potentially reaching Mill Creek, which would be detrimental to Redband trout and Columbia Spotted frog. 
  • We are concerned by the cumulative impacts to already severely degraded stream, seep, and spring systems; the lack of plant diversity and ground cover; and wildlife habitat, from heavy past logging, planned additional commercial logging in the Mill Creek sale, and legacy livestock over-grazing, continued cattle grazing, and the proposed large scale, high density mountain bike trail system.

Blue Mountains Biodiversity Project prefers the agency’s “No Action” alternative as the least ecologically harmful alternative for wildlife disturbance; steep slope erosion potential; plant cover removal and potential harm to sensitive plants; riparian impacts such as introducing excess fine sediment into Lemon Creek and tributary streams; and causing introduction of invasive exotic plants.  The next two alternatives that would be the least ecologically damaging for a mountain bike trail system would be alternatives 4 and 3.  Alternative 4 would have the least impacts from stream crossings and erosion from trails on steep slopes reaching Lemon Creek or stream tributaries, other than alternative 1.

Summary of the alternatives proposed by the Forest Service:

Alternative 1: No Action, so no mountain bike trail system in this location.

Alternative 2:   51.3 miles of trails, the largest and densest trail system proposed.  Mountain bike groups are promoting the originally proposed large scale, high density trail represented in alternative 2, due to its greater complexity, wider variety of trails for different skill levels, and larger mileage and scale of the trail system to accommodate more mountain bikers using it.  Alt. 2 proposes a trail segment through part of one potential fawning or calving site, out of only a few sites identified in the project area.  The proposed season of use from May until December would overlap the spring wildlife and plant reproductive season.  Numerous trails proposed in alt. 2 would be within ¼ mile of identified seep, spring, or elk wallow habitat.

Madeline, Cai, and Matthias on a steep barren slope near the flagged trail route. BMBP is very concerned about steep slopes, lack of ground cover, and potential landslide risk above Lemon Creek & its tributaries streams.

Alternative 3:   21 miles of trails, with a reduced footprint to address concerns about impacts to cattle grazing and wildlife habitat.  There would be no trails on the west side of the Lemon Creek drainage—which is apparently core Mule deer habitat (also good for elk) identified by the Oregon Department of Fish and Wildlife. There would be fewer trails throughout the east side of the drainage, retaining larger blocks of unaffected wildlife habitat and reducing trail miles in high use livestock grazing areas.

Alternative 4: 19.1 miles of trails, in a similar reduced footprint to alt. 3, but with fewer trail miles in the north and northeast sections of the project area, which reduces trail overlap with high use cattle grazing areas, and as with alt. 3, has no trails on the west side of the project area. 

Comparing alternatives 3 and 4: Both alternatives 3 and 4 have no trails proposed within existing elk security habitat.  Alt. 3 would retain the most total core habitat for deer and elk, with the highest average core habitat size.  However, alt. 4 better avoids impacts to Lemon Creek, since alt. 3 has much more trail mileage on slopes above Lemon Creek and some trail miles are next to the creek, which alt. 4 avoids. Alternatives 3 and 4 include only one crossing of Lemon Creek.

Mountain bike trail flagging through the forest with Madeline

Alternative 5:  28.7 miles of trails.  Alt. 5 includes the west-side cross country trail, with a higher concentration of trails in the northeast part of the project area.  It eliminates the east side climb (uphill) trail.  Alt. 5 would reduce total core elk and deer habitat by 506 acres—15%–and would reduce the average core patch size by 204 acres.  Alt. 5 would disrupt less wildlife habitat than alt. 2 (which would reduce total core habitat by about 16%), but more than alternatives 3 and 4.  Alt. 5 proposes the second-most miles of trails within the Lemon Creek riparian habitat and includes up to 3 stream crossings, as with alt. 2.  Numerous alt. 5 trails would be within ¼ mile of identified potential elk calving and fawning habitat and seep/spring/elk wallow habitat.

Alternative 6:  27.5 miles of trails, more trail mileage than alt.s 3 and 4 and 1.2 miles less than alt. 5.  Alt. 6 would reduce core habitat by 527 acres or 16% and reduce the average core habitat size by 205 acres.  Alt. 6 would retain proposed trails on both sides of the Lemon Creek drainage, but less than alt.s 3 and 4 on the west side.  Alt. 6 proposes fewer miles of trails within the Lemon Gulch riparian area than alt.s 2, 3, or 5, but has up to three creek crossings.  As with alt.s 2 and 5, numerous trails would be within ¼ mile of seep/spring/elk wallow habitat..

Alternatives 2, 5, and 6 are more ecologically destructive overall than No Action (alt. 1) and alternatives 3 and 4.

Forest near proposed mountain bike trail route

Let the Forest Service know that they need to protect wildlife, stream habitats, and forested ecosystems— the agency should adopt the No Action alternative. They should drop their plans to build trails that would harm elk, soils, sensitive plants and riparian habitats, and water quality. 

Please send your comments by December 19th at the latest to:
Beth Peer, Environmental Coordinator, Ochoco National Forest, 3160 NE 3rd Street, Prineville, OR  97754, or use the Forest Service online comment system at:

Thank you!