Access Fund comments on the Road 18 Caves EA

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Access Fund comments on the Road 18 Caves EA

Les Moscoso, Recreation Planner
Bend-Fort Rock Ranger District
Deschutes National Forest
1230 NE Third Street Suite A-262
Bend, OR 97701
7th July 2000

Dear Mr. Moscoso,

Re: Road 18 Cave Environmental Assessment

Further to the Access Fund's meeting with The Deschutes National Forest (the Deschutes) on the 19th and 20th June, we are pleased to submit comments that we hope will facilitate the preparation of the Road 18 Cave Environmental Assessment.

The following comments have been prepared by the Access Fund in consultation with the Oregon Climbers Coalition (OCC), and focus on issues identified in our on-site
discussions in June.

As you know the Access Fund is a 501 (c) 3 non-profit conservation and advocacy group representing the interests of climbers in the United States. Working in cooperation with climbers, other recreational users, public lands managers and private land owners, the Access Fund promotes the responsible use and sound management of climbing resources. We encourage an ethic of personal responsibility, self-regulation, strong conservation values and minimum impact practices among climbers.

In our previous letter to the Deschutes dated 24th May 2000 we described how we assist resource managers in a variety of ways. For example, the Access Fund provides grant funding for studies and resource mitigation projects, consults on policy and planning, helps to organize and educate local climbers, and networks with other interest groups and management agencies.

The Access Fund recognizes the challenging and unusual situation in which the Deschutes finds itself with respect to management of the Road 18 Caves. We reiterate our support for the proposed management direction insofar as it would provide for improved oversight of this sensitive area through a range of measures such as controlled
parking, improved education outreach, and seasonal wildlife restrictions. Furthermore, we believe climbers will support and comply with this level of oversight, especially if
they retain an interest in the area through preservation of some climbing opportunities and if use restrictions are primarily based on more site specific analysis of climber
effects on cave resource values, evaluated in context with effects from other recreation users.

1. Supplemental information on climbing opportunities at the Road 18 Caves, and definition of the climbing experiences The Deschutes has requested additional information about the climbing experience at the Road 18 caves.

In addition to the provided in this submission, The Access Fund recommends that the Deschutes work with the Oregon Climbers Coalition to obtain better information about the history of use of climbs in the Road 18 Caves, and an understanding about the special qualities and environmental character that makes climbing at the Road 18 caves areas such a valued and experience in Oregon.

There are two distinct climbing opportunities that can be experienced at the Road 18 cave entrances. These can be described as sport climbing and bouldering. Out of the 10 caves included within the Road 18 Cave strategy, climbing opportunities have been available in three. The unusual geology and topography of the caves also provides a unique climbing experience in the cave entrances. Special characteristics of this climbing include the rock texture, unusual foot and hand holds, location, steepness, cool temperature, protected aspect, unusual ambiance, quiet setting in high desert environment.

The climbing opportunities can be summarized:
Hidden Forest Cave
Sport climbing in main cavern
Small bouldering site at entrance to squeeze hole through to Hidden Forest main cave.

Skeleton Cave
Bouldering site at entrance zone to cave
Charcoal #1 ( Note -Currently restricted ) 3 sport climbing routes at left side of cave entrance.

The climbing experience is an unusual example of the diverse climbing opportunities in the United States. The fact that the extent (scale) of the climbing is limited, and also that the sport climbing is of high technical standard and therefore not readily accessible to a broad cross section of the climbing community, does not alter its recognition as a unique and unusual climbing experience.

Description of climbing opportunities

The various types of technical climbing are generally defined by the characteristics of the experience.

Sport Climbing emphasizes movement of extreme difficulty, minimizing risk, and relatively short and uncomplicated approaches and descents. Sport climbing routes are
typified by bolt anchors and overhanging rock. Not all sport climbers place bolts Ö only the first ascent party places bolts, and all subsequent parties use these bolts.
Historically climbers have been responsible for determining when and where to place, and replace, bolts. Sport climbing typically involves short single rope length routes (i.e. < 50 meters). Climbs generally end at top fixed anchors where the sustained difficulty of the climb diminishes or the character of the rock changes. The climber descends, by being lowered or rappelling from the top anchors.

2. Bouldering

Bouldering is the term given to climbing that concentrates on short sequential moves on rock usually no more than 20ft off the ground. Typically falls are very short (a few
feet) and usually inconsequential, unless the climber makes a bad ground landing. Each climbable sequence of moves is called a boulder problem, and each boulder
problem varies in difficulty. Boulder problems are given different grades of difficulty. Climbers typically will try difficult moves many times before succeeding on a given boulder problem. Some use bouldering as practice for bigger climbs: others pursue it exclusively as a rewarding sport in its own right. Bouldering requires relatively little equipment other than rock shoes, chalk and sometimes the use of a bouldering 'crash pad'. Bouldering pads (4Ò by 3Ò and up to 5Ô thickness) may be placed below climbs to soften falls and lessen risk of injury from accidental bad landing on protruding rocks. Bouldering embraces a greater degree of risk than sport climbing, and a sense of freedom that derives from the focus on pure movement rather than on equipment.

Magnesium carbonate powder (chalk) is used by both sport climbers and boulderers to improve contact between fingers and rock. In steep, technically difficult , humid environments, the use of chalk is widely considered as essential for the activity to take place.

2.Organization of climber representatives

The Access Fund recognizes that the issue of climbing in the Road 18 Caves has been difficult in part because there has not been a consistent voice speaking for climbers. In any discussion concerning recreational use management and natural resource protection, communications are facilitated by working through an organized and representative user group. To this end the Oregon Climbers Coalition has been set up as a registered climbers organization. All correspondence can be directed through:

Chairman - Larry Brumwell.
Address: 550 SW Industrial Way #39, Bend OR 97702
Tel: 541 388 6764 Fax: 541 388 6764
The Access Fund has more than ten years experience in organizing and working with local grassroots groups of climbers, and we are pleased to help OCC become
established. In addition to our two organizations, the regional chapter of the American Alpine Club (Oregon section), and the Bend-based climbing club the Cascades
Mountaineers are available for consultation on climbing management and resource protection issues.

3. Analysis of climber effects on natural resource values of the Road 18 caves.

The Access Fund remains concerned about the analysis of climber effects on natural resource values in the Road 18 caves. Specifically, we see little correlation between
the actual resource impacts caused by climbers and the proposed management action. We suggest this is due to a lack of clarity regarding how and to what extent
climbers resource impacts affect cave values. While we recognize that considerable time and effort were spent by the Deschutes in preparing the Cave Strategy document, we believe that there may be two reasons for this lack of clarity.

3.1. Site-specific analysis for cave resource values.

The cave strategy document addresses resource values for the Road 18 caves by considering the ten caves as a whole. Without examining each cave on a case by case
basis for each of the values listed, then relating how the specific pattern of climbing activity in a linear zone specifically interacts with or affects the resource, we do not see that there is necessary baseline information to guide a management response which is the least intrusive to public use and enjoyment of the resource, as mandated in the Forest Service Manual. We suggest that a way of addressing this concern may be to complete additional survey/evaluation work in the areas where there is an information shortfall. This would entail site-specific surveys in the linear climbing zones in Charcoal, Hidden Forest and Skeleton Caves. Only once the pattern of climbing activity is fully understood, and then examined in terms of the contact zone of the activity with the specified resource values, will there be a clear understanding of user effect.

If the Deschutes will have difficulty finding the resources to accomplish this additional analysis, the Access Fund may be able to provide assistance through our
environmental grants program.

3.2. Context of cave values and integrity of sites

It is difficult to gain an understanding of the sensitivity of resource values, and of the integrity and restoration of cave resource values of the Road 18 caves, when they are
considered as an isolated group and not in the context of the extensive cave and natural resource values within the Newberry volcanic area. Comparing the Road 18 caves with the extent and condition of the overall resource in this regional context, will give us a better sense of the sensitivity and viability of vegetation, fauna, cultural and archaeological resources.

* See attachment A for examples of how further analysis would aid understanding and clarification of climber effects on Road 18 cave resource values.

4. Proposal for a management alternative to preserve a limited climbing experience at the Road 18 caves

The Deschutes indicated it would benefit from suggestions regarding a climbing management alternative to the current proposed actions for the Road 18 caves.

In our recent meetings, concerns expressed by Forest Service staff included personal responsibility of recreational visitors, accountability of visitors for their conduct, and
mechanisms by which numbers of climbers can be kept within agreed spatial limits.

The Access Fund recommends that any proposal that allows for climbing to take place and be managed at the Road 18 caves should draw on practices advocated by other recreational interest groups also using this area. These practices include individual responsibility, defined management guidelines, and a strict user code of conduct based on Leave No Trace principles.

There are a number of examples of climbing permitted through a briefing process within sensitive environments such as in back country wilderness desert and alpine zones. Canyonlands National Park and Rocky Mountain National Park operate a permit and orientation scheme for climbers staying overnight in these areas. Orientations include providing educational information on appropriate visitor conduct.

The Access Fund encourage discussion between the Deschutes and OCC to develop an alternative which would allow climbing to be permitted, but managed within
guidelines and a code of practice specific to the special resource protection requirements for the Road 18 caves.

Discussions on management alternatives should draw on the following suggestions identified through our recent meetings:

Identification of areas where climbing opportunities can be permitted on a trial and review basis. This could include a restriction on some climbing routes but not others
based on their proximity and how climbing activity affects specific cave resource values.

An orientation/briefing process for climbing visitors to the caves so that they can be informed and personally responsible on special use requirements.

Improved education outreach about the sensitivity of the area as a whole and the cave entrance areas through signage at trailheads and information sheets provided in local climbing outlets or through an orientation process. Outreach could cover specific guidance on issues such as parking, seasonal wildlife closures, vegetation sensitivity, restrictions on camp and stove fires, camping, domestic animals (dogs), access and approach paths, not leaving quick draws or other climbing equipment, respecting soil, rock and other cave resources, respect to other visitors, noise, human waste disposal.

* Examples of outreach materials and signage are attached to this submission Consideration of allowing hand-drying agents in limited areas subject to whether the primary concern about their use is visual or physical effects.

Consider alternative products and practices to reduce effects.

Camouflage existing permitted anchors though assistance from OCC.

Establish protection zones around sensitive vegetation communities, boulder accumulations and soil deposits to reduce disturbance from general visitor use using
techniques such as signage, natural materials and path diversion where appropriate.

Rock art Identification of extent of rock art at Hidden Forest and discreet signing showing boundaries of protected zone. Suggest use of Access Fund/OCC names to
indicate user group support of restricted access. In addition consider possible diversion and identification of alternative approach path at Hidden Forest Cave.

Establishment of regular climbing liaison meetings between Deschutes National Forest and OCC to monitor and evaluate the effectiveness of a permitted climbing
arrangement.

Establishing a record of climber/volunteer activities and initiatives to record site meetings, efforts to look after the cave environment through litter cleans ups and outreach
initiatives.

Consider additional funding sources such as the Access Fund Environmental grants program to assist with funding costs for some of the above initiatives.

5. Agency contacts for climbing and resource management

The Deschutes inquired whether the Access Fund could provide agency contacts and management examples of similar situations involving cave values and climbing
management.

The situation in the Newberry volcanic area is unique, and the management direction needs to be tailored to the specific conditions of this area.

The Access Fund cannot provide examples of similar situations involving cave entrances, although some of the issues such as cultural resources, wildlife, and vegetation
sensitivity are commonly experienced by resource managers in other areas. We have worked closely with the Forest Service and other federal land agencies on related
issues around the country. The following contacts are representative of some recent collaborative work and may be able to provide useful feedback to inform the Road 18
caves decision-making.

Donnie Richardson Ö District Ranger, Stanton Ranger District Daniel Boone National Forest, KY Tel: (606) 663 2852 coordinated Forest Service interdisciplinary team in
turning around a divided user group/agency situation into an established agency user group working relationship and effective management program (issues Ö access,
archaeological sites, vegetation, trails, fixed anchors, education outreach)

Cecile Ison Ö Archaeologist, Daniel Boone National Forest, KY Tel: (859) 745 3138

Joe Pollini Ö Recreation Manager, BLM Proposed Wilderness study area Volcanic Tablelands, Bishop Feild Office, CA Tel: (760) 872 4881 (rapid growth in popularity of
bouldering area Ö issues included cultural resources (rock art), minimal publicity policy for agreed climbing areas, code of practice for use of sensitive environment)

Tom Skinner Ö Wildlife Biologist, Coronado National Forest, AZ Tel: (520) 670 4535 (seasonal wildlife restrictions, turning around a divided user group/agency situation into an effective management program) Lori Denton Ö Recreation Planner, Coconino National Forest, Peaks Ranger District, AZ Tel: (520) 526 0866 (climber visitor and use
surveys, trails)

The Access Fund again thanks the Deschutes National Forest for the opportunity to comment on the management strategy and proposed environmental assessment for the Road 18 caves. The climbing opportunities in these caves, while quite limited, are unique and compelling enough to merit a comprehensive analysis of the importance of the opportunities to climbers, and the effects of climbing on cave values, both on a cave by cave basis and in the context of the regional cave resource. We hope our remarks are received in the spirit of cooperation with which they are submitted, and we welcome the opportunity to discuss in greater detail planning alternatives and possible scenarios under which some climbing could be preserved in the Road 18 Caves.

Sincerely

Kath Pyke

Conservation Director

cc:
District Ranger Ö Bend Fort Rock Ranger District
Forest Supervisor Ö Deschutes National Forest
Oregon Climbers Coalition

* Encs.

Attachment A
Examples of how further analysis could aid understanding and clarification of climber effects on Road 18 cave resource values.

Of the 10 caves considered within the Road 18 Caves EA we suggest the following additional analysis at the three caves (i.e. Skeleton, Charcoal #1 and Hidden Forest) that have climbing recreation opportunities. Any analysis should also take into account effects from other users, and cumulative disturbance affects from past history of
non-climbing use. We also suggest that effects from climbing are evaluated following a schematic approach. This method has proved helpful for analysis of climbing effects in other public lands areas.

Schematic breakdown of the stages of a climbing visit
Approach path to the climbing area from the trailhead
Base of climb (staging area)
The vertical part of the climb (linear climbing zone)
The descent from the climb
The exit path from the climbing area to the trailhead

Cave Resource values

1. Vegetation. Unless there has been a detailed survey of what species are present at each cave on the approach path taken by climbers, other visitors, and at the base of the specific climbs we are unable to assess what effects climbers versus other visitors are having on the vegetation communities and consequently what measures may or may not be necessary to mitigate trampling effects and allow restoration efforts.

2. Invertebrate fauna. The boulder accumulations within the cave entrances and further back into the caves are stated as important habitat for invertebrates. Clarification is
required on what species are present in each of the 3 sites where climbing has taken place, and which areas are more sensitive than others. Unless this level of information is available we cannot assess how climbers versus other users maybe affecting invertebrate fauna viability, and consequently introduce management measures such as zoned off areas to protect sensitive populations.

3. Bat populations

The Access Fund is supportive of seasonal climbing restrictions to protect bat populations, although usually there is an emphasis on maternity colonies. In our
organizations support of seasonal wildlife closures we standardly share information (as much as it is available) with agencies on species sensitivity to disturbance,
breeding success and population viability for the area in terms of local, state and regional context. In the Road 18 Caves situation we have not been able to gain a thorough understanding of the situation. We understand that in Stookey Ranch Cave the bat population represents over 60% of the Central Oregon population for that species. We would like to ask what percentages of the cave resources do the different bat populations and species require. If their protection is driven by T& E listing under federal protection laws this should be made clear. However if there is a balance to be achieved between percentage of resources protected and visitor access to other sites, this requires further discussion in terms of regional USFS bat protection policy.

Cave soils

Cave soils have been highlighted as a special value associated with the Road 18 Caves. However we were unable to obtain a clear understanding as to which caves held
more sensitive deposits than others, where these sites are located within the caves, and how much their value and site integrity had been changed through previous human use and disturbance of the sites. Unless this information is available we cannot ascertain how climbing affects soil values, by relating where any trampling or disturbance from climbing may take place in relation to the sensitive areas.

Archaeological/Cultural

The Access Fund recognizes that there are confidentiality issues in discussing sites with sensitive cultural and archaeological values. However, without some broad degree of information sharing on these issues, we cannot identify how climbing might be affecting resource values. For example at Charcoal Cave #1 it was not clear what agency or organization is conducting the current archaeological survey, nor the time scale for completion. Without information about what sections of the cave they are examining we cannot correlate how climbing activity may be affecting these values. The Access Fund standardly supports zoning off areas to protect cultural interest. However these situations focus on specific sites rather than an entire area unless there is justification about disturbance to warrant complete restrictions on access.

Chalk and geology values

The Access Fund would encourage a more thorough analysis of the effect of chalk on geology and visual values for the three caves in question. There is limited information about how chalk interacts with rock surfaces. The study by Donnie McGowan in Climbing magazine (April 1987) that is sometimes referenced in these discussions has been questioned by subsequent authors (Stuart Swineford, August 1994, Rock and Ice magazine).

For each of the caves we recommend clarification over whether chalk is a visual or physical effect concern. At Skeleton Cave, a past history of fires and soot blackened
walls questions concerns about use of chalk affecting carbon dating potential. At Hidden Forest Cave, natural calcite secretions can be confused with chalk deposits. If
chalk or climbing activity is affecting fragile geologic features we recommend that individual climbing routes be surveyed within their linear zones. OCC would be able to
provide roped assistance so that someone with relevant expertise could closely examine the cave walls. At Charcoal Cave #1, chalk use would not be apparent to public
users due to the distance of this site from the public trail.

The Access Fund welcome working with THE DESCHUTES to examine options to reduce visual effects of chalk through regular chalk clean ups following prescribed agency guidelines, methods to minimize chalk use and spill such as use of chalk balls, and potential use of hand drying agent alternatives for the most visible sites.

Fixed Anchors

Fixed anchors are standardly used by cavers to access cave systems. Any discussion of climbing use of fixed anchors in cave entrances should not lose sight of this fact. In terms of potential damage to the rock, an evaluation needs to be made of total rock area affected, whether fixed anchors affect rock integrity, whether their placement damages any fragile geologic structures. In terms of visual intrusion this discussion should also be place in context with other features. For example metal ladder access to Skeleton Cave. Fixed anchors can be effectively disguised by camouflage techniques. The Access Fund does not condone leaving quick draws in place after climbing use and the climbing community would be expected to take away all removable items of climbing equipment after a visit.

Access Fund comments (7/7/00)

Provided by Kath Pyke
Conservation Director Access Fund