ROAD 18 CAVE PROJECT

ENVIRONMENTAL ASSESSMENT

CHAPTER II - ALTERNATIVES

I. SCOPING
The scoping process identifies public, Forest Service and other agencies issues regarding a proposal to implement an action. Public scoping was initiated early in the process by including this project in the spring, summer, fall and winter (2000) editions of the Schedule of Projects (SOP) for the Ochoco and Deschutes National Forests and the Prineville District of the Bureau of Land Management. Letters were mailed to the Project mailing list requesting comments on the Proposed Action (April 4, 200). Public comments are used by the IDT to identify issues, further develop the proposed action and develop alternatives to the proposed action. There were 71 responses to the scoping letter. Thirty seven of the responses came in a form letter, two from WillametteValley Grotto, one from Bat Conservation International, one from Wanderlust Tours, two from the Access Fund, four phone conversations, nine e-mails and fifteen individual letters.

The following comments were made to the proposed action-scoping letter:

a. Form Letters
The form letters requested that "sport climbing" be allowed in Charcoal #1 and Hidden Forest Caves. They requested the use of bolts and drying agents (chalk) be considered as viable parts of climbing. They felt using colored chalks, like gray or black, could minimize the visual impact of white chalk. They do not believe chalk is detrimental to rock's integrity. They urged working together to work out a compromise.

b. Caving Organization
Willamette Valley Grotto wrote two letters. In the first letter their position is that damage is caused by the use of bolts in caves. They feel the placement of bolts in the entrances of caves to facilitate sport climbing violates the Federal Caves Resources Protection Act and established caving ethics. In the second letter, they requested permission to remove the bolted climbing anchors from Charcoal and Hidden Forest Caves. Their position is that rock climbers have had, and will continue to have, a negative impact on the caves and cultural resources, requiring continued monitoring and active management.

c. Climbing Organization
The Access Fund is concerned that sport climbing had been singled out in the EA as an especially undesirable recreational use of the caves, in terms of resource impacts and alleged conflict with aesthetic values. They felt this was a bias based on not enough evaluation of the caves as a unique climbing opportunity. Their position is that climbers are not entirely responsible for all the illegal or inappropriate activities in the caves. They felt the EA should consider in more detail how climbers would be affected by a proposal that would eliminate all climbing in the Road 18 caves.

They feel the EA should analyze how the values (wildlife, cultural, plants and geology) have diminished below the specified described values and what their potential is for restoration. It is not clear what value these specific caves have in relation to other lava tube cave resources in Central Oregon.

They would like to see an alternative that allows sport climbing in at least one of the caves on a trial basis. They believe there is little proof that hand-drying agents constitute excavation, damage, or removal of cave resources as per the Federal Cave Resources Protection Act. They suggest that prohibiting the mere possession of hand drying agents in the Road 18 caves may infringe on basic legal rights of cave visitors.

Their second letter was a follow up to the field and office meeting on June 19 & 20, 2000. This meeting was held to acquaint the Access Fund with the proposal for this project and familiarize them with the process for completing it.

d. Wildlife Organization
Bat Conservation International Inc. (BCI) felt that bats have lost their traditional roosts in caves due to human disturbance and commercialization. They would like to have parking areas at Skeleton and Wind caves relocated away from the caves to limit disturbance. They agreed with all the proposed management goals in the proposed action and suggested a seasonal closure at Charcoal Cave to monitor the brown bat maternity colony.

e. E-mail Comments
Most of the email comments were concerned that access for the elderly would be restricted. They also wanted to have enough parking and turn-a-round or drive through area for a pickup and horse trailer. There were concerns that rock climbers were defacing the caves by using chalk, bolts and prying rocks out of the cave ceilings. One commenter thought the Forest Service should use photo monitoring at each of the caves to monitor and lessen impacts caused by visitors. They also wanted the trails inside the caves marked better so people would stay on the right paths. One commenter wanted to remove the existing bolts at the caves. One commenter was concerned that all the caves would be put off limits to sport climbers forcing them to find and use other caves not on maps and felt this treatment was unjust.

f. Individual's Letters
Commenter (#42) supports moving the parking areas away from the cave entrances to discourage drinking parties. He supports the removal of bolts from all the caves to lessen impact on wildlife.

Commenter # 44 did not support imposing restriction at the caves. Instead he thought the Forest Service should redirect the money planned for the kiosks and hire a person to supervise the activities at the caves increasing the odds of making those destructive individuals responsible for their actions.

Commenter # 45 does not want access limited and felt if cars had to be parked further away they could be vandalized easier. He felt that limiting access would discriminate against low income or single parent families. He feels that limiting access will not stop vandalism, just move it somewhere else.

Commenter #46 felt that sport climbing should be allowed in the caves and sport climbers should not be classified as hooligans.

Commenter #47 felt the proposed action is biased against spelunkers and discriminates against sport climbers. He felt the Forest Service should build a relationship with the sport climbing community and work with them to clean up or do other work around caves. At Skeleton Cave, he felt the parking lot should be at least 1/2 mile from the cave entrance. He felt it should be permissible to move the rocks to allow sport climbing, and allow hand-drying agents until it is proven to destroy the rock. He thought climbing should only occur in the mouth of the cave where sunlight shines. At Hidden Forest Cave he thought the parking area should be 1/2 mile from the entrance of Arnold Ice Cave. Existing bolts and maintenance of the bolts should be allowed as well as allowing the painting of existing bolts to hide any reflection. He felt the entire south wall should be open to climbing and allow climbing only in the mouth of the cave.

Commenter #48, felt that parking areas should be 1/2 mile from cave entrances, include kiosks, improve paths to the most scenic caves, improve trails to those cave floors that are already accessible, remove the existing steel ladders, replace rocks piled on the floor by past rock concert and partygoers. He felt that bolting on a few specific routes should be allowed and a few warm up bouldering routes allowed. He thought the Forest Service should find and designate some of the one hundred cave entrances that can be used for just advanced climbing and keep the areas clean with the help of users.

Commenter #58 had several comments relating to caves and cave management. He thought the EA discouraged recreation use. He claims that caves are part of a cultural landscape and urban landscape and no longer a part of a natural landscape. He thinks that smoke in caves, whether from campfires, wildfires or smoking, is inhaled into the caves and affects the vadose zone. The vadose zone is the subsurface open space in the earth's crust above the ground water level.

He felt that educating the public about the effects of litter, use of liquids (washing cave walls); and the effects of graffiti on resources would be a good idea in minimizing or preventing damage to cave resources. He was concerned that installing gates at cave entrances could prevent good airflow and animal use.

He said if Stookey Ranch Cave is the major bat hiberniculum, why would the Forest Service place restrictions at Wind Cave to protect Western big-eared bats?

He was concerned that relocating parking lots could affect handicap use and not meet ADA if travel distance exceeds 1/4 mile.

He wondered why the Forest Service would eliminate climbing, the use of chalk and bolting.

He asks the IDT to define and demonstrate a microenvironment and effects on it.

He wonders why these caves are considered unique when we have over 450-named lava tube caves in Oregon. He says the plant community around caves is not unique, but common.

He doesn't believe that restoration of caves is realistic.

Commenter #66 thought the caves should be less accessible to minimize vandalism. Thought if groups like the Boy Scouts visited the area they and their leaders should be educated to not disturb or destroy cave resources.

II. ISSUES AND MEASURES
The scoping process for the Caves Environmental Assessment, including public involvement, identified a total of four issues related to the proposed action. The issues, together with applicable laws, regulations, and policies, were used as alternative design criteria. The ability of how each alternative addresses each issue involves the use of "key indicators" or "measures of responsiveness" (measures). Measures were used in this analysis to clarify and compare the difference between alternatives and not as a strict quantitative measure of environmental effects. Measures must be taken in context when interpreting effects.

Issue 1 -Access to Caves
The proposed action would relocate parking areas at Boyd, Skeleton, and Wind Caves and make access to the caves non-motorized use only. Most visitors would be required to walk the closed road to access these caves. There would be an ADA trail built at Boyd Cave with a road to trail project. Trails would be self discovery with no system trails developed. There is a concern that relocating the parking areas from proximity to the caves would compromise safety and encourage theft and vandalism to vehicles. The new parking areas would not be large enough to accommodate the parking of vehicles towing horse trailers or large RVs. Relocating parking areas and not developing system trails would discourage the elderly and handicapped from viewing the caves or accessing the area.

Units of Measure -
Distance of parking areas to caves.
Parking capacity/design of parking areas to accommodate horse users and large RV's.
ADA Accessible.

Issue 2 - Availability of climbing opportunities.

The proposed action would reduce the type, variety and location of climbing opportunities at several of the Road 18 caves. The elimination of chalk use and the removal of bolts from caves and routes would prevent climbing activities.

Unit of Measure - Availability of climbing opportunities by alternative (bouldering and sport climbing).

Issue 3 -Effects of activities at each cave on wildlife (bats) habitat and populations.
Increased use at the caves by recreationists may be negatively impacting bat species that use the caves. Despite seasonal closures that have been implemented at several caves during maternity and hibernation periods, many cave users continue to ignore these closures, and disturb bats during the critical periods. Alternative 3 addresses this issue with gate installations and hibernation period closures.

Unit of Measure -
Timing of disturbance to bat species by alternative. Timing of disturbance includes maternity, hibernation, and day/night roosting.

Issue 4 - Inappropriate Cave Use
Currently, all of the caves in the project area are listed as significant caves as per the Federal Cave Resources Protection Act. Most of the caves receive moderate use from a variety of visitors seeking a variety of experiences. The most inappropriate or impactive activities are those that destroy or alter cave resources, such as: acts of vandalism, graffiti and spray painting, dumping garbage or litter, removal or damage of cave resources, or other such destructive behaviors or activities.

The extent to which these activities alter or damage the cave resources varies with the type of activity, the location of the activity in reference to cave resources, and the amount of alteration of the condition of the cave that results from the activity. Providing measures to counter these activities is key to reducing and/or eliminating their effects.

Unit of Measure -
The distance from the parking area to the caves.
Availability of cave conservation information.

III. ALTERNATIVE DESCRIPTIONS

Alternatives are designed to move towards the desired condition specified in the Forest Plan consistent with the standards and guidelines in that Plan.

A. Alternatives Considered But Eliminated From Further Analysis
1. An alternative was considered that would allow the use of hand drying agents. However, not knowing, or likely ever knowing (due to trade secrets, competition between companies) what the chemical make-up of the agents are, or if there are potential effects on biological and physical resources, hand-drying agents would not be allowed until such effects are better documented.

2. Another alternative was considered that would restrict or eliminate public use of the caves. This was eliminated because it would not meet the Federal Cave Resources Protection Act for providing recreation opportunities at caves.

3. Another alternative considered would have installed a fee system for cave use or visitation. This was considered impractical at this time as it could make the Forest Service liable for any mishap or injury while visiting the caves. Also, the Forest Service does not have the personnel or budget to implement a fee system and projected revenue would not cover the cost of operations due to the low/moderate use of the caves.

B. Actions Common To All Alternatives
The Federal Cave Resources Protection Act states, "Any person who, without prior authorization...knowingly destroys, disturbs, defaces, mars, alters, removes or harms any significant cave or alters the free movement of any animal or plant life into or out of any significant cave located on Federal lands, or enters a significant cave with the intention of committing any act described in this paragraph shall be punished in accordance with subsection (b) Punishment." To comply with this, any existing bolts would be removed and scars rehabilitated. The placement of any new unauthorized bolted climbing routes would not be allowed. Other actions that occur in the caves that fall into this definition would also not be allowed. The removal of bolts and the rehabilitation of the scars would return the caves to a more natural condition, while removing impacts to cave resources.

Similarly, the current restriction on the use of hand-drying agents, including chalk, would be put into effect permanently. Chalk and hand-drying agents could be ingested by wildlife, especially bats, that could be dangerous to their health. Because of the uncertainty of the chemical make-up of hand-drying agents, or their potential affect on wildlife, this measure would remove any potential threat to wildlife or invertebrate species that rely on caves to survive. If further evidence or research indicates there is no or negligible effect, this restriction could be removed in the future.

The preceding would occur regardless of which alternative is selected by the Deciding Official. Alternative C would be the exception to this, where some bolted climbing routes would be authorized.

Under the action alternatives, the following activities would occur:

• For caves with parking facilities, institute a self-issuing permit program to collect information on the visitor's name, purpose, number in party, comments and use patterns. There would be cave information and proposed cave etiquette on the permits or information board.
• Should the need arise; allow additional Special Use tours under authorized permit. Permittees should display a public need with an approved operating plan. Limit existing and future group size to 6-8 people at one time and no more than three tours per cave per day. Appropriate caves for this activity include Boyd, Skeleton, and Wind. Permittees would be responsible to include cave sensitivity/conservation etiquette for each group. Other special uses, such as movie making, would be authorized on a case-by-case basis.
• Restrict access to foot traffic only to promote public safety and to protect cave resources. Do not allow mountain bikes, horses, or motorized vehicles in caves. Continue to evaluate new recreational attractions and make recommendations based on impacts to cave resources and visitor safety.
• Prohibit use of internal combustion engines (such as generators) in caves.
• Prohibit the use of glass containers within caves to reduce litter and provide a safer environment to visitors.
• Maintain current populations of unique plant species in and near cave entrances by encouraging foot traffic in designated areas only.
• Add the wording " . . .and possession of" to the ban on use of hand drying agents {36 CFR 261.9 (a)(j)}.
• Prohibit possession and use of alcoholic beverages as defined by state law in all caves. Current restrictions are from sunset to sunrise
• To provide multi-agency consistency with seasonal closure periods, hibernacula closure dates would be October 15 to May 1. Maternity closure dates would be April 15 to September 30.

C. Alternative A - No Action
The no action alternative is a baseline by which to measure relative changes that would result from implementation of the action alternatives. Under this alternative, the proposed project would not take place. There would be no self-issuing permits. There would be no limit in the number of people who could use the caves at any one time. Visitors would continue to access the caves from the current parking areas. The lack of enforcement personnel and education kiosks would contribute to continuation of inappropriate use of cave resources.

D. Alternative B - Proposed Action
Under the proposed action the existing bolted routes in caves would not be authorized and bolts would be removed. It would also authorize a restriction on the use of hand-drying agents. The restriction on hand-drying agents, chalk and bolting is in accordance with the regulations for preventing damage to significant caves and cave resources.

Alternative B would define parking areas and trails that minimize the adverse impacts to vegetation and habitat near cave entrances. This would improve the vegetative and scenic quality at Boyd, Skeleton, Wind, Hidden Forest and Arnold Ice caves.

Alternative B would restore some cave resources to a more natural state and maintain others. For example, efforts to define parking areas and foot paths would improve or restore vegetation conditions, while relocating parking areas would reduce impacts from vandals which would in turn maintain the caves for future generations.

Alternative B would relocate the parking area for Boyd Cave to Road 18. The new parking area would accommodate large RVs and horse trailers. Also, the relocation of Skeleton and Wind parking areas would act as a deterrent for those dumping garbage or otherwise vandalizing cave resources. The caves would still be available to hikers, and other non-motorized visitors. (See Appendix C)

Under the proposed action an information kiosk would be installed at the Boyd Cave parking area/trailhead near Road 18. The kiosk would direct visitors to the caves. Also, an advance notice sign would be installed on Road 18 to inform travelers of the kiosk. Bold lettering that states "Cave Information" would identify the kiosk. It would provide useful cave information such as existing closures and "leave no trace" ethics. The kiosk would inform visitors of cave etiquette and restrictions and provide information to promote a better understanding and appreciation for caves and caves resources. Self-issued permits for Boyd, Skeleton, Wind and Arnold Ice caves would be available at the Kiosk. (See Appendix D)

A bat gate would also be installed at Charlie-the-Cave to protect and maintain bat habitat.

In Charcoal Cave #1 a year around closure order would remain in place until further analysis is completed.

Deg Cave would be closed year-round to reduce confusion to the public on the availability of this cave for exploration. Currently, Deg Cave is open from 45 days in the fall. With the proposal to change closure dates, the availability of this cave to the public would be reduced 15 days.

The following table summarizes the proposed actions on a cave-by-cave basis.

Table 1: Proposed Actions by Cave.

Alternative C
All actions identified in the proposed action would be the same as Alternative B except for the following:

• Boyd Cave: The parking area would not be relocated. It would remain at the current location but barriers to eliminate motor vehicles driving near the cave entrance and over vegetation would be improved. Based on comments received from the public, the parking lot would be better defined to accommodate large RVs and vehicles towing horse trailers. A trail would be improved to provide a defined footpath to the cave entrance. The area would remain open for equestrians using this site to ride shorter loop trails rather than those using the Horse Butte Trailhead. It would also provide closer/easier access for disabled and elderly visitors.
• Skeleton Cave: The alteration of rocks on the floor of Skeleton Cave would be designed to provide for public/climber safety, but in a manner that would be more natural appearing (to be determined by the Forest Service, spelunkers, and the local climbing community). There would be a seasonal closure during the bat winter hibernation period (October 15 - May 1).
• Wind Cave: Two bat gates would be installed. One at the main entrance to the cave and one at the skylight area to improve habitat conditions for the western big-eared bat. The gate at the main entrance would be locked during the bat winter hibernation period (October 15 - May 1).
• Hidden Forest Cave: Completed existing bolted routes would be authorized for climbing. Incomplete routes would be removed. New climbing routes would not be authorized in this or any other cave in the project area.
• Bat Cave: Two bat gates would be installed. One at the main entrance to the cave and one at the skylight area to improve habitat conditions for the western big-eared bat. The gate at the main entrance would be locked during the bat winter hibernation period (October 15 - May 1).

The following table compares the Issues by cave and Alternative.

Table 2 - Issues Comparison by Alternative.

*Although seasonal closures are in place, disturbance currently occurs and is expected to continue to occur by a small segment of the population.

**New seasonal restriction (hibernation) would be implemented. Similar to other caves where seasonal closures are in place, disturbance would occur by a small segment of the population.

+Gates would be placed at these cave entrances and closed during the hibernation period.

IV. MITIGATIONS
The following mitigation measures would be applied to all the action alternatives whenever the applicable site-specific conditions are present.

Mitigation Measures Common to All Action Alternatives
a. Wildlife

Activities associated with alternatives B and C (parking access changes, cave gate installation) should not occur during the period from December 1 through March 31 to reduce disturbance to wintering big game.

Cave closures for hibernating bat colonies (October 15 - May 1) would include a closure buffer of 300 feet. Activities from alternatives B and C should not occur at Skeleton or Wind caves during this time period.

Heavy equipment would not operate within 100 feet of a cave opening and not within 100 feet of a cave's underground passage (to be identified during project implementation). The objective is to avoid collapsing the cave.

b. Noxious Weeds
Use contract provisions for equipment cleaning.

Seed areas of disturbance with native plant species.

Monitor project work areas during and after work is completed and pull weed populations as necessary.

c. Cultural Resources
To reduce the possibility of destroying resource information by humans with easy access to historically important areas, dispersed roads would be closed by natural means, such as placing boulders and other means which would not disturb the surface layer of soil.

GOTO:

• Chapter I
• Chapter III
• Chapter IV
• Appendix A
• Appendix B
• Appendix C
• Appendix D

Deschutes and Ochoco National Forests Website
http://www.fs.fed.us/centraloregon/manageinfo/nepa/documents/bendfort/caves/chapter2.html
Last Update: 6/6/01
R.A. Jensen