National Trail Classification System, FSM 2350 and FSH 2309.18, 61600-61647 [E8-24193]

Agencies

• DEPARTMENT OF AGRICULTURE
• Forest Service

[Federal Register Volume 73, Number 201 (Thursday, October 16, 2008)]
[Notices]
[Pages 61600-61647]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-24193]



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Part VI





Department of Agriculture





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Forest Service



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National Trail Classification System, FSM 2350 and FSH 2309.18; Notice

Federal Register / Vol. 73, No. 201 / Thursday, October 16, 2008 / 
Notices

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DEPARTMENT OF AGRICULTURE

Forest Service

RIN 0596-AC47


National Trail Classification System, FSM 2350 and FSH 2309.18

AGENCY: Forest Service, USDA.

ACTION: Notice of issuance of interim final directives and public 
comment period.

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SUMMARY: The Forest Service is issuing these interim final directives 
as an amendment to Forest Service Manual 2350, Trail, River, and 
Similar Recreation Opportunities, and Forest Service Handbook 2309.18, 
the Trail Management Handbook, to incorporate revisions to the agency's 
national trail classification system (TCS), consisting of the Trail 
Classes and Design Parameters. Chapters 30 and 40 in the Trail 
Management Handbook have not been included in these interim final 
directives because these chapters do not relate directly to the TCS and 
Design Parameters and because the agency plans to update them 
significantly. The comments on these chapters will be addressed in 
preparation of final directives. The agency is providing a 60-day 
public comment period on these interim final directives and will review 
timely comments in developing final directives.
    Trail Classes are general categories reflecting trail development 
scale, arranged along a continuum. Managed Uses are the modes of travel 
that are actively managed and appropriate on a trail, based on its 
design and management. Designed Use is the Managed Use of a trail that 
requires the most demanding design, construction, and maintenance 
parameters and that, in conjunction with the applicable Trail Class, 
determines which Design Parameters will apply to a trail. The Design 
Parameters are technical guidelines for the survey, design, 
construction, maintenance, and assessment of a trail, based on its 
Designed Use and Trail Class.

DATES: These interim final directives are effective October 16, 2008.

ADDRESSES: The interim final directives and this Federal Register 
notice are available electronically on the World Wide Web at https://
www.fs.fed.us/recreation/. The record for these interim final 
directives is available for inspection and copying at the office of the 
Director, Recreation, Heritage, and Volunteer Resources Staff, USDA 
Forest Service, 4th Floor Central, Sidney R. Yates Federal Building, 
1400 Independence Avenue, SW., Washington, DC, from 8:30 a.m. to 4 
p.m., Monday through Friday, except holidays. Those wishing to inspect 
the record are encouraged to call Jonathan Stephens at (202) 205-1701 
beforehand to facilitate access into the building.

FOR FURTHER INFORMATION CONTACT: Jonathan Stephens, Recreation, 
Heritage, and Volunteer Resources Staff, USDA Forest Service, (202) 
205-1701.

SUPPLEMENTARY INFORMATION: 

Table of Contents

1. Background and Need for the Interim Final Directives
2. Public Comments on the Proposed Directives and Agency Response
     Overview of Comments
     Response to General Comments
     Response to Specific Comments by Section
    [cir] FSM 2350
    [cir] FSH 2309.18
     Response to Comments on Regulatory Certifications in 
the Proposed Directives
     Comments Beyond the Scope of the Proposed Directives
3. Comparison of the Pack and Saddle Trail Guides and the Pack and 
Saddle Design Parameters
4. Summary of Revisions to the Trail Class Matrix and Design 
Parameters
5. Regulatory Certifications for the Interim Final Directives
     Environmental Impact
     Regulatory Impact
     No Taking Implications
     Civil Justice Reform
     Federalism and Consultation and Coordination with 
Indian Tribal Governments
     Energy Effects
     Unfunded Mandates
     Controlling Paperwork Burdens on the Public
6. Access to the Interim Final Directives

1. Background and Need for the Interim Final Directives

    The Forest Service is responsible for managing 193 million acres of 
National Forest System (NFS) lands. On these lands, approximately 
144,000 miles of NFS trails are managed by the Forest Service. An NFS 
trail is a forest trail other than a trail which has been authorized by 
a legally documented right-of-way held by a State, county, or other 
local public road authority (36 CFR 212.1). A forest trail is a trail 
wholly or partly within or adjacent to and serving the NFS that the 
Forest Service determines is necessary for the protection, 
administration, and utilization of the NFS and the use and development 
of its resources (36 CFR 212.1). Design, construction, operation, and 
maintenance of NFS trails fall under the authority of Forest and 
Grassland Supervisors.
    Since at least 1991, the directives have included three categories 
for classifying NFS trails based on their difficulty level. These 
categories, which are enumerated in the Forest Service Handbook (FSH), 
are most difficult, more difficult, and easiest. In addition, since 
1991, the FSH has contained technical guidelines, called trail guides, 
for specific types of uses, including hiking and pack and saddle use. 
For each of the three difficulty levels, each trail guide contains 
design, construction, and maintenance guidelines for the physical 
characteristics of trails. The physical characteristics include maximum 
pitch grade and length, clearing width and height, tread width, and 
surface. The difficulty levels in the trail guides encompass trails 
ranging from the least developed, which are typically steep or narrow, 
to the most highly developed, which are typically wide with minimal 
grades.
    Trail management and use were (and still are) based on the 
management intent for the trail, as determined by the applicable land 
management plan, applicable travel management decisions, trail-specific 
decisions, and other related direction. When local managers identified 
a trail's management and use, they identified the applicable difficulty 
level. Once managers determined the applicable trail management and use 
and difficulty level, applicable technical guidelines from the 
appropriate trail guide could be identified.
    In 1994, the Forest Service implemented a trails database module 
that included numerous trail attributes, including the three difficulty 
levels of most difficult, more difficult, and easiest, and the three 
trail classes of way, secondary, and, mainline. However, the classes of 
way, secondary, and mainline incorporated into the database did not 
correlate directly with the difficulty levels in the FSH.
    In 1998, the Forest Service determined that a more uniform and 
integrated national trail classification system would improve inventory 
and on-the-ground management. Consequently, in 1999 the Forest Service 
transitioned from the three trail classes of way, secondary, and 
mainline to the five Trail Classes in effect today. The five Trail 
Classes are keyed more precisely to the physical characteristics of NFS 
trails and more accurately stratify them for various purposes, 
including database inventory, development of land management planning 
objectives, visitor information, and assessment of costs. In general, 
the five Trail Classes encompass many of the attributes and 
characteristics of the

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previous way, secondary, and mainline trail categories.
    In 2000, the Forest Service launched a national effort to enhance 
its trail program, including improving inventory, tracking of trail 
condition and needs, and accuracy and accountability of costs; 
minimizing confusion and inconsistency in terminology and 
interpretation of guidance; and improving the communication, quality, 
and utility of trail data. As a result, the agency refined five 
concepts that are now collectively known as the ``Trail Fundamentals,'' 
including Trail Type, Trail Class, Managed Use, Designed Use, and 
Design Parameters. The Trail Fundamentals provide an updated and more 
effective means for consistently recording and communicating the 
guidelines for trail design, construction, maintenance, survey, and 
assessment.
    The Trail Fundamentals integrate the five Trail Classes with 
technical guidelines, called Design Parameters, for the design, 
construction, maintenance, survey, and assessment of NFS trails. The 
Design Parameters, which were implemented in 2004, superseded the 
technical parameters in the Trail Guides in the FSH. When the agency 
shifted from the Trail Guides to the Design Parameters, the design, 
construction, and maintenance guidelines changed in minor, technical 
ways with no effect on how trails were managed on the ground.
    The following provides a description of Trail Class, Managed Use, 
and Designed Use, the three Trail Fundamentals that were most critical 
to development of the TCS and Design Parameters.

Trail Class

    The current Trail Classes range from Minimal/Undeveloped (Trail 
Class 1) to Fully Developed (Trail Class 5):
    Trail Class 1: Minimal/Undeveloped Trail
    Trail Class 2: Simple/Minor Development Trail
    Trail Class 3: Developed/Improved Trail
    Trail Class 4: Highly Developed Trail
    Trail Class 5: Fully Developed Trail
    Each Trail Class has descriptors for the physical characteristics 
of trails, including tread and traffic flow, obstacles, constructed 
features and tread elements, signs, and typical recreational 
environment and experience.

Managed Use

    A Managed Use is a mode of travel that is actively managed and 
appropriate on a trail, considering its design and management. There 
may be more than one Managed Use per trail or trail segment. As 
indicated by use of the word ``actively,'' the term ``Managed Use'' 
reflects a management decision or intent to accommodate a particular 
use through trail design, maintenance, and management. As with the 
previous classification system, the applicable Managed Uses of a trail 
are based on a trail's management intent. A trail's management intent 
is determined by the applicable land management plan, applicable travel 
management decisions, trail-specific decisions, and other related 
direction.
    The concepts of Trail Class and Managed Use are interdependent. 
Determining the desired development scale or Trail Class requires 
consideration of the Managed Uses of a trail. Likewise, determining the 
Managed Uses of a trail requires consideration of the development scale 
of the trail. Therefore, the applicable Trail Class is usually 
identified in conjunction with the Managed Uses of a trail.

Designed Use

    The Designed Use is the Managed Use of a trail that requires the 
most demanding design, construction, and maintenance parameters. The 
Designed Use, in conjunction with the applicable Trail Class, 
determines which Design Parameters will apply to a trail.
    While there may be more than one Managed Use, there can be only one 
Designed Use per trail or trail segment. For example, if a trail has a 
Managed Use of Hiker/Pedestrian and Pack and Saddle, Pack and Saddle 
would be the Designed Use or design driver because it requires more 
stringent trail design, construction, and maintenance parameters.
    Once the Trail Class, Managed Uses, and Designed Use are determined 
for a trail or trail segment, the corresponding set of technical 
guidelines or Design Parameters can be applied.

Design Parameters

    The Design Parameters are technical guidelines for the survey, 
design, construction, maintenance, and assessment of a trail, based on 
its Designed Use and Trail Class. They reflect the dominant physical 
criteria that most define the geometric shape of a trail, including 
tread width, surface, grade, cross slope, clearing width and height, 
and turning radius. In some instances, a specific value for these 
factors is identified in the Design Parameters, while in others, a 
range of values is identified. In the latter case, managers narrow the 
range, selecting the specific value that best reflects the management 
intent for the trail.
    The Design Parameters do not indicate the types of uses that can 
occur or are allowed on NFS trails, but rather establish general 
guidelines for the design, construction, maintenance, survey, and 
assessment of NFS trails, based on their physical characteristics and 
Designed Use, as determined by preexisting management decisions. All 
nonmotorized uses are allowed on any NFS trail unless specifically 
prohibited (motor vehicle use is covered by 36 CFR part 212, subpart 
B). In addition, local deviations from any Design Parameter may be 
established based on trail-specific conditions, topography, or other 
factors, provided that the deviations are consistent with the general 
intent of the applicable Trail Class.

2. Public Comments on the Proposed Directives and Agency Response

Overview of Comments

    On July 3, 2006, the Forest Service published the proposed 
revisions to the TCS, including Design Parameters, in the Federal 
Register (71 FR 127) for a 60-day public comment period. The proposed 
revisions were also posted on the Forest Service Web site at https://
www.fs.fed.us/recreation/.
    The Forest Service received 122 letters or electronic messages in 
response to the proposed revisions. Each respondent was grouped into 
one of the following categories:
    Trail Interests--118
    State Agencies--2
    Individuals (unaffiliated or unidentifiable)--2
No comments were received on any section of the directives that is not 
listed below.

Response to General Comments

The TCS
    Comment. One respondent stated that the Trail Fundamentals and 
revisions to the TCS appear to be ``well conceived and could provide 
useful guidance.'' Another respondent stated that the Design Parameters 
and Trail Classes seem reasonable and in tune with what is on the 
ground.
    Response. The agency agrees that the TCS is an effective trail 
management tool that provides valuable guidance for the planning, 
design, construction, maintenance, assessment, and management of NFS 
trails. The TCS is resulting in improved consistency, communication, 
and quality of trail inventory, prescription, condition, and cost data.
    Comment. Two respondents were pleased with the clear definition and 
application of Managed Use, which

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recognize that there can be more than one Managed Use for a trail.
    Response. The Forest Service agrees that Managed Use is an 
important and very useful trail management concept and continues to 
strive for a clear understanding and consistent interpretation of this 
concept through issuance of these directives, training, and other 
reference material.
    Comment. Two respondents expressed support for the definition and 
application of Designed Use, based on the belief that this concept, in 
conjunction with the concept of Managed Use, promotes multiple trail 
uses on sufficiently designed, constructed, and maintained trails.
    Response. The agency agrees that Designed Use is an important trail 
management concept and that Designed Use, in conjunction with Managed 
Use, allows managers to communicate clearly the intended uses of a 
trail and to specify the design, construction, and maintenance 
parameters needed to accommodate those uses.
    Comment. One respondent believed that the TCS appears to take into 
account the impacts of nonpedestrian trail uses on resources and other 
trail users and to direct motorized and pedestrian use to trails that 
are capable of sustaining those uses.
    Response. The Forest Service agrees that the TCS and the interim 
final directives provide improved guidance regarding sustainable 
development, management, and use of NFS trails.
    Comment. One respondent asserted that application of the TCS should 
not result in a net reduction of trail miles on NFS lands and that 
trails closed for habitat protection should be rerouted.
    Response. The application of the TCS does not result in changes in 
availability or management on NFS trails. Rather, the TCS is a tool for 
improving consistency in tracking and summarizing trail inventory and 
communicating trail design, construction, and maintenance parameters. 
Decisions regarding adding or removing NFS trails from the forest 
transportation system are subject to applicable land management plan 
direction, travel management planning, and trail-specific planning and 
are beyond the scope of these directives.
    Comment. Two respondents asserted that there should be full funding 
for periodic, scheduled trail maintenance. One respondent recommended 
that any new standards or guidelines focus on appropriate scheduling of 
reconstruction, repair, and maintenance, as well as development of 
alternative funding sources to maximize trail appropriations and to 
fully fund trail work.
    Response. The Forest Service recognizes that there is a need for 
adequate funding for trail maintenance. Consequently, the agency has an 
even greater need for effective approaches for assessing and tracking 
NFS trail inventory, conditions, and maintenance needs and prioritizing 
needed trail maintenance. Implementation of the TCS is a key step in 
agency efforts to improve efficiency, consistency, and credibility in 
the identification and reporting of maintenance needs agency-wide and 
in the prioritization and implementation of maintenance work to be 
completed with limited resources. The TCS also facilitates 
identification, communication, and implementation of trail repair and 
maintenance conducted by contractors, Forest Service crews, and 
thousands of volunteers across the country.
    The interim final directives provide general guidance in FSH 
2309.18, section 18, exhibit 01, for determining appropriate schedules 
for recurring and other trail work. However, the determination of 
trail-specific maintenance schedules depends on a variety of factors, 
including current management priorities and available resources. While 
the agency strives to increase contributions from volunteers and to 
leverage funding for trail work, these activities are beyond the scope 
of these directives.
    Comment. One respondent stated that the proposed directives fail to 
provide context by not including guidance regarding the mission, 
vision, and goals of the TCS.
    Response. The interim final directives contain statements regarding 
the goals of the TCS in FSM 2353.02, paragraph 1, and 2353.12, as well 
as FSH 2309.18, section 20.2, paragraph 1.
    Comment. One respondent requested that the agency simplify the text 
of the proposed directives on the grounds that it is too bureaucratic, 
arcane, and difficult to understand.
    Response. The primary intended audience for this direction is 
Forest Service employees charged with administering the agency's trails 
program. The agency acknowledges that some of the TCS materials are 
technical and therefore require a certain level of technical training 
and expertise to understand. To facilitate clear communication and 
consistent interpretation, the agency is incorporating revisions 
throughout the interim final directives to improve clarity to the 
extent possible, including several new or revised definitions.
    Comment. Two respondents questioned the need for directives on the 
TCS and expressed concern that the Forest Service is spending time on 
paper and process, rather than accomplishing trail work in the field.
    Response. The Forest Service believes that sufficient and credible 
information for trail inventory and prescriptions is essential for 
effective management of the agency's trail program, including the 
determination of needed field work and efficient application of limited 
resources to accomplish that work. This information is used annually to 
report to Congress regarding annual accomplishments, the work needed to 
meet the National Quality Standards for Trails, and the cost of that 
work.
Multi-Use Trails
    Comment. Some respondents stated that identification of one 
Designed Use per trail or trail segment would be too limiting and would 
not accommodate multiple uses on a trail. These respondents expressed 
concern that identification of a single Designed Use would be based on 
the most intensive use on a trail, even if that use represented only a 
small percentage of use occurring on the trail. These respondents 
contended that this approach to Designed Use could result in the 
displacement or exclusion of trail uses. Some respondents stated that 
there needs to be a mixed-use trail category that would permit trails 
to remain available for multiple uses. Two respondents contended that 
in most cases there is no single Designed Use and that the TCS should 
include a single multi-use nonmotorized Designed Use for these 
situations.
    Response. The majority of NFS trails are managed for multiple modes 
of travel, including various combinations of Managed Uses. 
Implementation of the TCS does not change this approach to trail 
management. For example, many NFS trails are managed for hiker/
pedestrian, bicycle, and pack and saddle use, and many others are 
managed for all-terrain vehicle (ATV) and motorcycle use, with numerous 
other uses allowed on these trails.
    The TCS does not determine the Managed Uses of NFS trails. Rather, 
local trail managers determine the Managed Uses for each NFS trail, 
based on applicable land management plan direction, applicable travel 
management decisions, trail-specific decisions, and other related 
direction. This direction is based on consideration of current trail 
uses and their volume, relative levels, and seasons of use; potential 
or existing use conflicts; desired distances and challenge levels; 
topography; estimated

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development and maintenance costs; and other factors.
    Identification of the Designed Use from among the Managed Uses of a 
trail helps managers to ensure that the design, construction, and 
maintenance parameters for the trail are adequate to accommodate all 
the Managed Uses of that trail. To clarify this point, the interim 
final directives state that when determining the Designed Use from 
among the Managed Uses identified for a trail, managers should assess 
any essential or limiting geometry for the Managed Uses of the trail or 
trail segment to determine whether any trail-specific adjustments are 
necessary to the applicable Design Parameters (FSH 2309.18, sec. 14.4, 
para. 3).
    Comment. One respondent expressed concern that the requirement to 
identify one Designed Use per trail or trail segment does not apply to 
multi-season trails.
    Response. Many NFS trails have varying combinations of Managed Uses 
during different seasons of the year. Implementation of the Design 
Parameters does not change these determinations. To the contrary, both 
the proposed directives (FSH 2309.18, section 2.03) and the interim 
final directives (FSH 2309.18, section 14.4) state that when 
determining the Designed Use and Design Parameters of an NFS trail or 
trail segment, local managers should ``consider all Managed Uses that 
occur during all seasons of use of the trail or trail segment.'' 
Determination of the appropriate Designed Use from among the Managed 
Uses of a trail helps managers to ensure that the design, construction, 
and maintenance parameters for the trail are adequate to accommodate 
all of its Managed Uses during all of its seasons of use and on various 
Trail Types (such as when a Standard Terra Trail overlaps a Snow 
Trail).
    Comment. One respondent recommended developing Trail Management 
Objectives (TMOs) specific to multi-use trails that would allow less 
intensive nonmotorized uses, as well as more intensive motorized uses.
    Response. TMOs are developed at the local level, are trail-
specific, are based on applicable management direction, and include the 
identification of several factors, including the applicable Trail 
Class, Managed Uses, the Designed Use, and corresponding Design 
Parameters for the trail or trail segment. The TCS provides guidance 
for development of trail-specific TMOs for all NFS trails, including 
those with various combinations of motorized and nonmotorized Managed 
Uses. The development of trail-specific TMOs helps managers to identify 
the Managed Uses, including motorized and nonmotorized uses, and the 
corresponding intensity of use for a particular trail or trail segment.
Concerns Regarding Unnecessary Improvement and Maintenance
    Comment. Several respondents expressed concern that implementation 
of the TCS would lead to unnecessary improvement and maintenance of 
trails to a higher standard, resulting in wider, more urban trails and 
detracting from the rugged, challenging, natural quality of the trail 
experience on NFS lands. Two respondents expressed concern that 
implementation of the proposed Design Parameters would be elaborate, 
excessive, and costly, resulting in trails that would no longer have 
the wild, rugged character that many seek. Several respondents 
expressed concern that adoption of the proposed Design Parameters would 
result in mixed-use trails that look more like highly developed 
suburban trails.
    Response. Implementation of the TCS and Design Parameters will not 
cause any changes in trail prescriptions or on-the-ground management of 
trails. The TCS and Design Parameters are applied by local managers 
based on applicable land management plan direction, applicable travel 
management decisions, trail-specific decisions, and other related 
direction to develop trail-specific TMOs and trail prescriptions. 
Managers strive to provide a variety of trail opportunities for 
experiencing diverse environments and modes of travel, ranging from 
primitive and semiprimitive to roaded natural and urban, consistent 
with the role of recreation in the NFS and the capability of the land 
(FSM 2302, 2303, and 2350, sec. 03, para. 2).
    The national Trail Classes encompass a full spectrum of trail 
development, ranging from minimally developed, extremely rugged, and 
highly challenging trails in Trail Class 1 to fully developed, 
minimally challenging, and often accessible trails in Trail Class 5. 
The agency views each of the five Trail Classes as a valuable component 
of the range of NFS trail opportunities. In the interim final 
directives, the agency has included additional guidance on the Design 
Parameters regarding the level of challenge associated with various 
combinations of Trail Class and Designed Use, as shown in section 3 of 
this preamble, Table 7, ``Changes to the Trail Class Matrix,'' under 
Obstacles, and in Tables 8 through 14, under Design Surface Protrusions 
and Obstacles.
    Comment. One respondent expressed concern that trail maintenance 
and upgrades are determined by the use with the most impact, 
potentially resulting in undesired and costly development of higher-end 
trails.
    Response. The TCS does not dictate trail maintenance or upgrades. 
Under the TCS, trail prescriptions, including maintenance and 
improvement, are based on a trail's TMOs, which include identification 
of the intended Trail Class, Managed Uses, Designed Use, and Design 
Parameters for the trail or trail segment. Local managers are 
responsible for making these determinations based on the applicable 
land management plan direction, applicable travel management decisions, 
trail-specific decisions, and other related direction. This direction 
is based on consideration of current trail uses; their volume, relative 
levels, and seasons of use; potential or existing use conflicts; 
desired distances and challenge levels; topography; estimated 
development and maintenance costs; and other factors. Under the TCS, 
management intent drives the level of development of a trail, as 
reflected in the applicable Trail Class and Design Parameters, rather 
than the allowed uses of a trail. Therefore, the level of trail 
development under the TCS is desired and appropriate.
Nonmotorized Use
    Comment. Some respondents strongly supported the open-unless-closed 
Forest Service trails policy regarding nonmotorized use of NFS trails 
and believed that the following statement should remain in the TCS 
directives: ``All nonmotorized uses are allowed on any NFS trail unless 
specifically prohibited.''
    Response. All trail uses, not just nonmotorized uses, are allowed 
on NFS trails unless specifically prohibited. Therefore, the agency is 
retaining the following statement in the final interim directives: 
``The Managed Uses for a trail are usually a small subset of all the 
allowed uses on the trail, that is, uses that are allowed unless 
specifically prohibited.'' (FSH 2309.18, sec. 14.3, para. 4).
    Comment. Some respondents expressed concern regarding potential 
displacement of nonmotorized trail use by motorized trail use as a 
result of implementation of the TCS. Many of these respondents 
expressed concern that the Designed Use and subsequent maintenance 
parameters would be determined by the most intensive or motorized use, 
which would encourage more of the Designed Use and displace less 
intensive, nonmotorized uses.

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Several respondents expressed concern that adoption of higher trail 
standards would encourage motorized use, shifting the emphasis from 
nonmotorized to motorized use and promoting the exclusion of 
nonmotorized uses. Specifically, these respondents were concerned that 
all trails where motorcycles are not prohibited would be designed and 
maintained for motorcycle use, even if 95 percent of the use of these 
trails were nonmotorized.
    Response. The TCS does not cause a shift in the Managed Uses or in 
the balance of motorized and nonmotorized uses of NFS trails, nor will 
the implementation of the TCS result in adoption of higher trail 
standards. Trail managers are responsible for applying the TCS to 
reflect the management intent for each NFS trail, which derives from 
applicable land management plan direction, applicable travel management 
decisions, trail-specific decisions, and other related direction. This 
direction is based on consideration of current trail uses; their 
volume, relative levels, and seasons of use; potential or existing use 
conflicts; desired distances and challenge levels; topography; 
estimated development and maintenance costs; and other factors.
    The agency is sensitive to potential displacement of trail uses as 
use patterns and technology change. The agency believes that the TCS 
enhances managers' ability to implement the management intent for NFS 
trails and to provide desired trail opportunities, experiences, and 
challenge levels for nonmotorized and motorized uses, individually or 
in combination.
Coordination With Travel Management
    Comment. One respondent requested clarification of how the TCS 
integrates with travel management, in particular, with designation of 
routes for motor vehicle use.
    Response. Once a trail is designated for motor vehicle use, the 
trail's TMOs should reflect that designation. Directives are being 
finalized for implementation of the travel management rule at 36 CFR 
part 212, subpart B. The proposed travel management directives state 
that TMOs should reflect applicable travel management decisions. In 
addition, a trail's TMOs include identification of the applicable Trail 
Class, Managed Uses, Designed Use, and Design Parameters.
    Comment. Several respondents expressed concern that the proposed 
revisions to the TCS were not coordinated with, are inconsistent with, 
and do not reflect the subtleties of the Forest Service's new travel 
management rule. Some respondents recommended that the TCS be reviewed 
by travel management program coordinators and be made consistent with 
the travel management rule with respect to designation of trail loops, 
establishment of trail cutoffs, and conversion of closed roads to 
trails
    Response. The Forest Service is working on final travel management 
directives to implement the travel management rule, which requires each 
administrative unit or Ranger District to designate those NFS roads, 
NFS trails, and areas on NFS lands that are open to motor vehicle use 
by vehicle class and, if appropriate, by time of year. The managers of 
the national trail program and travel management program have consulted 
extensively in the development of their directives to ensure 
consistency in terminology and appropriate program integration. 
Designation of trails for motor vehicle use and consideration of 
conversion of NFS roads to NFS trails are within the scope of the 
travel management directives and beyond the scope of the TCS 
directives.
    Comment. Two respondents expressed concern about the cost of new 
federal requirements to upgrade trails and recommended that the 
upgrading be postponed until after the travel management directives are 
finalized.
    Response. The TCS does not require any specific actions with regard 
to design, construction, and maintenance of NFS trails, including 
upgrading their condition. Rather, the TCS is a tool used by trail 
managers to improve consistency in tracking and summarizing inventory 
and communicating design, construction, and maintenance parameters for 
NFS trails. Therefore, issuance of the interim final directives will 
not affect the cost of trail maintenance.
Recreation Opportunity Spectrum
    Comment. Some respondents commented that the proposed directives 
treat NFS trails solely as recreational facilities, with Design 
Parameters and maintenance cycles linked to classes in the Recreation 
Opportunity Spectrum (ROS) or Wilderness ROS, rather than as multi-
function transportation facilities with no linkage to ROS or Wilderness 
ROS classes.
    Response. The objectives in FSM 2353.02 for management of NFS 
trails remain largely unchanged. These objectives include the provision 
of ``trail-related recreation opportunities that serve public needs and 
meet land management and recreation policy objectives,'' the provision 
of ``trail recreation opportunities that emphasize the natural setting 
of national forests and grasslands and are consistent with land 
capability,'' and the provision of ``trail access for resource 
management and protection.'' The agency believes that implementation of 
the TCS furthers all three of these objectives because it is based on 
the scale of trail development and applied, along with the Design 
Parameters, so as to reflect the management intent for each NFS trail.
    ROS and Wilderness ROS classes are used by the agency to identify 
social, physical, and managerial settings in the NFS and to ensure NFS 
trails offer a suitable diversity of outdoor recreation opportunities 
(FSM 2353.13). There is no direct correlation between the five Trail 
Classes and ROS and Wilderness ROS classes, although some combinations 
occur more commonly than others. To clarify the lack of a direct 
correlation in the interim final directions, the agency has added a 
footnote to the Trail Class Matrix that states: ``The Trail Class 
Matrix shows combinations of Trail Class and Recreation Opportunity 
Spectrum (ROS) or Wilderness Recreation Opportunity Spectrum (WROS) 
settings that commonly occur, although trails in all Trail Classes may 
and do occur in all settings'' (FSH 2309.18, sec. 14.2, ex. 01). 
Managed Uses reflect various modes of travel, each of which may occur 
on trails managed for recreational use, on trails managed for 
recreational and nonrecreational use, or both. The TCS enhances 
managers' ability to develop prescriptions for the design, 
construction, and maintenance needed to accommodate the Managed Uses of 
each NFS trail.
National Scenic and National Historic Trails
    Comment. Some respondents said that it is unclear how National 
Historic and National Scenic Trails fit into the proposed TCS. These 
respondents expressed concern that none of the proposed Trail Classes 
includes guidelines for preserving National Historic Trails and that a 
one-size-fits-all approach is not appropriate for these trails.
    Response. The TCS applies to all NFS trails, including National 
Historic and National Scenic Trails. The TCS does not provide guidance 
on preservation of National Historic Trails. Rather, with regard to 
trail maintenance, the purpose of the TCS is to provide managers with a 
tool for consistently and effectively inventorying NFS trails and 
identifying and communicating their condition and the work needed to 
maintain them to their prescribed standard.

[[Page 61605]]

    Comment. One respondent expressed concern that the proposed Trail 
Classes vary with regard to the standards for trail marking and that 
signing and marking (even in wilderness areas) for National Historic 
and National Scenic Trails need to be consistent.
    Response. The Trail Class Matrix provides general guidelines 
regarding the appropriate level and type of signage by Trail Class. The 
agency has incorporated several clarifications regarding signing at 
junctions and route markers into the Trail Class Matrix (FSH 2309.18, 
sec. 14.2, ex. 01), as shown in Table 7, ``Changes to the Trail Class 
Matrix,'' in section 4 of this preamble. See ``Sign and Poster 
Guidelines for the Forest Service'' (EM-7100-15) for guidance on trail 
signing and marking, including sign design and placement for various 
modes of travel and at various locations, including wilderness areas 
and NFS trails.
    Comment. One respondent stated that the proposed Trail Classes must 
not change the intended or allowed recreational uses on National Scenic 
and National Historic Trails.
    Response. The Trail Classes do not dictate the intended or allowed 
uses of NFS trails. Trail Classes reflect the development scale of NFS 
trails and are applied, along with their applicable Design Parameters, 
so as to reflect the management intent for each NFS trail. 
Determination of a trail's management intent is based on applicable 
land management plan direction, applicable travel management decisions, 
trail-specific decisions, and other related direction. Decisions about 
which modes of travel are allowed on NFS trails, including National 
Scenic and National Historic Trails, are made by the responsible 
official at the local level, consistent with applicable law, including 
the National Trails System Act.
    Comment. One respondent expressed concern that application of the 
TCS could unintentionally alter well-established practices for 
construction, maintenance, and management of the Appalachian National 
Scenic Trail and its facilities. This respondent assumed that the 
stewardship manual for the Appalachian National Scenic Trail would 
continue to provide guidance with respect to polices applicable to that 
trail. This respondent expressed hope that the TCS would reduce, rather 
than increase, misunderstandings regarding appropriate development of 
the trail, its side trails, and its facilities.
    Response. Implementation of the TCS will not change on-the-ground 
management of the Appalachian National Scenic Trail. The TCS gives 
managers a standardized tool for inventorying trails, identifying and 
communicating the condition of trails, and identifying the work needed 
to maintain them to their prescribed standard. The TCS will not 
supersede the stewardship manual for the Appalachian National Scenic 
Trail. The agency believes that implementation of the TCS will improve 
communication between the Forest Service and its trail partners, 
including those who work on the Appalachian National Scenic Trail.
Management of Trails Based on Their Current Condition
    Comment. Two respondents asserted that Forest Service personnel 
surveying trails for the proposed TCS were instructed to determine the 
applicable Trail Class based on a trail's current condition and 
expressed concern about this practice. One respondent contended that 
this practice has resulted in reduction of the Trail Class for many 
trails that have had minimal or no maintenance over the past 30 years. 
The other respondent contended that in many cases a trail's inventoried 
condition differs considerably from its TMOs and that this discrepancy 
needs to be rectified.
    In addition, this respondent expressed concern that management of 
trails based on their current condition is inappropriate in wilderness 
areas and provided recommendations for assessing a trail's current 
condition in terms of whether the trail meets its desired condition. 
This respondent stated that establishment of trail objectives should be 
guided by the intent and purposes of the Wilderness Act, scientifically 
sound data on the capability of the ecosystem to withstand various 
types and varying intensity of use, and the need to preserve 
opportunities for primitive travel experiences and solitude, including 
transport by pack and saddle.
    This respondent also believed that trails in wilderness areas 
should maximize opportunities for primitive travel and camping, 
solitude, and aesthetic experiences unique to wilderness areas. This 
respondent contended that the agency should track the degree to which 
the condition of trails in wilderness areas reflects their management 
intent, as follows: (a) Meeting their management intent; (b) if they do 
not meet their management intent, being improved to meet it, if funding 
permits; (c) if funding does not permit improving them to meet their 
management intent, maintaining their current condition; or (d) 
continuing to deteriorate and further deviate from their management 
intent.
    Response. Forest Service trail managers are not instructed to 
classify NFS trails in accordance with their current condition. Forest 
Service training and reference materials instruct trail managers to 
identify the applicable Trail Class, Managed Uses, and Design 
Parameters for each NFS trail based on applicable land management plan 
direction, applicable travel management decisions, trail-specific 
decisions, and other related direction. Trail managers are instructed 
to document the applicable Trail Class, Managed Uses, and applicable 
Design Parameters in TMOs, which are defined in the interim final 
directives as ``documentation of the intended purpose and management of 
an NFS trail based on management direction, including access 
objectives'' (FSM 2353.05 and FSH 2309.18, sec. 05). When determining 
the applicable Trail Class, managers are instructed to ``choose the one 
that most closely reflects the management intent of the trail,'' as 
stated in the introductory paragraph to the Trail Class Matrix (FSH 
2309.18, sec. 14.2, ex. 01). For further clarification, the agency has 
revised the interim final directives at FSH 2309.18, section 14.2, 
paragraph 7, to state: ``Apply the Trail Class that most closely 
reflects the management intent for the trail or trail segment, which 
may or may not reflect the current condition of the trail.''
    Managers are instructed to apply the same management approach to 
NFS trails inside and outside wilderness areas. In wilderness areas, 
management intent for NFS trails is also contained in the applicable 
enabling legislation and wilderness management plan. Application of 
this management approach, which is based on the management intent for 
NFS trails, will not result in reduction of the Trail Class for NFS 
trails that have not received the desired level of maintenance.
Training
    Comment. One respondent recommended that the Forest Service 
consider some form of internal and external educational outreach to 
explain the TCS, as well as the Interagency Trail Data Standards 
(ITDS), the Forest Service Trail Accessibility Guidelines (FSTAG), and 
the Forest Service Outdoor Recreation Accessibility Guidelines 
(FSORAG).
    Response. The Forest Service presents numerous training sessions 
each year on these topics. While the majority of these training 
sessions are for Forest Service employees at the national, regional, 
and local levels, the agency has also provided dozens of related 
training sessions for participants from other

[[Page 61606]]

federal agencies, state and local agencies, and many trail 
organizations. With the increasing need for budget efficiency, the 
agency is also providing expanded opportunities for online training for 
Forest Service employees on these topics. The agency also continues to 
improve and disseminate its related reference and training materials 
and is planning to make them available via an external Web site, which 
is currently under development.
Need for Change
    Comment. Several respondents questioned the need for revision of 
the TCS and contended that the agency insufficiently explained and 
supported the need for the changes in the proposed directives. Some 
respondents requested that the Forest Service's trail classification 
system and Trail Guides remain the same as they are in the current 
directives.
    Response. As explained in the preamble to the proposed and interim 
final directives, the Forest Service's trail classes of way, secondary, 
and mainline did not correlate directly with the difficulty levels in 
FSH 2309.18, section 2.32c, exhibit 01. The five Trail Classes, in 
contrast, are keyed more precisely to the physical characteristics of 
NFS trails and more accurately stratify NFS trails for purposes of 
inventory, land management planning, visitor information, and 
assessment of maintenance and construction costs. The five Trail 
Classes are also incorporated into each set of Design Parameters.
    The Design Parameters, which superseded the technical parameters in 
the Trail Guides in the FSH, incorporate the design, construction, and 
maintenance guidelines in the Trail Guides, with only minor, technical 
changes that have no effect on how trails are managed on the ground. In 
some cases, the Design Parameters expand the range of values in a 
category. In contrast to the Trail Guides, each set of Design 
Parameters includes a standardized set of factors (e.g., Design Tread 
Width, Target Grade, and Short Pitch Maximum). These factors are 
defined in the interim final directives to enhance consistency in their 
application (FSM 2353.05 and FSH 2309.18, sec. 05).
    The Forest Service transitioned to the five Trail Classes in 1999 
and began using the Design Parameters in 2004. These inventory and 
trail management tools have been integrated throughout the agency's 
trail database, TMOs, and related management tools. The TCS and Design 
Parameters have resulted in improved consistency and quality of trail 
inventory, condition assessments, prescriptions reflecting the work 
needed to meet the National Quality Standards for Trails, and 
corresponding cost estimates. Therefore, it would not be cost-effective 
or productive to return to the earlier system.
2353.05--Definitions
    Comment. Some respondents supported a clearer distinction between 
nonmotorized bicycles and motor vehicles such as motorcycles.
    Response. The Forest Service agrees and in the interim final 
directives has added a definition that defines a bicycle as ``a pedal-
driven, human-powered device with two wheels attached to a frame, one 
behind the other.'' In addition, the agency has removed the definition 
for ``trail vehicle,'' defined as ``vehicles designed for trail use, 
such as bicycles, snowmobiles, trail bikes, trail scooters, and all 
terrain vehicles (ATV).''
    Comment. One respondent expressed concern that replacing the term 
``trail guides'' with ``Design Parameters'' lends the impression that 
they contain requirements, rather than guidelines, with little room for 
variance due to local situations. This respondent recommended using the 
term ``design parameter guidelines'' or revising FSH 2309.18, section 
14.5, paragraph 1, to state that the Design Parameters are only 
guidelines, not requirements.
    Response. The definition of Design Parameters included in FSM 
2353.05 and FSH 2309.18, section 05, and the introductory paragraph 
included with each set of Design Parameters state that the Design 
Parameters are technical guidelines. To clarify this point further, the 
agency has revised the introductory paragraph in each set of Design 
Parameters to state that the Design Parameters are technical guidelines 
for determining the parameters reflecting the management intent for 
each NFS trail. In addition, the agency has clarified the introductory 
paragraph in each set of Design Parameters to state that local 
deviations to any Design Parameter may be established based on specific 
trail conditions, topography, and other factors, provided that the 
deviations are consistent with the general intent of the applicable 
Trail Class.
    Comment. One respondent recommended changing the definition for 
Trail Class to ``a word description and numerical identifier of the 
trail development that represents the intended design and management 
standards of the trail.'' This respondent expressed concern that the 
definition in the proposed directives, ``The prescribed scale of trail 
development, representing the intended design and management standards 
of the trail,'' would give the impression that the Trail Class assigns 
the appropriate level of development, rather than reflecting its 
management intent.
    Response. The agency believes that the definition of Trail Class in 
the proposed directives is effective and succinct and is therefore not 
changing it in the interim final directives. After nearly 10 years of 
use, agency managers and technicians are familiar with this term as 
currently defined and, as a result, understand that determination of 
the appropriate Trail Class for each NFS trail or trail segment is 
based on the management intent for the trail as reflected in the 
applicable land management plan, applicable travel management 
decisions, trail-specific decisions, and other related direction, which 
may or may not reflect the current condition of the trail.
    Comment. One respondent recommended changing the definition for 
four-wheel drive way to ``a National Forest System Trail commonly used 
for four-wheel drive vehicles.''
    Response. In the interim final directives, the agency has replaced 
the term ``four-wheel drive way'' with the term ``four-wheel drive 
vehicle greater than 50 inches in width'' and its corresponding 
definition in FSM 2353.05 and FSH 2309.18, section 05. Defining the 
vehicle, rather than the type of trail used by the vehicle, is 
consistent with the concept of Managed Use, which is based on modes of 
travel, rather than trail categories defined by use type. Direction 
relating to four-wheel drive vehicles greater than 50 inches in width 
will be provided in the final travel management directives at FSM 2353, 
7700, and 7710 and FSH 7709.55. The agency has deleted FSM 2352, 
``Four-Wheel Drive Ways,'' from the interim final directives because 
the concept of four-wheel drive ways is no longer used by the agency.
    Comment. Two respondents recommended defining the term 
``trailheads'' to distinguish between a constructed parking area at a 
designated trailhead that has a hard surface and that is periodically 
maintained and a parking area with a natural or perhaps user-created 
surface. These respondents contended that this distinction is 
especially important when determining the applicability of the FSTAG 
between a trailhead and a trail.
    Response. The agency has revised the definition for ``trailhead'' 
in the interim final directives to include a related sub-definition of 
a trailhead for purposes of the FSTAG (FSM 2353.05).

[[Page 61607]]

2353.3--Difficulty Levels
    Comment. One respondent suggested requiring difficulty levels in 
FSM 2353.3 for pack and saddle and hiker/pedestrian uses that indicate 
the elevation and severity of a trail. This respondent stated that 
often when hikers share trails with equestrians, it can be dangerous 
for the riders and horses. This respondent recommended requiring 
posting of advice or warnings on trails with dangerous sections for 
inexperienced riders, such as a trail with rock bluffs and unsure 
footing and no areas in which to turn around.
    Response. The Forest Service does not believe that it would be 
appropriate to require posting of trail elevations, severity, or 
warnings on all NFS trails managed or designed to accommodate hiker/
pedestrian and pack and saddle use. This approach would not be 
consistent with management of NFS trails for other uses. Moreover, 
consistent with the FSTAG, the agency is no longer identifying 
difficulty levels for trails with a Designed Use of Hiker/Pedestrian. 
Instead, for trails in Trail Classes 4 and 5 with a Designed Use of 
Hiker/Pedestrian, the agency is requiring posting at trailheads the 
typical and maximum trail grade, typical and maximum cross slope, 
typical and minimum tread width, surface type and firmness, and 
obstacles. Managers have the discretion to post this information at 
trailheads for other Hiker/Pedestrian trails and NFS trails with other 
Managed or Designed Uses.

FSH 2309.18

Zero Code

05--Definitions
    The agency received the same comments on the definitions in FSM 
2353 and FSH 2309.18. Therefore, the agency is incorporating here by 
reference the response to comments on the definitions in FSM 2353.
FSH 2309.18, Chapter One (Recoded to Chapter 10 in the Interim Final 
Directives)
Section 1.2--Planning (Recoded to Section 12 in the Interim Final 
Directives)
    Comment. Two respondents supported field manager discretion in 
trail design and requested that this discretion be retained. Several 
respondents requested that the agency add flexibility to the proposed 
directives by basing Managed Uses and Design Parameters on practical 
concerns, instead of the proposed sets of overly rigorous Design 
Parameters. Several respondents requested that the agency give managers 
and resource specialists the discretion they need to design and 
maintain trails to retain their primitive and undeveloped character 
across all Trail Classes and Designed Uses. One respondent commented 
that the proposed directives should state that the determination of the 
appropriate Trail Class is not discretionary with the trail manager and 
should not reflect a trail's existing condition.
    Response. The agency believes that local managers need discretion 
to apply the TCS so as to reflect the management intent for NFS trails, 
which may or may not be consistent with their current condition. 
Accordingly, the proposed and interim final directives give local 
managers a considerable amount of discretion in identifying a trail's 
TMOs (including the applicable Trail Class, Managed Uses, Designed Use, 
and Design Parameters) based on the management intent for that trail. 
Flexibility is also built into the Design Parameters, providing a range 
for trail attributes such as tread width.
    Additionally, the Design Parameters allow for local deviations 
based on specific trail conditions, topography, and other factors, 
including desired setting, challenge levels, and experience 
opportunities, provided that the deviations are consistent with the 
general intent of the applicable Trail Class. To clarify this point, 
the agency has modified the Trail Class Matrix to reflect more clearly 
the range of ROS and WROS classes for each Trail Class (see Table 7 in 
section 4 of this preamble). In addition, the agency has added a 
footnote to the Trail Class Matrix stating that it displays commonly 
occurring combinations of Trail Class and ROS or WROS settings, 
although trails in all Trail Classes may and do occur in all settings 
(FSH 2309.18, sec. 14.2, ex. 01).
    Comment. Some respondents expressed concern that application of the 
TCS and Design Parameters would result in the closure or reduction of 
trails open to pack and saddle use and requested the opportunity to 
provide public input before any trails are reclassified, declassified, 
or closed. Several respondents stated that the agency should consider 
availability of funding, labor, materials, and time when making 
decisions about trail management and that lack of these factors should 
not result in reduction in the Trail Class.
    Response. The proposed and interim final directives do not provide 
for reduction in the Trail Class of any NFS trails, closure of any NFS 
trails, or removal of any NFS trails from the forest transportation 
system because of inability to maintain the trails to the applicable 
standard. To the contrary, the applicable Trail Class and Design 
Parameters of an NFS trail are based on its management intent, as 
reflected in applicable direction.
    In the interim final directives, the agency has revised FSH 
2309.18, sections 14.2 and 14.3, to state more clearly that 
determination of the Trail Class and Managed Uses of a trail is based 
on its management intent, as shown in the applicable land management 
plan, applicable travel management decisions, trail-specific decisions, 
and other related direction, which may or may not reflect the current 
condition of the trail.
    FSH 2309.18, section 18, identifies several factors to be 
considered when establishing priorities and requirements for trail 
management, including funding for labor and materials and scheduling of 
work. The directives include the National Quality Standards for Trails, 
which describe outcomes that trail users can expect to encounter and 
the level of quality the Forest Service plans to provide on NFS trails 
managed at a full-service level (FSH 2309.18, sec. 15). These standards 
establish the baseline for estimating the total cost of providing the 
quality opportunities visitors expect.
    Comment. Several respondents requested that the Forest Service 
develop a system for tracking consistency of TMOs with Forest Service 
planning documents that meet the requirements of NEPA and NFMA. One of 
these respondents stated that section 1.2, paragraph 2, of the proposed 
directives should clearly state that follow-up analysis needed to 
determine specific standards for a trail must comply with the National 
Environmental Policy Act (NEPA) and the National Forest Management Act 
(NFMA) and be subject to appropriate public involvement. Another 
respondent believed that the proposed directives must include 
provisions for public input on determination of all trail 
classifications, maintenance needs, and design parameters.
    Response. TMOs must be consistent with the applicable land 
management plan, applicable travel management decisions, trail-specific 
decisions, and other related direction issued in compliance with NEPA. 
The agency believes that it is not necessary to establish a separate 
process for tracking consistency of TMOs with the applicable land 
management plan and other applicable direction.
    In addition, application of the TCS and Design Parameters does not 
trigger the public involvement requirements in

[[Page 61608]]

NEPA and NFMA. Application of the TCS and Design Parameters is based on 
a trail's management intent, as reflected in direction that has been 
issued in compliance with NEPA and NFMA. Therefore, further 
environmental analysis and public involvement are not required. See 
Back Country Horsemen of America v. Johanns, No. 05-0960 (D.D.C. Mar. 
29, 2006), slip op. at 15-20.
    During required public involvement for trail-related direction and 
in general, trail managers work with the public and trail groups to 
obtain their input regarding the status and management of trails they 
use. Changes in the management intent of NFS trails as reflected in the 
applicable land management plan, applicable travel management 
decisions, trail-specific decisions, and other related direction are 
subject to the direction in FSH 2309.18, section 11, including the 
direction regarding compliance with NEPA.
Section 1.42--Trail Classes (Recoded to Section 14.2 in the Interim 
Final Directives)
    Comment. One respondent disagreed that there is a direct 
relationship between Trail Class and Managed Uses, that is, that one 
cannot be determined without consideration of the other. This 
respondent acknowledged that they were related, but believed that the 
determination of Managed Uses is always made before the determination 
of the applicable Trail Class.
    Response. Generally, the determination of Managed Uses cannot be 
made before the determination of the applicable Trail Class and vice 
versa. Trail Class and Managed Uses are interdependent because the 
appropriate scale of development of a trail depends on the types of 
uses that are actively managed on the trail, and the reverse is also 
true. To clarify that this interdependence is not an absolute, the 
interim final directives state: ``There is a direct relationship 
between Managed Uses and Trail Class: generally, one cannot be 
determined without consideration of the other.''
Section 1.42, Exhibit 01--Trail Class Matrix (Recoded to Section 14.2, 
Exhibit 01, in the Interim Final Directives)
    Comment. Several respondents stated that the three previous trail 
classes of mainline (easy), secondary (more difficult), and way (most 
difficult) and the Pack and Saddle Trail Guide adequately accommodated 
pack and saddle use in all ROS and WROS classes. Some respondents 
requested that the proposed directives state that trails in Trail 
Classes 1 through 3 are appropriate in primitive and semiprimitive 
settings, both inside and outside wilderness areas. One respondent 
expressed concern that application of the TCS with regard to ROS and 
WROS classes would result in changes in management of wilderness areas 
and the uses that are accommodated in wilderness areas.
    Response. The agency believes that the Trail Classes and Design 
Parameters are better tools for managing NFS trails, including NFS 
trails with a Designed Use of Pack and Saddle in all ROS and WROS 
settings, than the previous three difficulty levels and Trail Guides. 
In comparison with the previous three categories, the five Trail 
Classes are keyed more precisely to the physical characteristics of NFS 
trails and more accurately stratify NFS trails for purposes of 
inventory, land management planning, visitor information, and 
establishment of maintenance and construction costs.
    When the agency shifted from the Trail Guides to the Design 
Parameters in 2004, the design, construction, and maintenance 
guidelines in the Trail Guides, including the Pack and Saddle Trail 
Guide, changed in only minor, technical ways with no effect on how 
trails are managed on the ground. In contrast to the Trail Guides, 
which did not correlate with the trail classes of mainline, secondary, 
and way in the agency's database, the Design Parameters track the five 
Trail Classes. In addition, the Design Parameters refine and clarify 
the categories and values in the Trail Guides.
    The agency does not believe it is appropriate to state 
categorically that trails in Trail Classes 1 through 3 are appropriate 
in primitive and semiprimitive settings, both inside and outside 
wilderness areas. However, the agency has clarified in a new footnote 3 
to the Trail Class Matrix (FSH 2309.18, section 14.2, exhibit 01, in 
the interim final directives) that the matrix shows commonly occurring 
combinations of Trail Class and ROS and WROS settings, but that trails 
in all Trail Classes may and do occur in all settings. The new footnote 
3 also refers managers to FSM 2310 and 2353 and FSH 2309.18 for 
guidance on application of the ROS and WROS.
    Application of the TCS does not change management of wilderness 
areas or the uses that are accommodated in wilderness areas. Land 
management planning establishes ROS and WROS classes. The TCS merely 
provides managers with a tool for more consistently and effectively 
inventorying trails and identifying and communicating trail conditions 
and the work needed to maintain trails to their prescribed standard.
    Comment. Several respondents requested that the proposed directives 
give local managers the discretion to use treated round or dimensional 
timber for the construction and maintenance of water bars, puncheon, 
turnpike, and bridge components in Trail Classes 1 through 3 where it 
will not detract from the desired experience of a typical user. These 
respondents also requested that the proposed directives give local 
managers the dis