Still Fighting the Good Fight
The Trails Preservation Alliance (TPA) is continuously working for you and after an 8-year long fight, we are nearing the finish line. The TPA has filed objections to the Pike San Isabel National Forest (PSINF) Record of Decision (ROD) Final Environmental Impact Statement (FEIS.) At this point, we have kept a number of routes open and opened a few that had been closed. We are not out of the woods yet, but we will continue to strive for positive outcomes!
A Little History
In 2012 various environmental groups including The Quiet Use Coalition, Great Old Broads for Wilderness, The Wilderness Society, WildEarth Guardians, and Rocky Mountain Wild sued the (PSINF) claiming they had not done the necessary Environment Assessment (EA) on hundreds of roads and trails within the six ranger districts encompassing all PSINF land East of the Continental Divide from Rampart Range to Walsenburg. In 2015 the PSINF settled and agreed to complete EA’s on all of the contested routes, and the scoping phase began shortly thereafter in 2016. Late in 2019, the Draft Environmental Impact Statement (DEIS) was released with five possible alternatives that would determine the future of hundreds of motorized routes within the PSINF. Late in 2020, a Record of Decision (ROD) was released approving Alternative C which, along with some additions, has been fairly favorable to the motorcycle community.
Because the TPA has been leading the efforts to protect Off-Highway Vehicle (OHV) recreation since this lawsuit began we can place objections to this final ROD. Defending off-highway motorcyclists and ALL OHV users’ rights to access public lands and ensure the USFS allots a fair and equitable amount of land to accommodate OHV use for the increased demand that it continues to experience is a fundamental part of the TPA’s mission.
This is your donation money at work and we appreciate your ongoing support! Our work will never be done – every day the TPA is monitoring countless issues that have an impact on how our public lands are managed. Please consider making a tax-deductible donation to the TPA to help continue this important work.
Excerpt from the letter:
Rocky Mountain Regional Office
Attn: Reviewing Officer
P.O. Box 18980 Golden, CO 80402
Sent via U.S. mail and electronic mail: firstname.lastname@example.org.
Objections to DRAFT Record of Decision for the Pike and San Isabel National Forests Motorized Travel Management (MVUM) Analysis and Final Environmental Impact Statement (FEIS)
Dear Reviewing Officer:
The following objections are being submitted regarding the Record of Decision (ROD) for implementing the selected alternative [Alternative C] for the Pike and San Isabel National Forests (PSINF) Public Motor Vehicle Use Final Environmental Impact Statement (FEIS). We are submitting these objections on behalf of the Trails Preservation Alliance (TPA) and the Colorado Off-Highway Vehicle Coalition (COHVCO). The TPA and COHVCO have previously submitted comments relative to this project’s Draft EIS and Scoping comments on November 1, 2019. The TPA and COHVCO recognize and appreciate the substantial amount of work and effort that it has taken to accomplish this major milestone in the project.
In 2011, both the TPA and COHVCO joined the Pike and San Isabel National Forests as Intervenor Defendants in the lawsuit that began the MVUM Analysis Project. The TPA and COHVCO have both invested substantial financial resources since 2011 in the interest of maintaining access to the PSINF and United States Forest Service (USFS) lands. The TPA is an advocacy organization created to be a viable partner to public lands managers, working with the USFS and the Bureau of Land Management (BLM) to preserve the sport of motorized trail riding and multiple-use recreation. The TPA acts as an advocate for the sport and takes the necessary action to ensure that the USFS and BLM allocate a fair and equitable percentage of public lands access to diverse multiple-use trail recreational opportunities. COHVCO is a grassroots advocacy organization representing approximately 170,000 registered off-highway vehicle (OHV), snowmobile and 4WD users in Colorado seeking to represent, assist, educate, and empower all motorized recreationists in the protection and promotion of multiple-use and off- highway motorized recreation throughout Colorado. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations. The TPA and COHVCO are referred to collectively in this correspondence as “The Organizations.” The Organizations offer the following comments, concerns and formal objections regarding the project and the recently released Draft ROD and FEIS.
We believe it is appropriate and imperative to once again point out that the current Forest Plan for the PSINF is critically out of date, lacks the framework for current land management and inadequately provides relevant management guidance for the growing needs and demand for multiple-use and motorized recreation, especially OHV recreational opportunities. The current Forest Plan did not foresee, and therefore does not account for, changes in technology such as e- bikes and a escalating growth of UTV/side-by-sides. Whereas the existing Forest Plan no longer contains “desired conditions” that are meaningful and realistic given the growth and expansion of the Front Range communities that border the PSINF and the associated needs of the citizens relying upon, using and recreating on the Forest. The Organizations would offer that subsequent planning documents, namely the South Rampart Travel Management Plan (SRTMP) prepared in 2011 more accurately reflects current and ongoing conditions and incorporates relevant and attainable desired conditions in addition to receiving substantial public support from affected user groups. One of the primary purposes of the SRMTP was to determine which motorized roads and trails in the South Rampart Planning Area of the PSINF were necessary to provide a diverse, functional and sustainable transportation system (similar to the purpose of this action). The SRTMP also sought to balance resource protection, public safety, current and anticipated future recreational use demands, and public and administrative access needs. Key issues that were already developed in the SRTMP and remain relevant to this action/project included1:
a. Trail sustainability and impacts of trail based recreation and dispersed camping to forest resources (i.e., soils, hydrology, wildlife, & vegetation).
b. Inadequate opportunities for trail-based recreation in the planning area.
c. Minimization of motorized/non-motorized user group conflicts.
d. Consistency of proposed uses with adjacent land uses and special management areas, including roadless areas and the Manitou Experimental Forest.
“Under [NEPA], an injury results not from the action authorized by the agency’s decision, but from the agency’s uninformed decision-making.” Comm. to Save Rio Hondo v. Lucero, 102 F.3d 445, 452 (10th Cir. 1996). Such is clearly the case here.
To read the entire Objections to DRAFT Record of Decision for the Pike and San Isabel National Forests Motorized Travel Management (MVUM) Analysis and Final Environmental Impact Statement (FEIS) download the PDF here.