TPA/COHVCO combined comments to the Grand Junction BLM RMP

March 17, 2009
Subject: GJFO Travel Management Notes

General Notes: BLM policy is to perform a analysis of all routes and produce a travel plan for all modes of transportation. The inventory of the general access and the recreation routes is almost complete (on the maps made available in February of 2009), however, routes constructed in recent years that access the gas industry infrastructure is not included. Because the gas industry routes are expected to be in operation for a long time, it is difficult to do a comprehensive travel management plan without this information on the maps.

We suggest that the Field Office consider designating motorized routes for intensive management only in SRMAs. These include the present SRMAs and those areas classified as SRMAs in the new RMP. Designating and implementing the motorized and non motorized routes throughout the field office is a daunting task. This high level of management can not be sustained over the entire field office. In remote areas with low visitor numbers, a less intensive prescription can be adopted. The "open to existing only" prescription is far more feasible. Maps, entry kiosks and strategically located signs, to make sure the visitors know these areas are no longer open to cross-country travel have proven sufficient in the past, but only when BLM is pro-active about getting the signs in place, and making sure maps are easily obtainable. It is also very important that the signs be maintained. This approach is consistent with the custodial nature of recreation management on BLM lands not classified as SRMAs.

It is unclear at this time what method GJFO will use to determine which routes will be designated into a travel management system. We do expect the GJFO staff to make the selection of the guidelines public during the alternative development phase of this analysis, and we do expect to be full participants throughout the entire process. We also expect rational explanations for any routes that the Field Office wants to remove from the inventory.

Map F:
This map does not show the network of gas industry roads that exist along with the county roads and the recreational trails. The representation is incomplete, and fails to represent all the needs of a comprehensive travel analysis. The gas roads have become an integral part of the recreation trail system. At this point in the planning process, the density, impacts and opportunities that these roads create are not available for public review or analysis.

In sections 11 and 12 , just south west of the Pyramid Rock ACEC is a system of single track routes that are used primarily by motorcycle trials riders. (specifically F551-F572-F502-F538-F536-F602-F575-F573-F580-F633-F579-F503-F715-F615 ) This is a very valuable recreation opportunity. We would like to see this opportunity developed for trials motorcyclists. It provides an opportunity for both casual use and organized competition of a very high caliber. The natural features of rock and slick rock are highly sought after for a quality trials location.

Map G:
Most of the routes north of South Shale Ridge are inaccessible to the public. For a variety of reasons the private land owners have found ways to block public access to this large area. We hope GJFO will prioritize the restoration of public access to this area in the RMP. (specifically G67-G142-G50-G92-G45-G26-G202-G14-G52)

Map I:
This map includes the Coal Gulch Rd. (Mesa Co V.8) to Ross Ridge. In the North Fruita Desert Plan several trails were analyzed for construction in this area. At this time, GJFO has made no progress toward the implementation of these routes that were a major public issue of contention during the planning process. In fact, the already analyzed and approved trails do not even show on the map. Please refer to the North Fruita Plan final map. We expect to see these trails on the map, and we expect the unfinished trails to be a high priority for implementation in the RMP.

Some of these unfinished trails include the MTB/ motorcycle trail parallel to V.8 Road and connecting to Ross Ridge, the reroute of the Lippan Wash single track trail around the waterfall, and the motorized single track alternative the Lippan Wash (Waterfall) Trail.

The Ross Ridge area is an ideal location to begin a long-distance dual sport /backcountry route with a destination in Debeque. A number of existing BLM and county routes can be connected to made this opportunity possible. A trail connection would have to be made from Ross Ridge to McCay Fork to the east. This connects to county Rd. X.9. This connects to County Rd. O.9 to South Shale Ridge Rd. then east to X.9, east to County Rd.200 and south on Roan Creek Rd. to Debeque. Less than one mile of trail needs to be constructed to create this excellent opportunity. The rest is on existing county or BLM routes.

Map K:
The single track trails west of 4.0 Rd. near Prairie Canyon Rd. are excellent recreation trails. Designation of this trail system s important to local residents. Please try to work with the Moab FO to assure that the other half of the trail system , in Utah remains available for public use. The routes are: K213-K212-K210-K209-K211-K41-KK115-K110-K48-K204-K111-K30-K102-K205-K203-K202-K195-K196-K194-K198-K197-K199-K51-K151-K152-K149-K147-K252-K62-K251-K253-K255-K254-K252-K231-K235-K238-K239-K78-K93—K244-K245

Map L:
This map include the Grand Valley Open Area and the lands between 27 ¼ Rd and 21 Rd. The combined north desert zone is seen and treated by the public as one large open area because of the total lack of visible management by BLM. Between 300,000 and 400,000 visits a year are recorded in the area. This is more than any other area in the field office, (and maybe the most for any recreation area in western Colorado). The north desert is a regional attraction. It is an ideal place to teach kids to how to ride, and the mild Grand Valley winters make it popular spot for people seeking a riding vacation away from the snow country.

However, the North Desert’s close proximity to the city of Grand Junction, and a lack of official presence, has allowed the growth of a number of activities that are a hazard to the recreationists who like to visit and ride in this area. We have witnessed drug dealing, drug-taking, trash dumping, prostitution, assaults, and other bad stuff. We often find used needles and other illegal drug materials, human waste, and alcoholic drinking trash.

The failure of BLM to make even the slightest effort to reduce these criminal activities is irresponsible. Public health and safety is one of the few well-defined responsibilities of the BLM, and the public has a right to expect the BLM to take considerably more interest in reducing the criminal activity in a heavily used recreation setting.

As BLM staff so very rarely visits the area, we will tell BLM that the criminal activities conflict with the legitimate recreationists during the nightime and early morning hours. The reason is, many recreationists have come from out of state and "camp out" in expensive motor homes, with their families, in the North Desert. They bring a substantial amount of valuable personal property. These innocent out-of-town visitors too often find themselves confronted by Individuals who need to fund a drug habit GJFO should be ashamed that these visitors must share the recreation area with a serious criminal element.

Furthermore, the persistence of the drug trade and other criminal activity in the city is facilitated by the BLM’s disregard for the fact that these people use the North Desert to escape from the city police jurisdiction. GJFO is conspicuously aiding and abetting the drug and crime problem in the Grand Valley via its neglect of the North Desert.

Therefore, we insist that in the RMP, GJFO make it a high priority to increase its presence in the North Desert, and we insist that GJFO coordinate with the County Sheriff’s Office to drive the criminal element out of the recreation area. For the managing agency (BLM) to continue to ignore this area is stunningly irresponsible.

At some time in the past, hundreds of small catch basins and sediment dams were installed throughout the north desert. This is a significant step to control sediment travel and selenium transfer to the Colorado River.

The proliferation of routes between 27 ¼ Rd. and 21 Rd. can only be attributed to the BLM ignoring a obvious management issue for decades.

Issues that complicate the designating specific routes : Lots of commercial uses-oil and gas transmission lines-power line corridors-grazing leases-numerous entry points along the urban interface-4 county roads in planning area- inability for the public to differentiate between routes due to density- possible displacement of historic uses- mild terrain- sparse vegetation- arid environment- Mancos clay is the dominant soil type with high levels of selenium- slow vegetative recovery rate

Lets look at the pluses (+) and minuses (-) of some different management options:

1. Define a designated route system between 27 ¼ Rd. and 21 Rd.
+ provides structure to an unstructured situation
+ may have a positive influence on off site impacts
– almost impossible to manage
– would require a large commitment of BLM resources
+ would be politically correct
– might be very unpopular

2. Expand the Grand Valley open Area all the way to 21 Rd. Fence the west side of 21 Rd to delineate the open area from the designated trails area of the adjoining North Fruita Desert. Leave pass-throughs at the designated trail intersections on the west side of 21 Rd.
+ a manageable approach that limits the proliferation of trails
+ probably acceptable to the OHV public
– probably not acceptable to the green community

The city of Grand Junction has proposed major development for 29 Rd. to the east of the airport. An overpass and cloverleaf are proposed. The city would like to develop a light industrial park and truck service facility on private and state land in this area. The present use as a trailhead for OHV recreation onto BLM lands would be displaced.

There is obviously a huge demand for large, open motorized recreation areas. The exceptionally high annual visitor numbers for the North Desert makes this abundantly clear. Accommodations for the displaced BLM visitors must be built into the planning and development strategies for the proposed industrial development. The above management options would help to offset this loss.

Although we would prefer to keep the area west of 27-1/4 Road "Limited to Existing" prescription, we realize there is a considerable amount of diversity within the motorized recreation community. To effectively keep the area west of 27-1/4 Road from becoming another Open Area, GJFO should fence the west side of 27-1/4 Road to clearly delineate the different areas, and install clear and unmistakable instructions to the visitors of the change in regulation from "open" area to "Limited" area at the "pass-throughs.".

Map O:
Grand Mesa Slopes-The existing system of bicycle trails in the Palisade area are not shown on the map.

The urban interface zone accessed by the 34 & C Rd. entry is currently classified as an SRMA. The area has received only custodial management over the past decade. The plan that was written and adopted for the area in the early 1990s has not been implemented. As a result the area continues to be unmanaged. We recommend that the Grand Mesa Slopes be reclassified to an ERMA. The prescription for ERMAs is custodial management.

We recommend that all the existing routes be designated except in the vicinity of the 34 & C Rd. entrance (Area 01). In Area 01 barriers and fences need to be erected to define the designated routes that lead to the roads and trails beyond. The fragmented ownership pattern would make enforcement of a designated route system in the rest of the Grand Mesa Slopes very difficult.

Map P: Bangs Canyon
Bangs Canyon has already had the travel management process applied to it in the Bangs Canyon Implementation Plan of 2006. Further transportation planning should not be required. Routes closed and those designated for administrative use only are not delineated on map P. This is a mistake. Trails proposed for areas 1,4,5,6 are not shown on the map. This is also a mistake. Some closed routes have been removed, while others remain on the map. Please clarify which routes are to remain open to public access and which are scheduled for closure by the previous decision, and, please include the new routes, approved in the Bangs Plan, on the inventory maps. Leaving them off is a mistake.

This map does not accurately show the present condition. Some of the corrections that need to be made include:
• P152 is closed east of P 1030
• P270 is closed
• P219 is closed
• P106 is closed
• P450 has a locked gate at P451
• P288 has a locked gate at the section line between section 34 and 35
• Hiking and bicycle trails accessed from the First Flats Trailhead are not shown.
• A maze of trails between P735 and P665 is not shown
• The Old Kiln Trail is not shown
• The newly constructed single track trail in area 4 –connecting P1027 to P2 is not shown.
• The proposed trails (5C as shown on Bangs Map 5, March 2006) on Horse Mesa and Hells Hole are not shown.

GJFO seems to have hit a snag in the implementation of motorized trails as described in the Bangs Canyon EA FONSI. Progress on the Snyder Flats single track trails for motorcycles and bicycles appears to be stalled.

We suggest, as a solution, that the single track trails shown in the original plan be moved. The mileage can be compensated for by the construction of the 5C trails as shown in the final EA for Bangs Canyon. In addition, single track trails should be added in area 4 and area 5 to provide the same level of opportunity as was planned for in the 2006 EA. The demand for quality, purpose built single track experience has not diminished, but the supply has been stalled. As noted above, there is considerable diversity within the off-highway community, and the Bangs Canyon trail system is a handsome addition to the Grand Valley motorized opportunity spectrum.

Our recommendation for additional single track trails in areas 4 and 5 are presented on the attached map.

This issue can be resolved by a supplemental EA to the Bangs Canyon Implementation EA or through the RMP process. We suggest a supplemental EA, completed in a timely way, due to the high public interest that GJFO generated in the plan and in the trails during 2007 and 2008.

Map Q: Glade Park
The BLM lands north of DS Rd. beginning at the Utah border and extending east to Q27 and north to the NCA border have a series of routes that are not shown on the map.

The area east of Miracle Rock, near route Q528 has many more routes than are shown on the map. This is a popular hunting area. Access is important to hunters.

These omissions are a mistake, and need to be corrected.

Map S: Cactus Park/ Dominguez
The existing trail network in Cactus Park is entirely user created. It includes county roads, farm roads and ATV trails. Many of the trails on the west and north east portions of the area (along the ridge and those connecting to county Rd.31.4) are dead ends. From a recreation and resource point of view, these routes should be connected to make loop trails. In addition, the existing trails that run near the top of the ridge (in a north south direction) should be joined to the routes to the south. This would make a connection that will be beneficial to the recreation trail system as well.

Due to the evidence of unmanaged camping and day use, a trailhead or primitive campground near highway 141 (S648-S651-S646) would help reduce impacts from visitors.

Access to Dad’s Flat is important . routes S189-S379-S106-S9

We recommend that S117 and S161 remain open to motorized use as ATV trails. These routes provide spectacular views of the WSA for those not physically able to hike in. These routes end on the tops of cliffs, so intrusion of vehicles into the WSA is not likely.

The area to the west of Divide Rd. in the vicinity of routes-S197-S354-S356 and west to S7 –has seen a lot of cross country travel ( currently legal) by fire wood and stone gatherers. This un managed activity is stripping vegetation and disturbing stable soils. We recommend that if these activities continue to be allowed the routes of travel must be delineated and cross country travel prohibited.

The two through routes between Cactus Park and county Rd.24.2 are important recreational routes. They form part of the Tabaguhe trail. The routes take many different numbers in the BLM map. They do string together to make a variety of recreation experiences for the long distance off road “adventure” trail opportunity.

Map U: Granite Creek
It is vitally important that Sheep Creek Rd. (U676) and the connecting routes at the top of the mesa remain open to motorized access. These routes along with U199-U664-U675-U662-U665-U671- provide high quality OHV adventure and long distance opportunity. The remote nature of Ryan Park and Granite Creek are highly prized by the OHV community. These are the only unpaved connectors linking Gateway to Glade Park and Grand Junction. In addition these routes connect to even more scenic adventure opportunities to the west on Grand County roads in Utah.

Delores Point offers a spectacular OHV opportunity. The mix of easy roads and technical trails provides a quality experience of great riding and views of the south west canyons and cliffs. The specific routes include: U520-U544-U605-U599-U135-U110-U107-U382-U380-U379-U71-U37-U35-U36-U38-U47-U77-U80-U84-U731-U425-U69-U422-U56-U730.

Map V: Gateway Mesas
This map illustrates a vast undeveloped potential resource for motorized and non motorized recreation. The routes that remain from the historic mining activities create the basis for a destination recreation opportunity. We see this as a textbook opportunity to develop a true multiple use complex. The existing routes, plus purpose built single track trails, will provide for extensive and high quality Jeep, ATV and motorcycle trails. The views are spectacular. The history is fascinating. The trails are entertaining.

The rugged and remote nature of the mesas have great allure to locals and destination vacationers alike. The rocky nature of many locations is well suited to OHV. The routes created by miners up to 100 years ago are still often usable with no maintenance at all. Comprehensive signing and visitor maps will increase the fun and benefit the safety of all visitors.

We encourage that all the existing through routes be designated as multiple use trails. We also encourage that day use and overnight facilities are written into the plan so the public can better access the undiscovered place without the impacts from camping.

The number of routes and the complex nature of ground disturbance in the Gateway Mesa area makes route designation a very big task. We suggest that this work can be accomplished using a combination of BLM and NGO help in a collaborative process.

In recent conversations with the Grand Valley Ranger District of the GMUG, the possibility of designating or constructing interconnecting trails between the Gateway Mesas and the Uncompaghre Plateau motorized trails was favorably received by the District Ranger. We urge GJFO and the Grand Valley RD to communicate and co- operate on these potential routes. TPA would be willing to work with both agencies to help accomplish this goal.