July 12, 2011
This is an excerpt, please download the pdf to read the entire document.
Thomas Vilsack, Secretary of Agriculture
Emailed this date to:
Dear Secretary Vilsack:
Please accept this correspondence as the joint comments of the Colorado Off-Highway Vehicle Coalition (“COHVCO”), Colorado Snowmobile Association (“CSA”) and the Trails Preservation Alliance (“TPA”). For purposes of this document, we will refer to all organizations as the Organizations. The Organizations thank you for the opportunity to voice our support for a modified version of Alternative 2 in proposed Colorado Roadless Area Rule (“CRA Rule”). The Organizations support for this alternative is contingent upon the removal of the principal of designated upper tier areas. The Organizations are strongly opposed to the principal of “upper tier” areas as such a designation does not fit the purpose or intent of the rulemaking, directly contradicts the desire for public support and clarity sought to be achieved by the Colorado petition and significantly restricts management opportunities for upper tier roadless areas. The arguments supporting the removal of the designation of upper tier are based upon the RDEIS and a heavy dose of scientific common sense.
COHVCO is a grassroots advocacy organization of approximately 2,500 members seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of 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.
TPA is a 100 percent volunteer organization whose intention is to be a viable partner, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of trail riding. The TPA acts as an advocate of the sport and takes the necessary action to insure that the USFS and BLM allocate to trail riding a fair and equitable percentage of access to public lands.
CSA was founded in 1970 to unite winter motorized recreationists across the state to enjoy their passion. CSA currently has 2,500 members. CSA has also become the voice of organized snowmobiling seeking to advance, promote and preserve the sport of snowmobiling through work with Federal and state land management agencies and local, state and federal legislators telling the truth about our sport. While CSA is aware that roadless designations are normally not an issue for snowmobile usage, CSA is also very concerned that forest resources are properly managed and preserved for future generation’s recreational usage and enjoyment.
The Organizations believe the Forest Service has done a good job of separating the proposed Colorado Roadless Rule from Travel Management Planning in the numerous public hearings that have occurred throughout the state to address public concerns regarding the proposal. As Forest Service representatives are aware, there is a significant amount of confusion and frustration from the overlap of these planning tools. The Organizations believe that the meetings bright line distinction regarding the differences in these management tools has helped the public understand these differences. The Organizations believe it is critical that the bright line standard separating these tools remains clear in the final rule to avoid any increase in frustration of the public regarding the Roadless Rule.
note: This is an excerpt, please download the pdf (above) to read the entire document.