Archive | March, 2012

Letter to USDA in opposition of the report entitled “A Comprehensive Framework…”


March 9, 2012

Letter to USDA in opposition of the report entitled:
“A Comprehensive Framework for Off-Highway Vehicle Trail Management”

  101 Constitution Avenue, NW, Suite 800W
Washington, DC 20001
(P) 202-742-4301
(F) 202-742-4304

March 9, 2012

The Honorable Tom Vilsack
Secretary U.S. Department of Agriculture 1400 Independence Ave., S.W. Washington, DC 20250

Dear Secretary Vilsack:
As associations that represent the interests of millions of responsible motorized recreation enthusiasts, we oppose the U.S. Department of Agriculture (USDA) report entitled A Comprehensive Framework for Off-Highway Vehicle Trail Management, referred to as the Report, which was recently pulled from the U.S. Forest Service (USFS) website. We have questions concerning the planning and review process of the Report, the content of the initial Report, and any plan to reissue the Report. Moreover, we seek to clarify implications in the Report that portray the off-highway vehicle (OHV) community in a negative light. The document should be fact based and neutral.

We, the undersigned, believe that this new Report may result in a deleterious relationship between the responsible motorized community and the USDA.

According to the introduction in the Report, the purpose of the document is to “… help OHV trail managers develop sustainable trails and protect the environment surrounding the trails.” We agree that this is a worthy goal and appreciate the intentions of the USDA. However, the Report only serves to strengthen the current underlying apprehension of our community toward the USDA and other federal stakeholders with regard to trail management.

While the author references many OHV groups and associations, we understand that the USDA or any other federal agency associated with this document never consulted with the motorized community in the Report’s initial planning and review process. We find this to be disconcerting, since the Report focuses on OHV trail management. The author acknowledges two non-governmental groups (International Mountain Bicycling Association [IMBA] and Alaska Trails) as experts in OHV trail management. Although IMBA is not an OHV expert per se, its trail management materials and techniques are respected because of the similarities in design considerations.

Without being mentioned in the acknowledgement section, the author does mention within the Report two examples of excellent OHV management materials made available by the American Motorcyclist Association (AMA) and National Off-Highway Vehicle Conservation Council (NOHVCC). They are the following: the AMA Off-Highway Motorcycle & ATV Trails Guidelines for Design, Construction, Maintenance and User Satisfaction; and the NOHVCC Management Guidelines for OHV Recreation.

A group that is not mentioned in the acknowledgement section, but is cited numerous times throughout the Report, is Wildlands CPR. This group has extreme and radical opinions concerning the use of OHVs. For example, Wildlands CPR calls for OHV reform because “Off-road vehicles can go nearly anywhere, killing and harassing wildlife and destroying vegetation.” The group also states on its website that, “As a result of our on-going efforts, so far (with 47 decisions still to come), the Forest Service has removed 7,890 miles of roads and motorized trails from the designated travel system, and refused to designate 28,679 miles of user-created routes.”

Why does the U.S. Forest Service cite such a radical and extreme group for an official federal report that should be fact based and neutral? The author goes further and adopts the Wildlands CPR’s entire Environmental Analysis, which correlates OHVs and the use of trails with climate change. In fact, the Report states that OHV use causes “increase[s] in frequency and intensity of weather events.” A statement such as this transcends the realm of rationality.

In the Appendix D: Best Management Practices of the Report, the author admits to citing a Wildlands CPR document (“Best Management Practices for Off-Road Vehicle Use On Forestlands”) that is anti-OHV for the basis of best management practices. For example, the Appendix references a Wildlands CPR proposal that no routes/trails should be allowed in “citizen or agency proposed wilderness … and other lands with wilderness character.” This best management practice usurps congressional authority in the process to designate Wilderness. Only Congress can designate Wilderness. Moreover, “wilderness characteristics” was the defining language used to describe the Department of the Interior’s “Wild Lands” policy.

Furthermore, the Report concludes with a paragraph that indicates a bias of the author against the OHV community. The author states, “This framework was developed to help trail managers corral the OHV management dragon. The author hopes it has provided some insight into the nature of OHV trails and some tools to help keep the beast at bay. Happy herding and happy trails!” We find this statement derogatory and unfitting to be in an official government report.

We understand this Report was issued and made available to the many agencies within the federal government, but has since been pulled from the USFS website. Based on our aforementioned concerns, we applaud the USDA for this action. However, we have questions about what is coming next concerning republishing this Report. Will our areas of concern be addressed or will there be a disclaimer? Our groups believe a disclaimer is insufficient because the material sourced from Wildlands CPR is not supported with scientifically based data and should not be included in the Report.

We encourage the USDA to continue to engage the public in its deliberations on trail management. Our members stand ready to serve as a resource for you as you further consider the future composition of the Report.

Thank you for your consideration of our request. We look forward to receiving your timely response to the questions and comments above.

All-Terrain Vehicle Association
American Motorcyclist Association
BlueRibbon Coalition
Colorado Off-Highway Vehicle Coalition
Colorado Snowmobile Association
Trails Preservation Alliance
Utah Shared Access Alliance

The Honorable Tom Tidwell
US Forest Service 1400 Independence Ave., SW
Washington, D.C. 20250-0003

The Honorable Jon Jarvis
National Park Service 1849 C Street NW
Washington, DC 20240

Victor M. Mendez
Federal Highway Administration
1200 New Jersey Ave., SE
Washington, DC 20590





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Economic impact of expanding Wilderness designations


March 2, 2012

Economic impact of expanding Wilderness designations

This is the TPA and COHVCO initial reponse to the Udall’s plan to make more wildernesses in Colorado.

  Federal lands designated as Wilderness are the most restricted, least available public lands in the country, as these areas are supposed to reflect the lands in an “untrammeled by man” way.  Over 20% of the Colorado mountains are currently managed as Wilderness. Wilderness areas impose significant limitations on use that often directly conflicts with the public’s increasing desire for access to public lands. The simple fact is most people will never set foot in a federally designated Wilderness area, as there is no access for most users of public lands. The negative economic impacts of Wilderness restrictions to adjacent communities caused the Utah State Legislature to adopt a resolution requesting the federal government not to designate additional Wilderness in the state due to the negative economic impacts.  Wilderness limitations result in thousands of dollars in lost salary to families and tens of thousands in lost payroll and revenue for local communities to maintain roads and operate schools.  Our Organizations are compelled to voice our concerns on these issues in response to the Wilderness proposal from Senator Udall.

Our Organizations share many of the same concerns that prompted the Utah Legislature to act and believe these concerns have been completely overlooked in the creation of the most recent Wilderness proposal from Senator Udall’s Office.  Senator Udall’s proposal would create an additional 235,000 acres of designated Wilderness, mainly in Summit, Eagle and Pitkin counties, closing areas that currently have extensive trail networks and a wide range of recreational resources.  These closures would result in significant negative economic impacts that simply are not addressed in Senator Udall’s proposal.  The proposal also fails to explain why more restrictions are needed beyond noting a certain user group likes the area, and does not want the public to disturb them.  This is not the basis for good management of public lands.

While most people think of a wilderness as a large forest area where recreational opportunities are plentiful and easily accessed with campgrounds providing the ability to drive to a fishing hole, dispersed recreation, biking and family trips. Unfortunately these opportunities are almost completely excluded after federal designation of the area as Wilderness. A federally designated Wilderness area is an area that may only be accessed by horse or foot without basic facilities for recreation and maybe not be flown over by aircraft.  People have been arrested for crash landing hand gliders on areas designated as Wilderness.   Motor vehicles and mechanized travel is strictly forbidden in designated Wilderness areas, and until recently could not even be used for emergency response for injured people in the area.  Even for emergency response actions, federal approval is needed before the emergency responders can access the Wilderness. 

The restrictions from designated Wilderness have significant negative economic impacts on communities adjacent to the Wilderness areas, as federal planners estimate that 85% of people who do not find the type of recreation they are looking for will simply move on seeking the recreation rather than change.  The closure of these areas for 85% of users can have drastic economic impacts to communities, as most Colorado communities are solely reliant on tourism as more traditional industries are no longer present. These negative economic impacts add up rather rapidly. A recent Utah State study found that counties with significant Wilderness designations average $1,446 less in per household income,  $37,500 less in average payroll and generated $92,900 less in tax revenue than similarly located counties.  These are some very scary numbers when you realize that almost every county west of Denver has significant designated Wilderness in their jurisdictions. This data is simply not addressed in any of the Senators assertions of economic benefit from the closures provided in the proposal.

The expansion of federally designated Wilderness areas is even more troubling when other restrictions  on public lands usage are taken into account, as many other management designations preclude the use of motor vehicles.  These areas include areas of critical environmental concern, wild and scenic rivers, special interest areas, erroneously managed roadless areas and areas that simply preclude motorized access for social reasons.  Recent proposals and decisions for several federal planning offices have closed between 40% and 55% of existing trails that remain on the small portion of those planning areas where motorized access is still allowed.  These areas are becoming ever more critical to public access as  areas that have historically been open to all members of the public are closed in favor of  a small portion of the public.

The expansion of federally designated Wilderness boundaries in Senator Udall’s proposal also directly undermines the years of public involvement and dozens of public meetings that occurred in the development of the Colorado Roadless Rule.  While the Wilderness proposal nakedly asserts broad public support, the outreach is almost non-existent when compared to the years of true public input obtained for development of the Colorado Roadless Rule. The Organizations believe that the extensive on the ground analysis that occurred with the Roadless proposal must be taken into account with the Wilderness proposal.  When the Wilderness proposal areas are compared to the publicly developed roadless area, only a small fraction of the Wilderness proposal area was found even suitable for the lesser level of protection provided with a roadless designation.

The increasing age of the American population also weighs heavily against reducing motorized access to public lands. Retirees have significant time and resources available to access public lands for recreation.  While there are some persons who can continue hiking long distances after retirement we don’t think this is the normal user or that this user group is of sufficient size to expand motorized closures beyond the existing levels of closures.  Most users simply don’t want to hike all day to cast their line into a stream only a few times because they need to start walking back or have to pass on obtaining a trophy elk or deer simply because they are unable to remove it in any other manner than on foot.  These needs for motorized access simply are not addressed in the proposal.

The Presidents America’s Great Outdoors initiative seeks to expand and develop the American populations connection with public lands to develop health and fitness.  This initiative also weighs against motorized closures, as motorized access is by far and away the most common means for the first time user of public lands to become aware of the resources and opportunities that are provided.  Research indicates that a couple of hours of slow to moderate motorized recreation is comparable to an extended workout in a gym.  The Organizations believe that this alternative is a significantly more desirable experience for most users than a more traditional gym workout.

The motor vehicle is an integral part of all portions of our life including recreation. Designating more lands where people will not have motor vehicle access will not alter this characteristic of our society.  The Forest Service’s Rural Development office recently found that a developed trail system open to all users was a significant economic contributor to small communities and these trails should not be limited for any one user group.  This position is supported by Colorado State Parks data that indicates users demands for a motor vehicle as part of their recreational experience has increased over 150% since 1990. 

While there are forest uses that do not require a motor vehicle, research indicates that the number of people pursuing these activities have significantly declined since the early 1990’s.  This decline has created a supply of these resources that already far exceeds public demand.  The US Fish and Wildlife Service also has addressed the economic impact of designating Wilderness.  While the Fish and Wildlife service found that wildlife watching was a significant contributor to the Colorado economy, they also found that over 60% of this benefit directly resulted from people purchasing trucks, campers, OHV’s and boats as part of this pursuit.
Given that 85% of users will simply keep driving if their desired recreation is not found in an area, directly resulting  in thousands of dollars of lost payroll to local families and badly needed payroll and tax revenue for schools and roads any proposal must be strictly reviewed to minimize these risks.  Unfortunately, Senator Udall’s Wilderness expansion proposal does not clarify how these impact will be avoided, which leads us to the conclusion that these impacts have not been seriously reviewed or worse have been completely overlooked.   This is simply not acceptable given the current economic conditions and the resources that have been expended to attempt to remedy this problem. There is simply no need for more Wilderness, the risk to Colorado communities is simply too great





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