Archive | October, 2012

The continued analysis of the GNF TMP, Record of Decision


October 25, 2012

Grand Mesa, Uncompahgre and Gunnison National Forest
Scott Armentrout
2250 Highway 50
Delta, Colorado 81416
RE: Situation surrounding implementation of GMUG Travel Plan

Dear Mr. Armentrout;
We would like to thank you for the opportunity to meet with you on the 26th day of September at the Region 2 offices to candidly discuss our on-going concerns with the Travel Management Plan (“TMP”) for the Gunnison Basin. Your time and courtesy are appreciated and it was good to hear your thoughts on OHV recreation and your experience with clubs from your last Forest Service assignments.

As we discussed, the TPA and COHVCO feel there were many errors made in the GMUG travel plan, which are now directly contributing to the high levels of frustrations and conflict between the Forest managers and members of the public during the implementation of the TMP. You had requested that we outline the specifics of these errors in a letter to you. We are providing this correspondence in the hope of assisting in resolution of the rapidly escalating public opposition to the TMP. Our Organizations remain ready and willing to partner, with any combination of volunteers, grant applications or direct funding to assist in resolution of any site specific issues that maybe identified. Clearly this heightened level of frustration is not beneficial to the agency or any user group.

Our Organizations have had on-going concerns regarding the lack of balance of multiple uses and accurate adoption of wildlife management standards in the TMP. These concerns were the basis of our comments and the basis of our appeal of the TMP. While this appeal was declined, it appears that many of these concerns were also not resolved in the manner anticipated under the TMP. Our Organizations believe an in depth analysis of the current status of research on specific species may assist in resolving some conflicts surrounding the TMP as management guidelines have loosened significantly for several species management decisions since the TMP was finalized. Newly released research has clarified the lack of basis in theoretical concerns often relied on for development of plans at the time the TMP was developed. Travel Management is a fluid and on-going process that must be revised to adapt to newly released information and on the ground conditions.

The Organizations are also aware the GMUG has a draft Resource Management Plan being developed. While this correspondence most directly relates to the previously released Travel Management Plan, many of these issues are also involved in the draft Resource Management Plan. The Organizations believe a review of the draft RMP must also occur to insure that the most accurate and up to date science is relied on for management of the GMUG lands over the life of the RMP. Accurate information will insure that further conflict is not created with future planning initiatives as a result of the use of out of date information for standards in the RMP.


To read the letter in full please download the PDF.







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Central Mountains Wilderness and Forest Health Summit


October 20, 2012


Senator Mark Udall Office
Att: Jill Ozarski
999 18th Street
North Tower Suite I 525
Denver, CO 80202
RE: Central Mountains Wilderness & Forest Health Summit

Dear Ms. Ozarski; I wanted to follow up on our brief discussion at the Governor’s Forest Health Summit on October 12, 2012. I thought the presentation was great and the compelling discussion outlining the undeniable situation that surrounds poor forest health levels was very welcome. While the mountain pine beetle has heavily impacted Northern Colorado, most of Southern Colorado forests have been spared the wide scale devastation that has impacted northern Colorado. As was noted at the Summit, the explosion of the spruce beetle out of the Weminuche Wilderness and across Wolf Creek Pass has greatly expanded areas that are going to be experiencing significant declines in forest health from these infestations.

The Governor’s Forest Health summit highlighted many different facets of forest health concerns, the Organizations are aware much of this information has been echoed in other proceedings, both involving Senator Udall’s hearing earlier this summer in Colorado Springs and Representative Tipton’s House Committee hearing in Montrose. The Organizations welcome and continue to support the active role that Senator Udall has taken on the forest health issue. While wildfire activity is a highly publicized result of poor forest health, much of the beetle killed forests will not be impacted by wildfire. Rather the bulk of these areas will be impacted by gravity, causing the trees to fall in tangled snarls blocking trails and safe access for all users. These snarls will limit the ability of all users to safely hunt and fish in areas accessed by trails where falling trees have limited cross country foot travel.

The Organizations are aware that once again there is renewed pressure from the Hidden Gems Campaign to move forward with the Central Mountains Wilderness proposal that your office has been reviewing. As a result of this renewed push for Wilderness, the Organizations have to again state our vigorous opposition to the proposal and note that almost all management activity that has been found necessary to protect forest health in the Summit and other hearings are completely prohibited in a Wilderness area. While there are general assertions that Wilderness designations improve forest health, these assertions are not supported by any science and are directly contradicted by the expert testimony that has been provided in numerous public hearings and peer reviewed published research documents created by both State and Federal Land managers. These findings must not be overlooked when any land management decision is made.

Our Organizations are very concerned that the declining forest health will impact all facets of recreation in Colorado, and we are frankly puzzled as to the lack of interest in forest health issues that has been displayed by many other user groups. The Organizations are aware that the motorized community is comparatively well situated to address trees falling on trails, as motorized routes are often maintained with Forest Service good management crews, which are exclusively funded by monies generated by OHV registrations. A copy of the Colorado State Trails program fact sheet in enclosed with these comments for further information on the program. There are currently 14 good management crews, made up of approximately 5 full time seasonal employees, assigned to Ranger Districts throughout Colorado and an additional team that travels the state on an as needed basis. Every year more teams are formed to maintain trails on Ranger Districts. This year these teams spent most of their time removing dead trees from trails and adjacent areas.

The Organizations are aware other user groups simply do not have the resources to address large scale tree falls on trails. While volunteers are able to maintain small portions of non-motorized routes, these resources are not able to address threats at the level of the spruce and pine beetle epidemics. While these resources are limited, land managers are able to allow mechanized activity, such as the use of motor vehicle and chainsaws, in maintenance of non-motorized routes outside Wilderness areas. This flexible management authority allows these limited resources to be effectively applied to non-motorized routes. Unfortunately, land managers are severely hampered by Congressional Wilderness restrictions, as they lack the flexibility to allow mechanized assistance in maintaining routes in Wilderness. The Organizations must note that any assertion that thousands of dead trees could be effectively dealt with by using hand saws and horses probably lacks any realistic basis.

1. Deteriorating forest health threatens significant portions of the Colorado Economy.

Healthy forests are exceptionally relevant to our members, as frequently our members are a broad spectrum outdoor enthusiast, meaning they may be using their OHV for recreation one weekend but the next weekend they will be walking for pleasure (88.9%), using a developing camping facility (44.7%), using a Wilderness or primitive area (58.1%), fishing (44.6%) or hunting (28.4).1 The Organizations believe that the unhealthy forests pose a significant economic risk to the state of Colorado and a significant safety threat to any user of the forest. As we have previously discussed, a snowmobiler was killed in the Snowy Range portion of the Medicine Bow/Routt National forest after a falling dead tree struck him on a maintained trail. While we hope this type of an incident is an isolated incident, the Organizations have to believe similar incidents could occur again given the number of backcountry recreational users and the number of dead trees adjacent to trails. These type of incidents will not foster expanded use of Colorado’s trail network, but rather encourage other types of activity.

Recreation is a significant contributor to the Colorado economy as CPW research indicates 90% of Colorado residents are trails users. CPW has determined hunting and fishing contributes $2.5 billion annually to the Colorado economy. The Outdoor Industry Foundation determined outdoor non-motorized recreation contributes $2.5 billion to Colorado’s Economy and COHVCO’s economic impact study determined that OHV recreation contributes $1 billion per year. The Organizations are aware that these studies are not designed to be mutually exclusive and have significant overlap in their calculation methodology. These economic impacts are cited here to clarify that the economic impact of recreation is clearly significant. All of these activities will undoubtedly be negatively impacted by the high number of falling trees, as a tangled web of trees poses significant obstacles to anyone wanting to cross that area regardless of why they are there.

While the motorized community has developed a funding source to remove and deal with dead trees that may block multiple use motorized routes on public lands, the trail users seeking to maintain non-motorized routes lack a similar funding mechanism. The blocking of trails in designated Wilderness areas will negatively impact local economies as recreational users will no longer have access to these opportunities, as maintenance of these opportunities will simply be cost prohibitive. Blockages of non-motorized routes could also significantly increase socially based user conflicts on public lands, as non-motorized users may seek closure of multiple use trails, previously maintained by good management crews, in order to address the loss of unmaintained non-motorized trails. This type of a proposal would be VIGOROUSLY opposed by the motorized community.

The Organizations believe there is a bigger question that must be addressed in the discussion of forest health and economics before ever looking at expanding current Wilderness boundaries. Mainly, how do agencies maintain trails that clearly will be blocked by falling trees in the existing Wilderness areas? The Organizations believe this question must be answered before any discussion of user need for more Wilderness is started. Expanding management decisions, that are clearly not sustainable, simply makes no sense as these newly expanded areas will simply be lost to all recreation once significant trail maintenance is needed.

2. New research specifically identifes the negative impact that designated Wilderness has on forest health.

Attempting to manage the current forest health issues as an isolated incident in time that will not be repeated would be a mistake. Research indicates both mountain pine beetle and spruce beetle infestations have happened numerous times in the last century and predictions indicate this infestations will become more frequent and more severe. Management must address the fact that these pest infestations will probably happen again in our lifetimes and management decisions must be tailored to provide for long term management of a long term problem. The need for long term thinning and active management is specifically identified as an effective tool for management of these infestations in the Forest Service report prepared at your offices request. Clearly thinning and mitigation actions will not occur forest wide in a short period of time, these actions may take many years and be part of a more proactive management regime for Colorado public lands.

This long term vision and management opportunity will not be aided with the imposition of new Wilderness restrictions. The Organizations are aware that some of the areas proposed for additional Wilderness area are very difficult to thin. While this may be the case for some areas, other areas are available for thinning and active management. Obviously given the scale of thinning and remediation that is necessary, it could be some time before these areas could be thinned.

Wilderness and improperly managed Roadless areas were previously identified by the Forest Service as a significant factor contributing to and limiting the ability to manage the mountain pine beetle epidemic. This report is not discussed at length in these comments as previous comments have addressed this report. Since the release of this Forest Service report, additional Colorado Forest Service researchers have reached the same conclusions. The Colorado State Forest Service’s 2011 Forest Health report specifically identifies a major contributing factor to the spruce beetle outbreak as:

“Outbreaks typically occur several years after storms cause windthrow in spruce trees, which are susceptible to blowdown because of their shallow root system. Spruce beetles initially breed in the freshly windthrown trees, and subsequent generations attack and kill live, standing trees.” 2

The lack of access to Wilderness areas to manage blow down areas is specifically identified as a major limitation in forest managers ability to address spruce beetle outbreak. These blow downs are directly identified as causing the spruce beetle outbreaks. The 2011 State Forest Service report specifically states:

“Many areas where spruce beetle outbreaks occur are remote, inaccessible or in designated wilderness areas. Therefore, in most cases, foresters can take little or no action to reduce losses caused by this aggressive bark beetle. However, individual trees can be protected on some landscapes.”3

The Organizations must note the 2011 State Forest Service report extensively discussed how EVERY major spruce beetle outbreak in the state of Colorado was associated with a major wind event in a Wilderness area, which could not be managed by foresters. A copy of this report has been included with these comments to allow for a review of this discussion.

The Organizations urge your office to allow land managers to make science based decisions for the management of public lands and allow active forest management for as much public land as possible. While supporters of Wilderness may provide discussions that tug at heart strings regarding the Wilderness ideal, scientific research has concluded this ideal directly and significantly contributes to the overall poor health conditions of Colorado forests.

3. Decisions to remove specific areas from previous Wilderness legislation must be supported.

The Organizations have to note that the most recent call to action from the Hidden Gems Proposal is seeking to obtain inclusion of the Lower Piney, Elliot Ridge, Crazy Horse and other areas in the proposed Wilderness legislation. These areas were removed from Rep. Polis legislation as a result of ongoing good faith discussions between user groups facilitated by Rep. Polis office based on the high degree of mechanized and motorized that occurs in these areas throughout the year. These decisions to exclude these areas must be honored moving forward.

Attempts to include these areas in on-going discussions will make it very hard to move forward with any discussions regarding new areas. These attempts also significantly increase frustrations between the groups involved in the user group discussions. The motorized community had no input in the creation of any portion of the wilderness proposal, prior to involvement with governmental representatives. Once an area is removed from the Proposal, the area must remain off the table for all future discussions. The Organizations can find little solace in a consensus position regarding management of these areas, that will simply ignored by a party to that process when it is convenient.

The Organizations have been very hesitant to undertake user group type discussions on Wilderness as areas excluded in one round of legislation are frequently returned immediately back on the table after legislation is passed. New proposals simply attempt to move forward, regardless of the previous consensus regarding management. The ongoing attempts to reintroduce excluded areas into the good faith discussions prior to any legislation do nothing more than provide concrete reasons to clarify why we are hesitant to enter into such discussions at anytime.

The Organizations must also note that the High Country Snowmobile Club has received a grant from the State Parks Snowmobile program for the purchase of a snowcat to begin grooming previously ungroomed trails in the areas north of the existing Eagles Nest Wilderness. A high percentage of these groomed winter trails are routes that remain open for summer motorized recreation in the summer. The Organizations are aware you are planning on discussing the Central Mountains Proposal with the High Country Club independently, but we would like to confirm this grooming program is vigorously supported by the Organizations. As the High Country Club will confirm there is broad support for this grooming program from all user groups, and vigorous support for the proposal from the Forest Service.

4. Conclusion.

The Organizations are aware there is an ongoing push to renew waning interest in Wilderness proposals in the State. This initiative is completely at odds with the overwhelming body of research that has emerged from recent hearing and seminars regarding forest health. While these seminars and meetings have addressed forest health in a forestry context, the Organizations believe declining forest health poses a significant threat to all forms of outdoor recreation in the state of Colorado. The Organizations are puzzled as to why other user groups are not seeing these threats to access as a more significant threat to recreation in Colorado.

If you would like a copy of any of the reports relied on in these comments or have questions please feel free to contact Scott Jones at 508 Ashford Drive, Longmont CO 80504. His phone is (518)281-5810.


John Bonngiovanni
Chairman and President
Colorado OHV Coalition

Don.E. Riggle
Director of Operations
Trails Preservation Alliance

Scott Jones, Esq.
COHVCO CO-Chairman

1Cordell et al; USFS Research Station; Off-Highway Vehicle Recreation in the United States and its Regions and States; A National Report from the National Survey on Recreation and the Environment February, 2008; at pg 41-43.

2Colorado State Forest Service; 2011 Report on the Health of Colorado’s Forests; at pg 9.

3Colorado State Forest Service; 2011 Report on the Health of Colorado’s Forests; at pg 11.







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Tenderfoot Trail Project


October 3, 2012


Rep. Jared Polis
Att: Nissa Erickson
101 West Main Street Suite 101D
PO Box 1453
Frisco, CO 80443

RE: Tenderfoot Trail Project

Dear Ms. Erickson;

The above referenced Organizations are contacting you to address concerns recently raised with regard to the proposed development of a multiple use single track trail system on Forest Service lands in the vicinity of Tenderfoot Mountain outside Dillon, Colorado. For purposes of these comments, this project will be referred to as “the Proposal”.  The Organizations do not believe the specific facts surrounding the Proposal have been fully explained to the public, as only the scoping portion of the Federal planning process has been completed. The Organizations believe once the Proposal and levels of associated planning already performed are completely understood, many of these concerns will be minimized.

Prior to addressing the merits of the Proposal, we believe a brief summary of each Organization is needed.  The Colorado Off-Highway Vehicle Coalition (“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.

The Trail Preservation Alliance (“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.

The Organizations are aware that often conflict from public usage of public lands can be a concern for those private landowners in the area. Experiences in other areas with this issue have taught the Organizations that developing a minimal impact trail system is key to fostering good relations with all users and avoiding conflict. Our Organizations believe that after a complete review of the Proposal, and related planning documents, you will clearly conclude that current  concerns are not based on an accurate understanding of the Proposal and have been avoided in the development of the Proposal.

The Proposal is truly a small project and does not significantly impact the large number and mileage of routes that were to be closed as part of the recent White River Travel Management plan.  The Proposal encompasses over 4,000 acres and only adds 15 miles of new single track trails and restricts access on an additional 15 miles of existing routes to uses no wider than 36 inches in width. The Organizations do not believe trail density will be an issue with the Proposal.

The Organizations believe that width restrictors will be a significant implementation tool in the  Proposal, as width restrictors are an effective tool in minimizing width expansion issues that could arise from over width vehicles attempting to use the trail network. These 36 inch wide routes would be closed for 8 months out of the year to further minimize any possible impacts in the Proposal area.  The entire intent of the Proposal is to address multiple use needs in a manner that does not impact local residents or other users of the Tenderfoot Mountain area.

1.  Economics

While the Proposal is a comparatively small project, the significance of the project cannot be overstated to the users of the trail network.  Currently these users are not able to obtain a full day single track trail experience in the Summit County area, and are forced to leave the area to obtain this experience.  The Proposal will allow monies that are currently spent in other states or counties as a result of the severely limited opportunities to be retained in the Summit County economy.  Given previous experiences with our Organizations and Federal Land managers, the Proposal will clearly be an economic benefit to the Summit County economy.

The economic impact to the Colorado Economy of OHV recreation is over $1 billion dollars a year and over $200 million of that occurs in the central Colorado counties.  In the central Colorado counties, OHV recreation provides for almost 3,000 year round jobs. The Organizations are not asserting this Proposal will significantly alter these totals but this Proposal will aid in retaining spending resulting from single track trail use in the Summit County area.  As outlined later in these comments, any opportunity for this type of recreation is seriously limited in Summit county and as a result these users will frequently leave the area or even the state seeking out this recreational opportunity.

The Organizations believe that retaining this spending in the Summit County area should be a significant priority, as Summit County Colorado was recently found in the #3 position on the Wall Street Journal’s list of 21st Century American Ghost Towns.1 The bulk of spending associated with the Proposal would occur over the summer months, when seasonal ski related jobs are not employing people.  This spending would help stabilize the cyclical spending that results from a ski based economy.

The economic development that results from OHV recreation is significant, and as outlined in these comments, single track recreation is an area where the opportunities in Summit County are somewhat lacking currently.  Forest Service research indicates that a multiple usage trail network is an effective tool for the development of local economies.  This research specifically concluded:

“Recreation and tourism economies are the mainstay for rural counties with high percentages of public land. Actions by public agencies to reduce or limit access to for recreation have a direct impact on local pocket books. Limiting access by closing roads, campgrounds, RV parking, and trails for all or one special interests group will impact surrounding communities. Visitors to public lands utilize nearby communities for food, lodging and support facilities.”2

The Forest service targeting of trail networks as an effective tool for local economic development is based on the long track record of success that surrounds these types of projects.  The Hatfield McCoy trail network in West Virginia added over 10 million dollars of spending a year to one of the poorest counties in the US.3 The Paiute Trail System in southern Utah, which has become a destination for Summit County riders seeking single track trail experiences contributes, contributes similar amounts to the communities the trail network travels through.

The Organizations believe the Proposal will be a benefit to the local economy. While the scale of this benefit is unclear, the Organizations believe that the clear benefit of the Proposal weighs in favor of moving forward with the  Proposal.

2a.  Forest Service research indicates OHV recreation is a family based recreational activity.

The Organizations believe that a brief discussion of what an OHV recreational user is will create additional support for the Proposal and minimize concerns about possible negative impacts to the area. Forest Service research indicates that families are the largest group of OHV users. This research found that almost 50% of users were over 30 years of age and highly educated.4 Women were a large portion of those participating in OHV recreational activities.5 This research indicates that OHV recreationalists are frequently a broad spectrum outdoor enthusiasts, meaning they may be using their OHV for recreation one weekend  but the next weekend they will be walking for pleasure (88.9%), using a developing camping facility (44.7%), using a Wilderness or primitive area (58.1%), fishing (44.6%) or hunting (28.4).6

The Organizations believe the highly diverse recreational interests of OHV users aid in compliance with usage restrictions.  OHV users are highly familiar with possible impacts to other usages of public lands as these OHV users frequently use the same area for many different recreational activities and could be a member of another user groups the following weekend. The Organizations believe this user group is a highly responsible and highly sensitive user group that is more than willing to comply with usage regulations and possible concerns of other user groups.

2b. Colorado Parks and Wildlife Research indicates OHV users are a highly law abiding user group on public lands. 

In addition to a high percentage of OHV users being families, the law enforcement pilot program developed by Colorado Parks and Wildlife to address alleged law enforcement concerns with OHV recreation is further evidence the Organizations rely on to gain comfort with the Proposal.  This Pilot was developed in partnership with the Forest Service and Bureau of Land Management and is providing some of the first concrete information regarding law enforcement concerns involving OHV recreation.

The OHV law enforcement pilot program was created to address assertions of a compelling need to stop resource damage from OHV misuse at locations identified as violation “hotspots” by those seeking to limit public access to public lands.  While the Tenderfoot Mountain area was not identified as a hotspot for targeted enforcement, the Organizations believe these findings remain highly relevant to this discussion.  The law enforcement pilot program deployed additional trained professional law enforcement officers, funded by funds from the OHV registration funds, at  these “hotspots” during heavy usage times to supplement existing law enforcement resources in these areas.  As part of the pilot, the additional officers we required to keep logs of their contacts for reporting purposes.

The findings of this pilot clearly identify that these “hotspots” for OHV violations were anything but “hotspots”.  Over last summer, officers involved in the pilot program contacted over 10,000 people  of the 160,000 registered OHVs in Colorado, creating an astoundingly large sampling.  This pilot program found that less than 5% of riders committed any violations.   The overwhelming percentage of these violations were people not registering their OHV.  Only 1.5% of contacts involved activities, other than failing to register OHVs, where the officer found the activity serious enough to warrant the issuance of a citation.

The Organizations believe the conclusions of this groundbreaking research are highly relevant here and will provide a high degree of comfort to those with concerns about law enforcement and the Proposal.

The Organizations gain a high degree of comfort from the fact that the Summit County Off-Road Riders (“SCORR”)  have partnered with the Forest Service to assist with development and implementation of the Proposal.  SCORR is a Summit County based organization that has effectively developed and managed trail programs in other portions of Summit County.  While not all users of the  area are members of the club, the Organizations believe SCORR provides a strong tie to the community and an additional avenue for resolution of any issues that might arise.

Previous  SCORR projects have been highly successful and non-controversial after completion.  The Organizations must note that many of the same concerns and  objections were raised regarding previous SCORR proposals have again been  raised about the Tenderfoot project.  None of these concerns have been found to be significant after the opening of adjacent project areas, giving the Organizations additional strength in their belief the SCORR club will obtain similar results with the Tenderfoot project.

The Organizations have found that a strong local club provides a great  connection with projects allows active management and rapid resolution of any issues that might occur, as the local club is a member of the community.  These clubs may want  to develop trail opportunities in other areas of the county in the future and the success or failure of any project would directly impact their ability to move forward with other projects.   The on-going relationship and ties that SCORR has with the Summit County area should not be overlooked.

3a.  Multiple usage forest management requirements.

Pursuant to the Multiple Use Sustained Yield Act and the Federal Land Policy and Management Act, and other federal laws, the Forest Service operates under multiple use mandates. These statutes require that no single use be  given a higher priority for planning and usage of public lands.  There have been significant closures of motorized routes across the White River National Forest, including the Tenderfoot Mountain area for a variety of reasons under the recently released White River Forests travel management decision.  These closures have resulted in a need to expand access for single track multiple use trails on the White River National Forest to satisfy multiple use principals under federal law. 

Many opposing the Proposal assert that previously submitted comments on the Travel Management Plan are relevant to the Proposal.  The Organizations must note this assertion lacks factual basis as the Tenderfoot Proposal was not addressed in the White River travel management decision.  The Tenderfoot proposal was a multiple year project that was occurring even as the TMP was released.  Given the different schedules of the projects, inclusion of the Tenderfoot Proposal in the Forest Travel Management plan would have resulted in a significant delay for the rest of the Travel Plan.

While recent closures of routes has been very visible, travel management is a fluid and ongoing process that is governed by multiple use mandates, and governs the development and implementation of trail projects as well as closures. The Organizations believe this Proposal is a good balance of Summit County concerns and Federal land management requirements for the Tenderfoot Mountain area, when the management of this area is reviewed for a longer period of time. This Proposal does not significantly impact the overall trend in this area.  The project map provided during the scoping process identifies the large number of trails closed in the Tenderfoot area. 


As a result of the closure of almost all multiple use single track trails on Tenderfoot Mountain, only a small distance of single track multiple use trail remains on the White River National Forest.  This recreational opportunity is found  in the Golden Horseshoe area of the Dillon Ranger District.  The limited numbers of single track trails in the Golden Horseshoe area is reflected by the dotted lines on the MVUM insert for the Golden Horseshoe Area. 


tenderfoot_2012_8a.jpg 8

Given the serious limitation on single track multiple use trails in the Dillon area, this would appear to be a possible violation of multiple use mandates the Forest Service must comply with in managing public lands. The Proposal adds 15 miles of new single track trails and restricts access on trails on the ground to 36 inches max on an additional 15 miles of existing routes over 4,000 acres of planning area. These trails would provide a multiple use single track opportunity that does not alter the significant reduction in the number of routes in the Tenderfoot Mountain area and the White River National Forest as a whole.

3b. Levels of Protection

Much of the correspondence from those opposing the Proposal assert the Proposal allegedly violates Summit County Planning documents. The Organizations must note that while the Summit county regulations certainly must be taken into account in developing the Proposal, these local regulations are an insufficient basis to alter the Federal Statutory requirements for management of public lands, which the Forest Service must comply with.  A review of these documents finds many of the standards proposed for management of the Tenderfoot area are wholly inconsistent with Forest Service guidelines and requirements for Travel Management. As a result the Forest Service had to develop a more consistent plan for the management of the Tenderfoot area, that could be effectively implemented.

For several issues, the Proposal provides higher levels of protection than required in the Summit County legislation.  The Summit County legislation requires several routes remain open year round  for full sized motorized and ATV  usage.  Based on Wildlife concerns in the Proposal area, Forest Service planners have determined that these routes being open year round would pose a significant threat to elk wintering in the area. As a result of these concerns, seasonal closures of ALL routes is required under the Proposal to mitigate possible impacts to Wildlife.  The Organizations have to believe these seasonal closures will be highly effective as routes in the area frequently receive significant snowfall and quickly become impassable to OHVs.

The Organizations must also note the Summit County regulations are often complex and conflicting with general federal road management standards.  These conflicts and complexity would result in travel management decisions that are difficult to explain, completely different than forest regulations in other areas,  difficult to enforce and would create a significant amount of frustrations and confusion among those that are attempting to use this area.   Avoiding this type of user conflicts and frustration will greatly improve public support for management of the area and create a management plan that is sustainable in the long run for this area.

The Organizations vigorously assert that the Proposal provides a far more enforceable plan for the management of the Tenderfoot Mountain area, when compared to other management recommendations for the area.

4.  Wildlife Concerns

As previously noted, a seasonal closure of all routes in the Tenderfoot Mountain area from October to June is already part of the Proposal to add an additional level of protection for wildlife possible in the area.  The Organizations believe that these seasonal closures will be highly effective given the high levels of snowfall in the area that rapidly make routes impassible to all OHV traffic.

Public concerns voiced by those opposing the Proposal raise concerns about wildlife calving areas being impacted by the Proposal.  The Organizations are unsure the basis for these concerns, as CPW mapping does not identify the Proposal area or any portion of the Tenderfoot Mountain area as an Elk Reproductive area.  The Elk Reproductive areas identified by CPW are outlined in red on the map below.

Elk Reproductive Areas

It appears that those opposed to the Proposal have confused Elk Reproductive Habitat with Elk Winter Range.  Elk Winter Range identified by CPW is identified in the areas outlined in purple in the map below. 

Elk Winter Rangetenderfoot_2012_10.jpg10

Given the Proposal already provides all routes in the area be closed from October to June, the Organizations are unsure what basis could be relied on to assert that wintering wildlife in the area would be impacted by the Proposal. 

5a. The Proposal does not imcrease sound levels at adjacent propserties.

Sound created by recreational usage of public lands has been a planning  consideration in the development of the White River Forests Travel Management Plan.  Trails in the Tenderfoot Mountain area, such as the Oro Grande Trail that were closed to motorized travel as they did impact adjacent properties.  Under the Proposal, NONE of these trails would be reopened.

Given the awareness of possible sound impacts from the Proposal on adjacent homeowners, professional sound testing engineers have already been brought in to analyze possible impacts on adjacent property from sound.    This report does note that the ONLY noise issue that was identified was HWY 6 and the Oro Grande Trail, neither one of which has been addressed in this proposal.   A copy of this report is enclosed with these comments.

The report specifically concludes that motorized recreational usage of the trails to be opened in the Proposal does not increase sound levels at these residence beyond ambient levels.   This report does note the primary source of sound for these residence was Highway 6.  Utilization of highway 6 is beyond the scope of this Proposal.

5b. The Proposal will not threaten wildlife with sound levels.

The possible impact of sound from the Proposal on wildlife has also been a concern voiced in opposition to the Proposal.  This type of an impact is an issue that has been extensively researched by the Forest Service.  While this research has centered on winter motorized recreation, these findings are completely relevant here as any impacts to wildlife would be more easily recognized during winter periods when stress is greater on the animals.  This research has uniformly concluded that sound level related to usage of OHV’s has little to no impact on wildlife.   As a result the Forest Service studies have specifically found:

 ”Based on these population-level results, we suggest that the debate regarding effects of human winter recreation on wildlife in Yellowstone is largely a social issue as opposed to a wildlife management issue. Effects of winter disturbances on ungulates from motorized and non-motorized uses more likely accrue at the  individual animal level (e.g., temporary displacements and acute increases in heart rate or energy expenditures) than at the population scale. A general tolerance of wildlife to human activities is suggested because of the association between locations of large wintering ungulate herds and winter recreation. Habituation to human activities likely reduces the chance for chronic stress or abandonment of critical wintering habitats that could have significant effects at the population level, especially when these activities are relatively predictable.”11

This research has also uniformly concluded that animal response to people on foot or with a dog is consistently higher than the animals response to motorized vehicles, even with the higher sound levels that maybe associated with the motorized vehicle.

“Deer consistently bedded near snowmobile trails and fed along them even when those trails were used for snowmobiling several times daily. In addition, fresh deer tracks were repeatedly observed on snowmobile trails shortly after machines had passed by, indicating that deer were not driven from the vicinity of these trails… The reaction of deer to a man walking differed markedly from their reaction to a man on a snowmobile… This decided tendency of deer to run with the approach of a human on foot, in contrast to their tendency to stay in sight when approached by a snowmobiler, suggests that the deer responded to the machine and not to the person riding it.”12

The Organizations believe there is significant research already conducted for the Proposal concluding that sound levels from the Proposal will not impact wildlife.  The findings are supported by the extensive body of Forest Service research  that has concluded that sound levels from motorized recreation do not have a negative impact on wildlife. Given this body of research, the Organizations do not have any basis to support a concern about sound impacting wildlife in the Proposal area.


The Organizations are aware there is public concern regarding the Proposal.  Given that public scoping of the Proposal has only occurred, we believe these concerns are the result of a lack of information regarding the Proposal.  The Organizations  believe that additional information regarding the Proposal will aid in understanding the specifics of the Proposal and address many of these concerns that may exist as a result of limited information.  The Organizations are vigorous supporters of the Proposal as this multiple use trail network will be a significant benefit to recreational users of these trails.

If you would like a copy of any of the reports relied on in these comments or have questions please feel free to contact  Scott Jones at 508 Ashford Drive, Longmont CO 80504.  His phone is (518)281-5810.


John Bonngiovanni
Chairman and President
Colorado OHV Coalition

Don.E. Riggle
Director of Operations
Trails Preservation Alliance

Scott Jones, Esq.
COHVCO CO-Chairman



1 Douglas A. McIntyre; American Ghost Towns of the 21st Century; 24/7 Wall Street; April 11, 2011;

2Humston et al; USFS Office of Rural Development; Jobs, Economic Development and Sustainable Communities
Strategizing Policy Needs and Program Delivery for Rural California; February 2010 at pgs 51-52

3Marshall University Center for Business and Economic Research; Final Report; The Economic Impact of the Hatfield~McCoy Trail System in West Virginia; October 31, 2006 at pg 3.

4Cordell et al; USFS Research Station; Off-Highway Vehicle Recreation in the United States and its Regions and States: A National Report from the National Survey on Recreation and the Environment (NSRE) February, 2008; pg 56.

5Id at pg 56.

6Id at pg 41-43.

7USFS- Dillon Ranger District- Map of Tenderfoot Trail area provided to public with scoping documents on Ocotber 11, 2011.

8USFS – Dillon Ranger District 2012 Motor Vehicle Use Map- Inset of Golden Horseshoe area

9Colorado Parks and Wildlife – 2012 Elk Reproductive areas map in Google Earth formatting provided by Hunting GPS maps

10Colorado Parks and Wildlife – 2012 Elk Winter Range areas map in Google Earth formatting provided by Hunting GPS maps

11PJ White & Troy Davis. Wildlife responses to motorized winter recreation in Yellowstone. USFS 2005 Annual Report at Pg 1.

12Richens, V. B., & Lavigne, G. R. (1978). Response of white-tailed deer to snowmobiles and snowmobile trails in Maine; Canadian Field-Naturalist, 92(4), 334-344.







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