May 3, 2014
|Uncompahgre Field Office – Burn Canyon Trail Project
Att: Burn Canyon Travel Management
Prior to addressing the specifics of these concerns, a brief summary of the Organizations is warranted. 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. For the purposes of these comments, COHVCO and TPA will be referred to as the Organizations.
1. Significant changes in the scope of proposal must be completely addressed and simply have not been.
The Organizations have significant concerns regarding the lack of meaningful analysis of many impacts that result from the changed scope of the project. Per scoping the scoping letter, the project seeks to develop a new single track multiple use trail network described as follows:
While the Organizations vigorously supported the scoping in the original proposal, the Organizations are not able to support the direction now reflected in the preferred Alternative. The preferred alternative would:
The Organizations must highlight the scope of change in direction of this project, which was scoped to provide 34 miles of multiple use single track and has now changed to providing no miles of multiple use single track in the preferred alternative. After a brief review of the comments provided in scoping and a complete review of the EA, the Organizations are wholly unable to identify any basis or concern that could be relied on for the significant changes in the proposal that are now identified.
Given the prioritization of a single user group that is not able to fund any portion of the project over multiple use recreation in the planning area will increase user conflicts. These concerns are compounded by the fact that the user group that is being excluded is the only one to pay to assist with management of their recreational usage. These concerns are further compounded as the development of the proposal impairs assertions that agency money is being properly directed towards partnering to maintain and manage existing opportunities in the field office.
It is the Organizations position that these impacts are unacceptable result for any user groups recreational activity and must be avoided in any plans that expand trail networks. If agency personnel are not able to fund maintenance of current opportunities, any assertion of sufficient funding being available in the future would be highly suspect.
The Organizations agree that these materials are critically important in mitigating impacts and educating users and developing a trail system that is successful in the long run. The Organizations simply are not able to explain how these materials will be developed if there is no money to develop these resources for the area. The Organizations have to believe that simply developing these resources without changing current usage would result in a significant benefit for all user and achieve the goals and objectives of the proposal and completely avoid any possible negative impacts that would result from more opportunities that fail to address these known management issues that are currently unresolved.
Additionally the UFO has recently provided a single track non-motorized trail network outside Ridgway and significant portions of the Domingez-Escalante NCA were designated for the benefit of non-motorized users. These are opportunities that must be balanced and weigh heavily in favor of Alternative 2 of the proposal in order to address the critical lack of motorized single track in Colorado.
6. Analysis of most resource specific issues is completely faulty.
Benefits of moving from an open to existing route designation simply are not relevant to this proposal, as the area has been under existing roads and trails management standards since the adoption of the UFO TMP in 2010. If there are impacts resulting from off trail usage, these are now enforcement issues and probably the result of the specifically identified lack of signage and maps for the planning area rather than benefits of the EA. If these same management standards, such as no signage or maps for users area continued, off trail usage will continue regardless of the type of usage that is allowed. The Organizations vigorously assert that rather than attempting to assert benefits from previous management decisions, the proper question should be how to fund implementation and education of users regarding the newly adopted TMP. These concerns are more specifically addressed in previous portions of the comments.
The Organizations are deeply troubled that the analysis of many resource issues provided in the EA exhibits a similar confusion of management standards in an effort to create a position that the proposal will be a benefit and there will be no impacts. The EA must be comparing the alternatives to current management of the area rather than to each other, which is commonly the case in the EA. The Organizations vigorously assert that much of the new trail network that is to be developed is in areas that simply have no trail network currently and are outside of possible impacts from existing opportunities. Any position that building a trail in an area that currently has none probably lacks factual or scientific basis and credibility. The proper question to be addressed is does the trail network negatively impact the area, which cannot be accurately addressed by merely comparing alternatives. Funding and ongoing maintenance of the trail is a critical component of this analysis, and must address issues like the proposed alternative provides for a 31% increase in routes that are on highly erodible soils. Regardless of who is using the routes, they will need maintenance.
“Non-motorized winter recreational activities caused 89% of monitored moose to be displaced, while snowmobiles caused 50% displacement, and trucks caused 21% displacement. Furthermore, 100% of observed moose demonstrated disturbance behaviors when disturbed by skiers and snowshoers, moving an average of 80 yards away. In contrast, 94% of moose moved 50 yards when disturbed by snowmobiles.”12
Weeds and invasive species will be brought into areas and habitats that have been isolated previously. This will cause impacts that must be addressed. Monitoring and management of any outbreaks of invasive species will be problematic due the failure to provide funding for long term management. Again these are issues that the OHV Good Management crew currently in place on the UFO could easily address if this was a multiple use trail network. That maintenance and funding is illegal under the preferred alternative.
Another failure of analysis of impacts that result from management changes in the preferred alternatives involves the management of critical winter range for wildlife. These areas are consistently closed to usage. Rather than apply these management standards the EA proposes to allow foot and horse traffic as follows:
“Seasonal Closures – All designated routes in the Norwood-Burn Canyon Area would be closed to motorized and mechanized travel from December 1 to April 30 to prevent disturbance to wintering big game. …. Foot and horse travel would be allowed.”16
There is simply no scientific basis for allowing foot and horse usage of the area during winter range times. These usages are repeatedly identified as usages that acheive the highest and longest levels of response from wildlife. Allowing these usages while excluding others will generate a minimal benefit to the species that are relying on the area as winter range. Again the Organizations assert meaningful analysis of this standard must be undertaken to develop a plan for the usage of the area.
The Organizations vigorously support the development of additional multiple use single track trails in the planning area as reflected in Alternative 2 of the EA. These trails would help address the void of motorized single track riding opportunities that currently exists in the State of Colorado and more specifically in the areas surrounding the proposal. The Organizations believe that this proposal would provide a significant resources for all users of trail network as multiple use trail opportunities are very limited in the proposal area.
The Organizations are vigorously opposed to the preferred alternative that is in the EA as this will directly limit the funding that is available and directly impact the ability to actually implement any of the rather extensive mitigation tools, such as parking, maps, kiosks and other resources that are identified as necessary under both current management and the preferred alternative.
If you have questions please feel free to contact Scott Jones, Esq at 508 Ashford Drive, Longmont CO 80504. His phone is (518)281-5810 and email is firstname.lastname@example.org.
Scott Jones, Esq.
1 BLM, Uncompaghre Field Office Burn Canyon scoping letter dated April 3, 2012.
2 See, BLM Uncompaghre FO, draft EA on Norwood-Burn Canyon Comprehensive Travel Management Plan; April 2014 at pg 13. This document is hereinafter referred to as the EA.
4 See, Government Accountability Office report to Congressional Requestors GAO-13-618; Forest Service Trails- Long and Short term improvements could reduce maintenance backlog and enhance system sustainability; June 2013 at pg.
5 See, EA at pg 29.
6 EA at pg 31.
7 EA at pg 2.
8 EA at pg 9.
10 San Juan Forest – Resource Management Plan
11 See, USDA Forest Service, Rocky Mountain Research Station; The Southern Nevada Agency Partnership Science and Research Synthesis; Science to Support Land Management in Southern Nevada; Executive Summary; August 2013 at pg 38.
12 See, Rudd, L. T., and L. L. Irwin. 1985. Wintering moose vs. oil/gas activity in western Wyoming. Alces 21:279-298.
13 See, Sime, C. A. 1999. Domestic Dogs in Wildlife Habitats. Pages 8.1-8.17 in G. Joslin and H. Youmans, coordinators. Effects of recreation on Rocky Mountain wildlife: A Review for Montana. Committee on Effects of Recreation on Wildlife, Montana Chapter of The Wildlife Society. 307pp..
14 Rumble, Mark A; Benkobi, Lahkdar; Gamo, Scott R; 2005. Elk Responses to Humans in a Densely Roaded Area; Intermountain Journal of Sciences. 11(1-2); 10-24 @ pg 17-18.
15 EA at pg 34.
16 EA at pg 14.