Rio Grande National Forest
Attn: Dan Dallas, Forest Supervisor
1803 W. Highway 160
Monte Vista Co 81144
RE: Rio Grande National Forest Plan Revision Initial Comments
Dear Supervisor Dallas:
Please accept these comments on the Rio Grande National Forest Plan Revision Project on behalf of the Trails Preservation Alliance (“TPA”), Colorado Snowmobile Association (“CSA”) and the Colorado Off-Highway Vehicle Coalition (“COHVCO”). Prior to addressing the specific concerns that have been raised to date in the development of the new Rio Grande National Forest’s Resource Management Plan (RMP), the Organizations would like to thank the Rio Grande National Forest staff for their efforts to date in the planning process. The Organizations are aware that the Rio Grande National Forest is one of the first forests to move forward under the new United States Forest Service (USFS) planning rule and at this time and USFS guidance regarding the application of the new planning rule to local forests or planning units remains under development. This lack of planning rule clarity compounds the inherent conflict that exists between current forest planning timeline and the rate at which species management and research are progressing. This lack of clarity has made any efforts on the Rio Grande difficult at best as there are many new concepts and principals developed under the planning rule that will heavily impact plan development. The Organizations believe that the efforts to date have done a commendable job in satisfying these new requirements and standards and the Organizations remain willing to assist in resolution of any issues that might arise on this front in any way that we can.
The TPA is a volunteer organization created to be a viable partner to public lands managers, working with the USFS and the Bureau of Land Management (BLM) to preserve the sport of trail riding and multi-use recreation. The TPA acts as an advocate for the sport and takes the necessary action to insure that the USFS and BLM allocate a fair and equitable percentage of public lands access to diverse multi-use recreational opportunities. COHVCO is a grassroots advocacy organization representing approximately 150,000 registered off-highway vehicle (“OHV”) users in Colorado seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of multi-use and 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. Colorado Snowmobile Association (“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 become the voice of organized snowmobiling seeking to advance, promote and preserve the sport of snowmobiling by working with Federal and state land management agencies and local, state and federal legislators. TPA, CSA and COHVCO are referred to collectively in this correspondence as “The Organizations.”
The Organizations offer the following comments, values and concerns regarding this plan update moving forward.
- The Organizations believe that continued multi-use access and motorized recreation within the National Forest is vitally important to the preservation and conservation of our public lands and the well-being of our citizens. The Organizations acknowledge that as America becomes more urbanized and populations rise, our younger citizens are becoming less connected to and are less likely to identify with the outdoors in their daily lives. Our Organizations have worked diligently and continuously to help Coloradans and visitors to our State to be able to access and enjoy our public lands in a safe and responsible manner. We recognize that there is a bona fide correlation between an individual’s personal health and their participation in outdoor activities. We continually strive to get youth and families excited about visiting, seeing and experiencing all that our public lands have to offer. We have a history of partnering with the USFS to protect our forest resources while reducing and eliminating barriers that are continuing to make it difficult for Americans to get outside and travel on a multi-use trail or share a road as part of their outdoor recreational experience. The Organizations feel that this renewal of the Forest Plan must work diligently to ensure that a balanced spectrum of opportunities are provided in the Rio Grande National Forest to properly serve the diverse cross section of our population and meet their recreational needs. We contend that both “Conservation philosophies” and “Recreation activities” are compatible and can work in harmony for the betterment of the Forest. We request that this revision of the Forest Plan fairly and adequately provide an Environmentally, Economically and Socially sustainable end state.
- The USFS has been a recognized supporter of the California Children’s Outdoor Bill of Rights. Nationwide there are concerns about the youth of our country’s lack of exercise, detachment from outdoor activities and limited access to public parks and land. The Rio Grande National Forest along with its associated network of roads and trails provides the necessary access and recreational opportunity for the surrounding region’s youth to explore nature, play in safe places, follow a trail, go fishing, camp under the stars, connect with the past and many of the other activities inspired by Richard Louv’s book “Last Child Left in the Woods.” Loss or closure of the multi-use and motorized system of trails with the Rio Grande National Forest would certainly be a tragedy and lost opportunity for the region’s youth to be able to connect to and be exposed to nature.
- It is well recognized that the average age of our country’s population is increasing and the number of persons aged 50 and older is steadily increasing. As the average age grows, so is the number of people still choosing to recreate outdoors but more and more will be less able to use non-motorized methods of travel or participate in high-energy, high-skill sports. As this demographic group grows, so will their needs for access to the Forest by motorized or other assisted methods. If we collectively fail to recognize and plan for this changing demographic, we will be deliberately excluding a significant and growing segment of the population from the opportunities to experience and enjoy the Rio Grande National Forest. Many of us hope to retain our individual mobility into the “Golden Years,” but many will not, and they will need to rely upon some sort of motorized assistance to access the places we all enjoy and cherish. The Rio Grande National Forest’s Assessment #9, Recreation even states that “For seniors, inaccessible infrastructure and lack of opportunities that enable senior adults to continue in outdoor recreation constrains recreation participation”.
- The economic impacts of multi-use and motorized recreation within the Rio Grande National Forest must not be overlooked or underestimated. Even though the Rio Grande National Forest receives somewhat lower visitation than other national forests in Colorado, there are still significant economic benefits being realized by all of the communities and Counties encompassed by and in proximity to the Forest. As an example, motorized recreational enthusiasts were responsible for $990 million in direct expenditures relating to motorized recreation in Colorado during the 2012-2013 season alone.
- Our Organizations contend that the previous Forest Plan and subsequent Travel Management Plan (TMP) substantially reduced recreational opportunities, reduced access, eliminated multi-use/motorized recreational opportunities and was too restrictive. This new plan must seek a more balanced and fair allocation of resources to recreation and especially multi-use/motorized recreational opportunities. Similarly, the restrictions of the former plan have contributed to the current poor health of the forest and unnecessarily hampered the efforts of the agency to be able to properly and effectively mitigate fuels and manage the density of the forest biomass.
- With few if any exceptions, the roads and trails within the Rio Grande National Forest have been in existence and providing public benefits for decades. History has shown that these routes provides a level of tangible recreational, economic and/or forest access value. Continuing to have an adequate network of forest roads and trails will be truly beneficial and necessary in providing sufficient access for future timber management, continuing forest visits, recreation, emergency access/egress and wildland firefighting efforts. This minimal threat is accurately reflected in the aquatic assessments on the Rio Grande National Forest which clearly conclude that these routes pose an exceptionally low level threat to water quality.
- We feel it is important to spotlight the following general principles regarding multi-use recreation and are important considerations when evaluating any modifications to the Forest Plan:
- Generally forest visitors participating in multi-use activities will use routes that exist and adequately satisfy their needs and desires.
- Non-system trails and roads should be reviewed during this review process to determine if any of these non-system routes will fulfill a valid multi-use need and can be altered to meet recreation and resource management considerations.
- Route networks and multi-use trail systems should meet local needs, provide the desired recreational opportunities and offer a quality experience. We are not asking that this be done at the expense of other important concerns, but a system of routes that does not meet user needs will not be used properly and will not be supported by the users. Occurrences of off-route use, other management issues and enforcement problems will likely increase when the routes and trails do not provide an appropriate and enjoyable opportunity.
- Recreational enthusiasts look for variety in their various pursuits. For multi-use, to include motorized/OHV users, this means looped routes. An in-and-out route may be satisfactory if the destination is so desirable that it overshadows the fact that forest visitors must use the same route in both directions (e.g., access to dispersed camping sites, overlooks, historic sites, the Wheeler Geologic Area, etc.). However, even in these cases, loop systems will always provide better experiences.
- “Desired Recreational Experiences” is subjective and will vary from individual to individual. Calls to decommission roads or to return areas to more natural states and enhance recreational experiences is purely subjective and a personal opinion. No one will be able to enjoy the forest and all of the resources the forest has to offer if adequate access is not provided. Multi-use and motorized recreation is indeed a bona fide form of recreation and not one to be reduced, banned or eliminated on public lands.
- An adequate network of forest roads and trails is necessary to provide access for proper forest management and especially in times of emergency. The USFS is a world renowned expert on wildland firefighting and knows firsthand the importance of good access, redundant routes and routes in key places and the impact of those routes on the safety of the firefighters, the public and successful wildland firefighting. The demands for reduced road inventory, for reduced route density and increased decommissioning of roads is not collectively and universally in the best interest of the forest nor the public. The demand for more and more closure of multi-use and motorized access is often based upon self-serving desires and an unwillingness to share our natural resources with others, intolerance of mixed forest uses and an unwillingness to coexist in our individual pursuits of recreation. Likewise the premise that decommissioning roads will reduce human caused fires is absolutely unfounded and unsubstantiated and should not be utilized as a criteria for any decisions regarding the elimination or closure of any multi-use or motorized route.
- Not all dead roads are necessarily of low value and in need of closure. Many dead end spurs and “low value” routes provide access to picnic areas, dispersed camping sites, overlooks, etc. Although the values of these roads is less than that of main roads, connectors and loops, (i.e. “higher value” routes) their individual, overall benefit and value must be individually considered. We acknowledge that these roads will likely not generate much positive public interest and comment, however these routes can still have substantial importance to the public. We would encourage the Rio Grande National Forest to listen to your own recreational and field staff when assessing any low value or dead end spur roads.
- Duplicative roads and trails may on the surface appear redundant and not needed. This is often the cry from those unfamiliar with multi-use and motorized recreation or simply seeking to eliminate or reduce public use of these roads. However, we would challenge that some duplicative routes may in fact offer unique benefits for distributing the use rather than concentrating use to a single route or may offer looping and other recreational opportunities. It is our position that every route has recreational value as each route provides a unique experience to those using the route for recreational activity.
- The Organizations in general oppose the conversion of routes to “Administrative Roads”. This designation in and of itself suggest an elitism attitude that Agency staff or other special designated personnel are the only ones capable of properly using a route. If a route is important for USFS and agency staff to access a location, it is very probable that that same route is equally important or desirable for the public to access the same or similar location. If the route is properly constructed and receives the requisite level of maintenance, there should be few reasons the public should not be allowed similar access and privileges. The designation that only “special” personnel are allowed to use a route does little to foster any sense of community and partnership users and agency staff should have for each other. Discrimination of the public users and the fostering of elitism should not be perpetuated, encouraged or allowed to proliferate. The designation of routes for Administrative Use should only be utilized in the rarest of instances where the exclusion of the public can be justified for very site specific, meaningful and justifiable conditions (e.g. mandated security of critical infrastructure, etc.).
- In the past there have been unfounded concerns for American elk and mule deer as a reason to close and limit multi-use and motorized recreation on public lands. The premise that “large animals, especially deer and elk, are sensitive to traffic and activity along roads” is not supported by published scientific research. Extensive studies completed as recently as 2005 by the National Park Service (NPS) in Yellowstone Park stated that “Effects of winter disturbances on ungulates from motorized and non-motorized uses more likely accrue at the individual animal level than at the population scale.” Even the biologist performing the research stated that the debate regarding effects on human recreation on wildlife is largely a “social issue” as opposed to a wildlife management issue. This NPS research would certainly seem relevant to wildlife in the Rio Grande National Forest and does not support a premise for closures and reductions in multi-use recreational opportunities. Additional research published by Mark Rumble, Lahkdar Benkobi and Scott Gamo in 2005 has also found that hunting invokes a more significant response in elk than other factors in the same habitat area (e.g. roads or trails). Likewise research by Connor, White and Freddy in 2001 has even demonstrated that elk population increases on private land in response to hunting activities. This research again brings into question why multi-use trail recreation (specifically motorized recreation) might be cited and used as the justification for any closures or modification to public access.
- The Organizations are aware of demands regarding a perceived inadequacy of the USFS to provide enforcement of regulations pertaining to multi-use and motorized recreation in particular. We would challenge that based upon several studies, pilot projects, etc. by the Colorado Parks and Wildlife Division, the USFS and the BLM to analyze if indeed an enforcement issue exists, and without exception, those projects have shown there are no problems due to a lack of enforcement. The State of Colorado’s OHV funds have been used to subsidize law enforcement programs and the detailing of law enforcement officers to OHV areas only to come back with consistent results that this cry for the need for enforcement is unfounded, unsubstantiated and just plain inaccurate. In 2011, the Colorado Parks and Wildlife Division initiated an OHV Law Enforcement Pilot program to address the accusations, questions and concerns raised by critics of OHV recreation on public lands in Colorado. The data and observations gathered from this Pilot program in 2011, 2012, and 2103 repeatedly demonstrated excellent compliance with OHV rules and regulations throughout Colorado by OHV users. It was estimated that over 10,000 individual OHV users were stopped and inspected during the Pilot Program and 94% of those users were found to be fully compliant with Colorado OHV laws and regulations.
- Sound. Motorized and non-motorized uses are equally legitimate uses of public lands and especially on USFS roads and multi-use/motorized trails. Sound from motorized use is to be expected in areas open to motorized use. The Organizations would offer that the State of Colorado already has strict standards for any and all sound emanating from OHV’s. This very detailed standard has proven to be effective since 2006 and governs vehicles produced as far back as 1971. OHV users themselves have funded efforts to educate, test and “police” themselves for sound level compliance. We feel that complaints of noise and demands for sound reduction are once again unfounded and will often be used as a selfish excuse to try and reduce or eliminate motorized access and use of public lands.
The Organizations would be willing to partner with the USFS to address any site specific sound issues that may be asserted to be present on the Rio Grande National Forest. The Organizations have undertaken sound testing with independent third parties at numerous other areas asserted to have sound issues and have almost uniformly found that site specific sound issues are unrelated to OHV activity and are more commonly related to trains, air travel and high speed arterial roads in the area.
The Organizations further submit that those seeking a quiet recreational experience have a wide range of opportunities available on the Rio Grande National Forest given the high levels of Wilderness already in place. The Organizations submit that these opportunities must be utilized before additional closures are undertaken, as the inability to access a “quiet area” is a different issue than the lack of quiet areas on the Rio Grande National Forest.
- We acknowledge that the Rio Grande National Forest may have struggled somewhat with the proliferation of non-system trails by ALL users throughout the Forest. However, we feel much of this stems from an increasing need and demand for multi-use recreational opportunities on public lands in general. As the State of Colorado’s population has grown, so have the sales of Off Highway Vehicles (OHV’s), bicycles, hiking equipment, camping units and other forms of outdoor recreation increasing the demand for recreation sites within the Rio Grande National Forest. We would offer that much of the increase in illegal user-created routes, braided routes & trails and unauthorized group campsites are a result and reflection of inadequately meeting the needs and demands of the public and the recreational users who choose these areas. An adequate and varied inventory of routes and trails that fulfills the user’s spectrum of needs for variety, difficulty, destinations, challenge, terrain and scenic opportunity will lead to improved compliance and less off route travel. Closure and reduction of recreational opportunities and the resulting concentration of the ever increasing number of users, has shown again and again that the desired results are not obtained.
- As future Proactive and Adaptive Management Plans are considered to try and achieve a particular desired condition or end state, these Plans should include thresholds and triggering mechanisms that allow for the expansion and adding of recreational opportunities, not just curtailment, restrictions and eliminations of opportunities. If desired conditions are not being achieved or monitoring protocols are not rendering the preferred results, consideration should be given that perhaps the needs and demands of the users are not being adequately provided for. One example might be off trail use or use of closed routes. Rather than assuming this is merely caused by a minority of users ignoring the rules, this may indeed be an indicator that the existing network does not adequately meet the user group’s spectrum of needs for a route to a particular destination, level or degree of challenge, route length, etc. The Organizations believe the motorized game retrieval standards currently allowed on the Rio Grande National Forest provide a concrete example of the need for flexibility in management to achieve management objectives.
- The motorized community has proudly partnered with land managers to help offset budget limitations, which has resulted in grant funding exceeding $100k per year now being provided to the Rio Grande National Forest, even in light of the most recent round of budget cuts to the USFS. Lack of fiscal capacity by the USFS should not be a criteria for, or lead to closures and reductions in public recreational opportunities, closure of routes or elimination of public access to the Rio Grande National Forest. We fully realize the stark realities of ever diminishing budgets, but it would be a travesty that the public citizenry should be locked out of any public lands and denied access because of a lack of funding. Maintenance and staffing may suffer, but the public must not be shut out. Public access must be preserved and the ongoing grant funding that has been provided on a project and Good Management Crew basis for the Rio Grande National Forest the Organizations hope has played an integral part in efforts to maintain access to public lands for all user groups. This grant program has become more important every year as federal budgets continue to decline at a somewhat alarming rate and creates a situation where leaving a trail open to motorized usage significantly expands funding available for the route to be maintained with.
- The Organizations encourage the individual Ranger Districts within the Rio Grande National Forest to carry on their efforts and continue to make submissions for grants through the Colorado Parks and Wildlife OHV Grant program to support OHV trail related projects on the Forest. OHV project grants can address the full spectrum of OHV recreation support needs. Examples of eligible OHV grant funded activities includes:
- Construction, reconstruction or maintenance of OHV routes or multi-use trails that allow for motorized use
- Crossing structures, bridges, railings, ramps, and fencing
- Bank stabilization and retaining structures
- OHV trail corridor re-vegetation and erosion control
- Trailhead development and/or support facilities related to OHV or multi-use trails including parking areas, restrooms, and related facilities
- Equipment needed to build or maintain OHV trails
- Signs – directional, regulatory, and interpretive signage for OHV routes
- Printing – maps/guides, safety and educational materials programs, publications and videos on safety and OHV recreation
- OHV trail or system planning, engineering, or design
- Land acquisition or easement projects. NEPA review and environmental compliance work required under NEPA or other statutes
- Restoration of closed trails or damaged areas where a nexus exists between OHV misuse and needed repairs
- Salary, compensation and benefits for crew members or project employees
- OHV Education and safety programs
- Wildlife habitat restoration
- In general, the Organizations do not support the segregation of users and the exclusive use of one user group at the exclusion of others. We feel it is both socially beneficial and desirable for all users to learn to coexist and to show tolerance and respect for other users and groups of users. Just as we all learn to live together in our daily lives away from the forest, we should also extend that willingness to coexist when in the forest. Segregated user groups only fosters arrogance, elitism, intolerance and eventually leads to unjustified stereotyping and discrimination which results in greater user conflict. The Organizations are intimately familiar with the situation where user conflict is used as a strawman for the desire to create exclusive use areas on the Rio Grande. The Organizations are not aware of any major user conflict areas or issues currently existing on the Rio Grande and creating user conflict in an attempt to create exclusive use areas on the forest would be unfortunate.
- We feel it will be necessary for this revision of the Forest Plan to provide opportunities and future opportunities that will not restrict the changes and development of new technologies such as hybrid bikes, electric bikes/motorcycles, personal mobility devices just to name a few.
- Together our Organizations do not support or endorse the expansion of Wilderness areas within the Rio Grande National Forest or management that seeks to provide expanded Wilderness like experiences. In Colorado alone, there are approximately 3.7 million acres of Congressionally designated Wilderness in our National Forests or approximately 15% of all USFS lands. Another 210,984 acres of Wilderness are located within Colorado’s Bureau of Land Management (BLM) boundaries and 306,081 acres are located in Colorado’s National Parks. In total, there are 2 million acres of designated Wilderness already in Colorado. This is an area larger than the states of Rhode Island and Delaware combined. Many of the remaining lands within the State that might be considered for “Wilderness” designation have been specifically “released” by Congress from future consideration as Wilderness, or have been studied by the agency and deemed unsuitable for Wilderness designation.
Finally, visitor use statistics do not suggest that we need additional Wilderness areas. Nationally, only about 5 percent of user visits to the Forest System are in Wilderness areas. The visitation figure for the Rocky Mountain region is even lower, about 4 %, despite over 15% of USFS lands in Colorado being Congressionally designated Wilderness. Congress has amply addressed both the need and demand for Wilderness in Colorado. Wilderness advocates frequently claim new Congressional designations of Wilderness areas will drive economic growth, which claims are supported by generalized assertions by the Outdoor Industry Association (OIA) research findings that outdoor recreation is $646 Billion dollar a year industry. The relationship of this research and Congressionally designated Wilderness is unclear at best, as the OIA research specifically includes valuations of activities such as motorized recreation, Bicycling, RV camping, and Snowmobiling. In reality, most Americans, for various reasons, are unable or unwilling to enlist in the physical and rigorous effort required of the adventures in Wilderness areas. The Rio Grande National Forest and other forests face broad-scale ecological threats that require well designed management responses that do not stop at a Wilderness boundary. In Colorado, we only need to look outside to see the devastation tied to catastrophic wildfires and the spruce beetle outbreaks. An ecological imbalance has developed over time because widespread treatments in the Engleman and Blue Spruce stands that would have created age class diversity, enhanced the vigor of remaining trees, and improved stand resiliency to drought or insect attack—such as timber harvest and thinning — lacked public acceptance in the past.
- Four large Wilderness areas on Rio Grande already provide exceptional recreational opportunity for those seeking to user experience (i.e., La Garita, Sangre de Cristo, Weminuche, and South San Juan). Even with these exceptional resources, these areas only received 4% of visitor days to the Rio Grande. A lot of local frustration with complex fires and impacts that lack of management had with these fires scope and intensity. Requirements for Wilderness management have also greatly increased basic operation costs for land managers as even basic maintenance may only be done without mechanical assistance.
- Colorado Roadless Rule. The Organizations are also concerned that the Roadless Rule is often used as a lever for the expansion of Wilderness areas. This is a misapplication of the Roadless Rule, as Colorado as developed its own rule that specifically identifies motorized trails as a characteristic of a Colorado Roadless area. While Roadless areas have limitations on road construction and heavy maintenance, trails are entirely outside the scope of the Colorado Roadless Rule  as trail networks may be constructed and expanded in a Colorado Roadless Area.
In the development of the Colorado Roadless Rule, an extensive inventory of characteristics of each area of a forest proposed to be managed either as a CRA or Upper Tier areas was undertaken. A significant portion of the Rio Grande National Forest was proposed to be managed as upper tier Roadless Areas under Alternative 4 in the NEPA analysis. After the inventory was completed most of these areas were identified to remain Colorado Roadless areas due to existing levels of human activity in the areas. Given the proximity in time of this inventory, the Organizations believe this inventory is highly relevant to discussions seeking the expansion of any wilderness like management as these areas were recently inventoried for these characteristics and found not to be eligible. The Organizations are not aware of any management in these areas where Wilderness characteristics were possibly expanded.
- National Monument Designations. The Organizations would not support the designation of any new or existing historic sites, geologic sites or other areas being designated as National Monuments (with their inherent and corresponding restrictions and limits on public access). We offer that the Rio Grande National Forest has done an adequate job throughout its history in recognizing and preserving the many special and unique sites, locations and landscapes contained within the current Forest boundaries. Any designations as National Monuments are unnecessary and would be detrimental to ensuring unfettered public access. The Organizations support the status quo access to such locations as the town site of Bonanza, the Wheeler Geologic Area, Cumbres and Toltec National Historic Landmark, Mount Blanca, the Natural Arch, the Fremont Special Interest Area, etc.
- We would ask that any future access easements allow “full public access” and that no “conditional easements” or easements restricting travel to a specified mode or modes of travel be exchanged or conveyed. The Organizations are also aware of extensive efforts in other national forests to create buffers around any non-motorized route or route that might have been provided a specific designation by Congress. Each of these specific designations are managed under the National Trails System Act, which clearly addresses the relationship of any designated routes and adjacent management standards as follows:
“Development and management of each segment of the National Trails System shall be designed to harmonize with and complement any established multiple use plans for that specific area in order to insure continued maximum benefits from the land.”
Given this clarity of management, the Organizations would find it difficult to establish a fact pattern where the existence of a trail in an area could be used to close multiple use recreation in areas adjacent to the trail.
- Cultural sites – The Organizations were pleased to note that The Need for Change document states the desire to expand several cultural areas while maintaining motorized access. Maintaining multiple use access is critical to the public support for these areas in the future, as the public should understand why an area is important and without this type of hands on understanding resentment will grow for closure of these areas. The Organizations also vigorously assert that cultural sites have been specifically identified as a multiple use management concern and when multiple uses of cultural areas are balanced, closures to the areas are difficult to justify.
- Best available science must be relied on in the development of the RMP for all species. Often identifying best available science can be difficult as this is an issue that is now rapidly evolving for many species, such as the Gunnison Sage Grouse, Mexican Wolf, Wolverine and Canadian Lynx. The rapid evolution of best available science in comparison to RMPs has resulted in conflict between these two issues, and as recently exemplified by the Pike & San Isabel National Forest Plan Challenge can result in lawsuits being brought against land managers when forest plans conflict with best available science. Overreliance on outdated management principals and standards should be avoided in the development of the Rio Grande National Forest RMP as this will be an area which will be ripe for legal challenge in the future.The Organizations submit that the new adaptive management and monitoring standards further support the requirement that best available science be relied on both in the development of forest plans and over the life of the forest plan. The Organizations would also note that the on-going requirement to manage to best available science and avoid application of outdated management standards in the development of new forest or resource plans was specifically addressed in the new Lynx Conservation Assessment and Strategy (“LCAS”). While the LCAS is highlighted here similar provisions are found in almost all species specific management documents that have been created. The LCAS specifically provides as follows:
“This edition of the LCAS provides a full revision, incorporating all prior amendments and clarifications, substantial new scientific information that has emerged since 2000…… Guidance provided in the revised LCAS is no longer written in the framework of objectives, standards, and guide-lines as used in land management planning, but rather as conservation measures. This change was made to more clearly distinguish between the management direction that has been established through the public planning and decision-making process, versus conservation measures that are meant to synthesize and interpret evolving scientific information.” 
“Forest plans are prepared and implemented in accordance with the National Forest Management Act of 1976…..The updated information and understandings in the revised LCAS may be useful for project planning and implementation, as well as helping to inform future amendments or revisions of forest plans.”
Many wildlife or quiet use advocates are uncomfortable in reducing the strictness of management standards when best available science moves away from one low risk threat to a species to address newly discovered or understood threats. Given the clarity of these various positions and the legal exposure that could result from failing to implement these requirements the Organizations vigorously assert that best available science must be applied in the Rio Grande National Forest RMP moving forward.
- Motorized game retrieval. The Organizations submit that motorized game retrieval is an important component of the hunting experience on the Rio Grande National Forest. While the Organizations are aware this is a site specific travel management decision, the continuation of these regulations should be provided for as the RMP moves forward.
- Wildlife habitat connectivity- The Organizations are aware that nationally the concept of management of Wildlife Habitat area connectivity is a new concept but CPW has been at the forefront of this issue and has been critical in application of these types of principals on public lands throughout Colorado. As a result the Organizations submit that wildlife connectivity is an issue that has basically been resolved on the Rio Grande National Forest through the on-going site specific planning on the Forest and as a result do not see the need for significant changes in current management to address these issues.
- The number of categories in the new Rio Grande RMP must be reduced. The Organizations are aware there has been significant concern voiced over the proposed reduction in the number of management standards that are currently in the Rio Grande National Forest RMP. The Organizations vigorously support a significant reduction in the number of categories simply to comply with the landscape nature of an RMP. Even with the size of the Rio Grande National Forest the number of categories currently in place reflects several local plans being combined rather than a true landscape level plan that is developed to facilitate local planning moving forward.
The Organizations would welcome a discussion of these opportunities and any other challenges that might be facing the Rio Grande National Forest moving forward at your convenience.
Director of Operations
Trail Preservation Alliance
Scott Jones, Esq.
TPA Authorized Representative
Pat Steenburg & Clive Heller
Boot Hill Enduro Club
5511 Ridgetop Court
Alamosa, Colorado 81101
 See, COHVCO- Economic Contribution of Off-Highway Vehicle use in Colorado, prepared by the Lewis Burger Group – August 2013. A copy of this report has been enclosed for your convenience.
 See, National Off-Highway Vehicle Conservation Council- Management Guidelines for OHV Recreation, 2006.
 See, Colorado Parks and Wildlife – The 2014 Off-Highway Vehicle Law Enforcement & Field Presence Program, Colorado Parks and Wildlife Division, March 2014
 See, USFS National Visitor Use Monitoring Results, USDA Forest Service, National Summary Report, Updated 20 May 2013.
 See, USFS National Visitor Use Monitoring report for the Rio Grande National Forest- Round 3
 See, Colorado Roadless Rule § 294.41 Definitions; see also 294.46 Other activities (e)
 See, Proposed Colorado Roadless Rule; 77 Federal Register No. 128 (Tuesday, July 3, 2012) Rules and Regulations at pg 39580.
 See, 16 USC 1246(a)(2) emphasis added
See, Rio Grande National Forest “Need for Change document” pg. 6 – item D7. A complete version of this document is available here: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd493976.pdf
 See, Interagency Lynx Biology Team. 2013. Canada lynx conservation assessment and strategy. 3rd edition. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication R1-13-19, Missoula, MT. 128 pp. at pg. 2. (Hereinafter referred to as “LCAS”).
 See, LCAS at pg. 4