Archive | February, 2021

Wolf reintroduction in Colorado SB 21-105

Senator Don Corum
200 East Colfax, Rm 346
Denver CO 80203

Representative Perry Will
200 East Colfax, Rm 307
Denver CO 80203

Re: Wolf reintroduction in Colorado SB 21-105

Dear Senator Corum and Representative Will:

Please accept this correspondence as the vigorous support for SB 21-105 “Concerning the implementation of Proposition 114 concerning the restoration of Gray Wolves in Colorado” on behalf of the Organizations identified above. The Organizations must express our concerns around the social and economic impacts that might result from Proposition 114 without meaningful analysis of issues such as funding for the entire process and meaningfully providing management clarity for specific uses. Unintended consequences from the reintroduction must be avoided and we believe that SB21-105 would be a significant step towards reducing these consequences.

The Organizations believe it is significant for us to note clearly why we are deeply concerned on the wolf reintroduction issue. We DO NOT believe there is a general safety concern for our members pursing their chosen recreational interests in wolf habitat, as any assertion of wolves chasing OHV riders and killing them is patently silly. Our primary concern is how is this effort going to be funded, as we are opposed to any OHV/OSV program money funding this effort. Our second concern is less direct but also more compelling and is based on the decades of experiences around ESA listed and more general species management. Our second concern involves possible impacts to recreational access that could result from the wolf reintroduction from more indirect issues, such as declining populations of ungulates and other species in areas where recreational activity occurs. Given that wolves are a primary predator of most large ungulates, this type of impact is a primary concern in the wolf reintroduction. Our apprehensions directly concern management decisions taken in response to ungulate populations decline in areas where wolves are present since population declines are already a basis to close trails. CPW expert testimony to the Commission has already established these population declines will happen as a result of the wolf reintroduction, it is just a question of how much decline in particular areas.

1. Funding from State General fund revenues.

The Organizations submit that SB21-105 provides significant clarity around the funding of the wolf reintroduction. Foundational questions, such as the current lack of general funds to support the wolf reintroduction must be addressed. We support the use of general state funds for the reintroduction of wolves for the reasoning we provide in our letter of support for HB21-1040.

2. Timing

Proposition 114 clearly identifies the mandatory end date for the wolf reintroduction efforts and the Organizations have concerns about the ability to meaningfully complete required actions by the December 31, 2023 deadline. Even when these goals and objectives are reviewed in comparative isolation, this deadline is optimistic and many efforts will have to be occurring at the same time to achieve this deadline. The Organizations can say with absolute certainty that the wolverine and lynx collaboration we have participated in took years and this occurred without a
Constitutional Proposal being passed and without much of the complexity that surrounds the wolf reintroduction in Colorado. SB21-105 takes the significant step in ensuring these issues are not overlooked in the rush to reintroduce wolves earlier or without analysis of important issues.

3. Hard wolf population goals should be provided in SB21-105.

While the Organizations support SB21-105 in its current form, the Organizations would respectfully request one amendment to SB21-105, which would be either the specification of a hard goal for population for sustainability or specify a specific process for determining a specific population goal. The Organizations also submit that SB21-105 should include a specific process for delisting under state listings and petitioning for delisting federally once this population has been achieved. Currently the concept of sustainable population is the only objective under Prop 114 and this is comically ambiguous and totally unenforceable. As seen with Gunnison Sage Grouse there is an almost religious zeal for more and more of any species that can only be addressed with hard population goals. Without these mandatory population objectives clearly laid out, we are simply not setting the wolf reintroduction up for success in the long term.

4. Engagement of US Fish and Wildlife Service ad NEPA requirements are vigorously supported.

The Organizations vigorously support the specific inclusion of the US Fish and Wildlife Service in stakeholder discussions as proposed in the SB21-105, as this is consistent with the USFWS national strategy on wolf management. The service provides the following outline of this strategy:

“we described our national wolf strategy in our proposed rule to revise the List for the gray wolf in the Eastern United States (76 FR 26089–26090, May 5, 2011). This strategy was intended to: (1) Lay out a cohesive and coherent approach to addressing wolf conservation needs, including protection and management, in accordance with the Act’s statutory framework; (2) ensure that actions taken for one wolf population do not cause unintended consequences for other populations; and (3) be explicit about the role of historical range in the conservation of extant wolf populations.”

The recognition of this strategy by SB21-105 would provide significant clarity and additional resources for wolf management. This involvement would also facilitate resolution of cross boundary management issues such compensation for herd damage claims in neighboring states that result from wolves CPW has reintroduced.

USFWS involvement also provides significant additional resources and management expertise to the wolf reintroduction. This is exemplified by the fact that USFWS already theorizes that the wolf population in Colorado is sustainable

“Post-delisting and subsequent monitoring, and the expansion of the NRM population into western Washington, western Oregon, northern California, and, likely, Colorado (USFWS 2020, pp. 15–19, 28; see also Current Distribution and Abundance), indicate that the wolf population in the NRM DPS remains well above minimum recovery levels (see Current Distribution and Abundance).”

In addition to the legal complexities that surround national wolf management there have been numerous other legal developments that will clearly impact the Proposition 114 efforts and create additional need for provisions such as those in SB21-105. The 2018 unanimous Weyerhaeuser decision of US Supreme Court1 requiring a definition of habitat be created by the US Fish and Wildlife service, which would clearly impact the identification of designated lands as the Wolf is already listed in Colorado for protection and that protection relies on federal definitions. Even with the temporary removal of the wolf from the federal list, the relationship of the state listing in Colorado and how the USFWS defines habitat will impact wolf processes in Colorado. Clearly designated lands in Colorado must in some way align with federal definitions of habitat areas for all wildlife. Again SB21-105 recognition of this situation is highly valued and will improve the quality of the wolf reintroduction. 

The Organizations vigorously support the application of NEPA processes and review to the reintroduction as such analysis is commonplace in management of species listed under the ESA. The Organizations are aware of landscape level NEPA for management of the lynx in the Northern Rockies and Southern Rockies, Greater and Gunnison Sage Grouse and numerous other species. This type of management is critical in obtaining consistent and clear species management across management boundaries. Without this NEPA analysis, management is often highly variable from site to site, poorly scientifically based and immobile in terms of updating. NEPA also allows funding to be focused on areas where research is actually needed to develop management clarity on issues such as possible management standards and concerns. These impacts must be avoided and we vigorously support this provision of SB21-105 for this reason.

5. What is an economically and socially sustainable Wolf population?

The previous concerns around social and economic issues raised in these comments only address a tiny portion of the social and economic concerns that are present around Proposition 114. The Organizations are doubtful that any State general fund money will become available to support this effort, given the drastically reduced tax revenues that are present in the state due to COVID restrictions, without the mandate of SB21-105. The Organizations are also aware that any wolf reintroduction costs mandated under Proposition 114 are basically entirely new costs to be assumed by CPW in an environment where there are numerous other statutory mandates that must be complied with beyond Proposition 114, such as those provided in the Future Generations Legislation. Until significant clarity on basic questions such as those can be resolved the Organizations submit that only two wolves should be reintroduced as this is all we can afford and there is significant credible science that indicates the existing populations of wolves in Colorado may be sustaining already.

Please feel free to contact Scott Jones, Esq. at 518-281-5810 or via email at or via USPS mail at 508 Ashford Drive, Longmont, CO 80504 for copies of any documentation that is relied on in this document or if you should wish to discuss any of the concerns raised further.

Scott Jones, Esq.
CSA Executive Director
TPA Authorized Representative
COHVCO Vice President

Don Riggle
Director of Operations
Trails Preservation Alliance


1 See, Weyerhaeuser v. US Fish and Wildlife Service; US Supreme Court; No. 17–71. Argued October 1, 2018— Decided November 27, 2018

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Article Featuring the TPA in February Off-Road Business Association (ORBA) Magazine

We would like to thank our friends at ORBA (Off-Road Business Association) for this article about the TPA in the February Off-Road Business Magazine as well as Chad de Alva with Lightforce Media,  Rob Watt, and the Central Colorado Mountain Riders motorcycle club for their photo contributions to the article.

Article reprinted with permission.

Fighting for Access One Trail at a Time
Colorado’s Trail Preservation Alliance

by Bill Alspach

Article first page with Don Riggle photoFormed in Colorado in 2008, the Trails Preservation Alliance (TPA) was the idea of Don Riggle and a small group of like-minded motorcycle enthusiasts who were concerned by the loss of off-road motorcycle riding opportunities, especially single-track, on public lands throughout the western U.S. Faced with rapidly diminishing and disappearing recreational opportunities for single-track motorcycle riding, the TPA was created as a grassroots, not-for-profit (501c3) organization based in Colorado with influences across the West.

The TPA is not a membership group but a focused advocacy organization dedicated to ensuring fair and equitable access for motorized recreation. Primarily a volunteer organization composed of motorcycle trail riders wanting to preserve access to public lands and motorized trail riding; the TPA often partners with other advocacy groups but the TPA remains the sole regional activist organization for motorcycle trail riders. While the TPA’s primary goal has always focused on preserving the sport of motorized single-track trail riding, all forms of OHV recreation are supported by the TPA’s efforts. The work of the TPA has been accomplished through working with federal land management agencies, namely the U.S. Forest Service and the Bureau of Land Management. The TPA also leads the education of user groups on appropriate trail etiquette, supporting like-minded organizations and assisting Colorado-based off-road motorcycle clubs.

Reviewing the past 25 years of USFS and BLM travel management decisions, it became apparent to Don Riggle, his fellow TPA founders and the TPA Board of Directors (all unpaid volunteers), that there had been a concerted effort by land managers to reduce or eliminate OHV recreation on public lands. Riggle states “That if one compares the recreational opportunities for OHV use with the significant increase in wilderness area designations, expansion of ski areas, and commercial enterprises on public land, almost every form of leisure time activity has received a reasonable share of access to public lands, with one exception – motorized vehicle recreation.”


The TPA’s volunteers along with a few select technical and legal consultants are constantly on the watch for upcoming land use decisions and projects undertaken by both the USFS and BLM, and in some instances State land managers and agencies. The TPA staff often partners with and works with State of Colorado outdoor focused organizations and agencies such as Colorado Parks and Wildlife, the Outdoor Recreation Office, regional recreation COOPs and others. With these partnerships, the TPA advocates for off-road motorcycle use and OHV recreation and takes whatever actions are necessary to help ensure land management agencies allocate a fair and equitable percentage of access to motorcycles and OHV recreation on public lands. To help ensure success of on-the-ground projects that enhance motorcycle and OHV recreation, the TPA occasionally provides funds to purchase tools, signs and matching monies for grants.

In the past 13 years, the TPA has sponsored and assisted with the formation of numerous off-road motorcycle clubs throughout Colorado encouraging and mentoring the clubs to build positive relationships with their local land managers. The TPA also assists and helps fund similar advocacy efforts for OHV recreation in Utah through its partnership with Ride with Respect and in New Mexico with NMOHVA. Likewise the TPA routinely partners with the Colorado Off Highway Vehicle Coalition (COHVCO). The TPA and COHVCO recently worked together to produce impact studies documenting the economic contributions of OHV recreation and associated tourism across Colorado, which is widely viewed as the best source for this economic information in the region.

The TPA is funded entirely through donations, financial contributions and proceeds generated from the Colorado 600. This funding is provided in part by industry supporters that include KTM USA, Rocky Mountain ATV/ MC, Klim, Motion Pro, Dunlop Tires, MotoMinded LLC, Billet Racing Projects, DoubleTake Mirrors, Scotts and E-Line along with several generous, anonymous donors that believe in the TPA mission. In addition, to help build the TPA’s reserves and ensure adequate operational capital, the TPA’s annual Trail Symposium Workshop, the Colorado 600, is the TPA’s largest fundraiser. This yearly event is a five-day, off-road motorcycle ride and educational symposium through the mountains of Colorado. Each day, in the morning and evening, riders learn about the challenges facing trail riding enthusiasts and issues surrounding persistent reduction of motorized trails in Colorado and surrounding states. Riders have options to enjoy riding single-track, dual-sport or adventure bike routes or rides. The event often includes speakers from the motorcycle industry, USFS, BLM, clubs and organizations around the country. Proceeds from the event directly support the TPA but they also contribute to positive economic prosperity of the many small communities and counties that host the event.

To maintain communication with TPA’s financial contributors and supporters, updates are regularly posted to the TPA website ( news/) and sent to subscribers using email. At year’s end, the TPA summarizes its activities and achievements in an annual report to TPA supporters via email and postings to the website. Moving forward the TPA will also be using additional social media avenues to expand its communication efforts.

The Future: The TPA recently selected and hired an Executive Director to lead the TPA into 2021 and the future. Chad Hixon brings over 16 years of proven experience in leading organizations and building successful businesses in Colorado. Chad is a skilled off-road motorcyclist and has a proven record as a multiple-use trail advocate. This new leadership position for the TPA will focus on fundraising and ensuring the TPA has sufficient funds to operate long into the future. Additionally, Chad will work to increase the TPA’s support of our affiliated motorcycle clubs along with enhancing the TPA’s regional recognition through marketing efforts that spotlight TPA activities to protect the sport of motorized trail riding and OHV recreation on public lands.


Check out the full February edition here:

ORBA February 2020 magazine cover

Download a PDF of the TPA article:

Article first page with Don Riggle photo





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Funding wolf reintroduction in Colorado HB 21-1040

Representative Perry Will
200 East Colfax, Rm 307
Denver CO 80203

Re: Funding wolf reintroduction in Colorado HB 21-1040

Dear Representative Will:

Please accept this correspondence as the vigorous support for HB 21-1040 “Concerning the requirement that the costs associated with the reintroduction of gray wolves in the be paid exclusively from the general fund” of the Organizations identified above. Our primary concern is how is this effort going to be funded, as we are opposed to any OHV/OSV program money funding this effort. The Organizations submit that HB21-1040 provides significant clarity around the funding of the wolf reintroduction.

Prior to any discussion around the financial sustainability of the wolf reintroduction, the Organizations would like to clarify our unwavering support for the full compensation of any interest who experiences a loss as a result of the wolf reintroduction. These are valid costs that must be reimbursed fully. The financial sustainability of any species reintroduction is of critical concern to the Organizations and unfortunately, we are already intimately aware that Enterprise funds or other statutorily protected monies within CPW are “State money” for purposes of Prop 114 until the Legislature decides otherwise. This is contrary to Foundational assumptions as many users believe State general fund monies would be available to cover damage claims. HB21-1040 is a significant step in resolving this type of issue.

We have attached the Legislative Services memo that was provided to the Joint Budget Committee regarding the wolf reintroduction effort as Exhibit “A”. This memo specifically identifies management costs borne by States already managing reintroduced wolves. This memo identifies these costs as follows:






FY 2018-19



CY 2019

Oregon (biennial)





FY 2018-19

In current budgets, Colorado has directed minimal amounts to wolf issues, and costs borne around a wolf reintroduction are entirely new. Colorado is estimating $340,000 for just creating the wolf reintroduction plan. Herd damage claims from wolves probably cannot be accurately estimated since we have no idea how many wolves will be reintroduced but we can assume herd damage claims are basically zero from wolves in Colorado, which results in any damage claims being entirely new costs to be borne by a program that is already experiencing tight budget conditions. We are not optimistic that costs such as game damage claims will compete against needs such as COVID response, wildfire response or infrastructure needs for exceptionally limited state budget funds. This type of funding will need to be mandated. This is a major lift in isolation and another reason the detail of HB21-1040 is welcomed by our Organizations.

The long-term social impacts of funding that wolf reintroduction must addressed, given the support from generally non-consumptive users of recreation. The Organizations have partnered with CPW to try and develop alternative sources of funding. Cornerstones of North American management models are the fact that funding from specific user group fees should provide identifiable benefits to the user group. This has been one of the cornerstones of success for the OHV and OSV programs within CPW, which has become eroded already as only 60% of OHV revenues has been requested by DNR to be authorized for spending by the JBC after millions in user paid funding has been swept already. Programmatic support further erodes when possible funding is allocated to other priorities, despite the statutory protections against this usage provided in 33-14-101 et seq and 33-14.5-101 et seq. This is a concern for us and causes a variety of sustainability concerns for the partnership. The longer-range impacts must also be reviewed for sustainability as well as there are no user groups that are going to provide funding to support CPW and expand CPW efforts when only 60% of moneys may be applied to the program. The Organizations are opposed to OHV/OSV programmatic funds being eroded or put at further risk of loss to cover wolf reintroduction costs. HB21-1040 is a significant step towards avoiding this type of risk.

Please feel free to contact Scott Jones, Esq. at 518-281-5810 or via email at or via USPS mail at 508 Ashford Drive, Longmont, CO 80504 for copies of any documentation that is relied on in this document or if you should wish to discuss any of the concerns raised further.

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2021 Omnibus Wilderness & Amendments

Congresswoman Lauren Boebert
Att: Jeff Smalls & Ashley Higgins
1609 Longworth HOB
Washington DC 20515

Re: 2021 Omnibus Wilderness & Amendments

Dear Jeff and Ashley;

Please accept this correspondence as the comments of the above-referenced Organizations vigorously opposing the CORE Wilderness Proposal (HR 803) and the Colorado Wilderness Act (HR577) hereinafter referred to as “the Proposal”. After a detailed review of the Proposal, the Organizations have concluded that every area expanded or created in the Proposal would result in significant lost recreational opportunities for the overwhelming portion of visitors to the Proposal area, both currently and in the future. While there are significant lost opportunities, there is also no additional protections for multiple use routes that might remain outside the Wilderness areas and no new areas are designated or released for multiple use recreational opportunities.

The Organizations have spent many years trying to hammer out something that works for everyone around these proposals, and have simply been stonewalled at every turn by the sponsors of this legislation in both Houses of Congress. This is despite the fact our groups were thanked by outgoing Senator Mark Udall for our collaboration and efforts around the development of the Hermosa Creek Watershed Management legislation in signed into law on December 19, 2014 as Section 3062 in the Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act for Fiscal Year 2015 (PL 113-291). This legislation released a WSA and specifically protected motorized usage in the area moving forward, designated a large special management area where multiple uses were protected and designated Wilderness in areas where that management was appropriate. We had hoped this collaboration was a roadmap for resolving many of the ongoing challenges we encounter around Wilderness designation and releases. Unfortunately, we were incorrect as exemplified by the efforts around HR 577 and HR 803 as phone calls are not returned, meetings are continued and ideological trench warfare has returned around these Proposals.

It is worth noting, the Colorado Wilderness Act would heavily impact many recently developed trail networks that have enjoyed strong bi-partisan and community support or historical trail networks that serve a wide range of interests. Examples of these types of losses would include:

  1. Bangs Canyon area, which developed an extensive multiple use trail network after a complete NEPA review and analysis and almost a million dollars in direct funding from users for the project. The Bangs Canyon SMA area is now to be designated as Wilderness.
  2. Delores Canyon – this area has a large network of trails serving a wide range of interests that has existed for an extended period of time without controversy.

While the list above is far from exhaustive, these are examples of impacts we are seeing all too frequently.

a. Our position on Specific Amendments.

Please note that while we do not specifically address every Amendment, several of these are unrelated to recreational usages and outside our expertise to discuss in a meaningful manner. While we are not opposed to any of the Amendments on the list, we are not taking a position.

  1. Rep. Boebert 30×30 Program Nullification Amendment #18
    Vigorously support. This Executive Order is a direct conflict with multiple mandates that have managed public lands successfully for decades. Not only does this EO conflict with these mandates, the application of these concepts to private property rights and interests is even more troubling.
  2. Rep. Boebert – BLM headquarters – Amendment #16
    Vigorously support. Moving BLM national headquarters closer to lands owned and managed by BLM has greatly increased the responsiveness of the BLM to a wide range of issues. This amendment has garnered strong bipartisan support.
  3. Rep. Boebert Native Americans, Other Minorities and Women Jobs Protection Act – Amendment #60
    No position.
  4. Rep. Boebert CO, AZ, CA, WA Wilderness Study Act Amendment #56
    Vigorously support. The lingering designations around the Wilderness process create significant management challenges moving forward in areas that have never been suitable for designation as Wilderness. The loss of historical recreational opportunities due to the lingering designation of the West Needles WSA was a major issue driving the Hermosa Creek legislation.
  5. Rep Boebert Wilderness Wildfire Amendment #20
    Vigorously support. Impacts from catastrophic wildfire must be addressed to avoid further impacts to recreational usages and other interests outside the burn areas. Prohibiting this management by a subsequent Congressional designation of Wilderness simply makes no sense. Even without a Wilderness designation these efforts can be hugely expensive and the goal for these areas must be restoration and stabilization in a cost effective and timely manner.
  6. Rep Boebert Wilderness Authorization Amendment #19
    Vigorously support. Too often local interests in a Wilderness designation are overwhelmed by large special interests that are not even familiar with the areas being designated. Both CORE and Colorado Wilderness Proposals have extensive opposition from local governments impacted by designations but these concerns are not an issue for special interests based in Denver.
  7. Rep Boebert Colorado Wilderness Study area release Amendment #17
    Vigorously support. This has been proposed in stand alone legislation and as a possible balancing interest in the CORE proposal as part of Congressman Tipton’s REC act. Release of this designation is hugely important to the motorized community. These have proven unsuccessful previously.
  8. Rep Boebert Recreation Amendment 14
    Vigorously support. It is our experience that clearly stating all actions to be protected in the designation is a critical step and this simply has not been done in the Curecanti NRA portions of the Proposal. There is a long history of diverse high-quality recreational opportunities being provided without controversy in the proposed Curecanti NRA. These high-quality multiple use opportunities have been specifically recognized when Congress passed legislation exploring a possible Congressional designation for the area in 1999. These are recreational opportunities that the Organizations and its members have enjoyed in the area including use of the 10 campgrounds located throughout the proposed NRA some of which are approaching 100 sites in size. When Congress mandated review of the Curecanti area for possible designation as an NRA, Congress specifically recognized that:
    “Congress finds that….
    (8) land in and adjacent to the Black Canyon of the Gunnison Gorge is—
    (A) recognized for offering exceptional multiple use opportunities;”1
    As a result of Public Law 107-76, the NPS undertook an extensive review and analysis of the recreational usage on the Curecanti NRA. This research specifically identified the wide range of important recreational opportunities on the Curecanti as the NPS identified the following breakdown of visitation to the area:2While there is a long history of high-quality multiple use recreation occurring in the Curecanti NRA with Congressional recognition and approval, the CORE Wilderness act seeks to greatly reduce the scope of these opportunities without discussion. Currently, the CORE Wilderness Act requires that the Curecanti NRA is to be managed for:
    “(A) AUTHORIZATION. —Except as provided in subparagraph (B), the Secretary shall allow boating, boating-related activities, hunting, and fishing in the National Recreation Area in accordance with applicable Federal and State laws.”3
    The wide range of recreational opportunities and diversity simply is not supported or protected when the characteristics of the Curecanti NRA are hunting, fishing and boating. In a troubling turn of events, hunting, which is identified as the reason less than 5% of visitors are using the Curecanti NRA is identified as a characteristic of the NRA, while other uses such as camping and trails-based usages, which are some of the highest visitations of the area are omitted. This simply lacks any basis in logic or fact and simply must be resolved to ensure that the current usages of the area are reflected as the Curecanti area is an area where all recreational usage exists with minimal conflicts and identified as one of the big wins for multiple use. Our position on that assertion is exactly the opposite.
  9. Rep Boebert Water Rights Amendment #13
    No position.
  10. Rep Boebert Grazing Amendment #15
    No position.
  11. Rep Boebert grazing Amendment #66
    No position.
  12. Reps. Stauber and Boebert Amendment #11
    Vigorously support for reasoning in issue #6.
  13. Reps Stauber and Boebert Amendment #12
    Vigorously support for reasoning in issue #6.
  14. Reps. Stauber and Boebert Amendment #10
    Vigorously Support. Our concerns with Thompson Divide and mineral withdrawal more generally are the standards proposed would require management of the area to reduce emissions generally found in auto exhaust. This could be used to close trails in these area in the future. We would like to see any management restricted to at least point sources for emissions.
  15. Reps Fulcher, Boebert and Man water Rights- Amendment #39
    No position.
  16. Reps Fulcher, Boebert and Man water Rights- Amendment #44
    No position.
  17. Reps. Westerman and Boebert OHV trail Amendment #48
    Vigorously support. This is a major concern for the motorized community as many proposed Wilderness boundaries are only a few feet from adjacent trails outside the Wilderness. This makes it very difficult to impossible to maintain the trail in the long term and also puts the trail at risk of immediate closure as MVUM and forest service mapping often is not accurate enough to be used in this manner.
  18. Reps Westerman and Boebert High Risk Fire Amendment #46
    Vigorously support for reasoning in #5.
  19. Reps Newhouse and Boebert Amendment #54
    No position.
  20. Reps LaMalfa and Boebert vegetation management
    Vigorously support for reasoning on issue #5.

B. Conclusion.

The Organizations welcome this opportunity to comment on the proposal and related amendments. These amendments are a step in the right direction.

Please feel free to contact Scott Jones, Esq. if you should wish to discuss any of the issues that have been raised in these comments further. His contact information is Scott Jones, Esq., 508 Ashford Drive, Longmont Colorado 80504; phone 518-281-5810; email

Respectfully Submitted,

Scott Jones, Esq.
COHVCO/TPA Authorized Rep.
CSA President

Don Riggle
Director of Operations
Trails Preservation Alliance

1 See, Public Law 107-76 at §2.
2 See, National Park Service; Curecanti National Recreation Area- Visitor Study- Summer 2010 at pg. 34
3 See, §402(c)(4) of the CORE act proposal.

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