Archive | January, 2023

Seasonal Trail Closures – Salida Ranger District Trails # 1434, 1412 & 1336

Re: Seasonal Trail Closures – Salida Ranger District Trails # 1434, 1412 & 1336

To whom it may concern,

Thank you for the opportunity to comment on updates to the Season Trail Closures in the Salida Ranger District (SRD). Please accept these comments in objection to the proposal.

The TPA is a volunteer centered 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 off-road motorcycle riding. The TPA acts as an advocate of the sport and takes the necessary action to ensure that the USFS and BLM allocate a fair and equitable percentage of access to public lands.

All public land users must question any management strategy that limits or closes access to public land. We must ask questions and insist that the justification behind these decisions is relevant and based on fact. As a motorized advocacy organization we know to well what it means to have your access limited on public lands. Our initial reaction to the SRD’s proposal was in favor of expanding seasonal closures to all uses on the following trails; Greens Creek #1412, Rainbow Trail #1436 and ATV route #1434. After all, it only seems to make sense that if human disturbance is the issue then all human related activities be limited.

At first glance this seems like an obvious conclusion and now that seasonal closures are becoming more common to include all uses it would indicate that it is an effective strategy. However, we have been unable to find an example of where their implementation has a measurable deliverable as to its effectiveness as part of the proposal. If they are effective at achieving their goals shouldnt part of the plan include how that will be measured? Are seasonal closures rescinded or reevaluated if, after a certain amount of time, issues persist, get worse or get better? Coupled with questionable rationale behind their implementation in the first place, these are just some of the questions all public land users must ask of those implementing or suggesting them as a management strategy.

Therefore, with thoughtful consideration and the review of supporting documents it is the TPA’s suggestion that the SRD not expand the current seasonal closures to include all uses. In addition the TPA suggests that the SRD revisit the existing closures and the rationale that has put them in place. Please find additional comments prepared by Wildlife Science International on behalf of the TPA below.


Chad Hixon
TPA Executive Director




Chad Hixon
Trails Preservation Alliance

Rob Roy Ramey II, Ph.D.
Wildlife Science International, Inc.
P.O. Box 386
Nederland, CO 80466

Date: January 15, 2023


Please submit my scientific review (below) of as part of your comments on the proposed seasonal closures of the following trails: Greens Creek #1412, Rainbow Trail #1336, and the 1434 ATV route (hereafter referred to as, Proposed Action).

Review of Proposed Action


The USFS has failed to provide a credible scientific rationale in support of the Proposed Action. More specifically, the proposed action rests on the false premise that non-hunting recreation (motorized or non-motorized) in big game winter range is a threat to local elk and mule deer populations. That premise and the three-sentence rationale for the Proposed Action, are based upon nothing more than surmise and speculation. The premise and rationale behind the Proposed Action are also refuted by elk and mule deer population data and statements in CPW’s herd management plans. The sole scientific support cited in support of the Proposed Action is an erroneous citation to the findings of Ciuti et al. (2012).

1) The premise that non-hunting recreation on public lands in and around Chaffee County is a threat to its local big game populations of elk and mule deer, is frequently stated as if it were fact, however, it lacks a factual basis. To date, no credible data have been produced that directly link non-hunting recreational use with declines in individual fitness or population trends in elk or mule deer that cannot be attributed to other factors including: density dependence, disease, competition, hunting, predation, permanent development, drought, and/or biased experimental design (i.e. repeated pursuit of radio-collared animals until reproductive failure occurred or harassment inside of enclosures where they were previously hunted). An exhaustive scientific review of this fundamental issue may be found in my peer review of the Chaffee County Wildlife Tool (attached and included herein as part of this comment).

2) The rationale behind the Proposed Action is contrary to CPW’s most recent elk and deer population estimates. The 2019-2021 elk population data for the Data Analysis Units E-17, E-27, and E-22, shows that all three of these populations are above current objectives. Those data may be found here:; Herd Management Plans may be found here:

While mule deer in Data Analysis Units D-15, D-16, and D-34 are below objective, herd management plans make no mention of this being the result of recreational disturbance of any kind. Instead, cougar predation, density dependence, habitat conversion by agriculture and development have been the leading causes of decline to now stable levels. Mule deer D16 (2020) plan states, “Since 1999, the leading cause of known deer mortality in D-16 has been cougar predation, which led to the initiation of a nine-year, three-staged research project in D-16 and neighboring herd D-34 to examine mule deer population response to changes in cougar density and how cougar/deer populations respond to various harvest levels. This project will provide better understanding of how cougar harvest could be used as a deer management tool.”

The D-15 herd plan states, “Since its low point in the mid 1990s following an apparent density-dependent population crash, this population has gradually rebounded and increased to a post-hunt 2009 estimate of nearly 6,000 deer. With the exception of a slight population decline associated with low survival rates during the substantial winter of 2007-08, the population trend for this herd remains positive. However, measured survival rates of radio-collared fawns and does in the adjacent D-16 DAU (Cripple Creek Deer Herd) have again begun to decline in recent years and local biologists have begun noticing apparent over-use of available winter range forage. Much of the available habitat has reached later-seral stages and appears heavily browsed. Game damage complaints are currently at reasonable levels, but have increased somewhat in recent years, particularly in and around the human population  centers of Salida and Buena Vista. Given these indicators, current populations may be approaching the general social and biological carrying capacity for deer in this DAU as current habitat conditions, human encroachment and development, and competition with elk and livestock begin to potentially create a density-dependent situation.”

Thus, there are no data to support the premise and rationale for the Proposed Action.

3) Ciuti et al. (2012) was either misread or misrepresented by USFS staff writing the justification of the Proposed Action. Reading Ciuti et al. (2012) closely, it is clear that the “landscape of fear” studied by the authors was created by the obvious threat of hunting on public lands, and not by non-hunting recreation. As pointed out by Ciuti et al. (2012) and others, hunting is what leads to a “landscape of fear” where humans are perceived by game species as predators, which leads to increased vigilance and potential avoidance of human activity. The association between hunting and motorized vehicles, including UTVs, ATVs and e-bikes all used by a large proportion of hunters, is what leads to game animals exhibiting stronger reactions to them. Thus, the USFS needs to recognize that it is not hiking, horseback riding, cycling, e-biking, motorcycling, ATVing, or vehicles per se that are driving elk vigilance, it is first and foremost, hunting.

The following excerpts from Ciuti et al. (2012) underscore why recreation hunting on public lands is the driver of the behaviors they observed:

“The highest levels of vigilance were recorded on public lands where hunting and motorized recreational activities were cumulative compared to the national park during summer, which had the lowest levels of vigilance.”

“This is a true landscape of fear, where each human is perceived by elk to be a potential predator, even within the protected area, as animals are threatened by hunting pressure immediately along its borders.”

We found the highest levels of elk vigilance on public lands during the hunting season, when hunting and intrusive recreational activities occurred cumulatively, whereas the lowest levels were found in the national park in summer – even when crowded with people…”

“If hunting is not permitted, then behavioural adaptations, such as habituation, can evoke a decrease in vigilance levels (Fig. 4; [72]).”

“… in a human-dominated landscape where hunting is allowed, behavioural responses to road traffic can be extreme.”

In addition to the findings above, Ciuti et al. (2012) stated that:

“We documented the complex link between disturbance and behavioural response in a human-dominated landscape, though we were not able to estimate the actual cost of human disturbance on wildlife in terms of fitness and population dynamics.”

This is an honest acknowledgement that is important relative to the Proposed Action (and similar closure orders like it) because it illustrates the notable absence of any evidence of a negative effect on survival and reproduction at an individual level (i.e. Darwinian fitness), or collectively on population trends, that are independent of other factors (i.e. predation, disease, climatic variation, and overabundance). Yet, despite an absence of data and exclusion of other factors through hypothesis testing, some authors prefer to assume that virtually any behavioral reaction by wildlife to human activity will somehow be deleterious to the wildlife population. However, federal agencies cannot rely on unsupported assumptions, nor surmise and opinion, instead they are required to comply with the Information Quality Act. And, as discussed above, the best available data do not indicate that there is any deleterious effect of recreational activity on elk or mule deer in any of the three trails covered in the Proposed Action. Nor are there unbiased data in the literature indicating the same from other Rocky Mountain elk or mule deer populations (see peer review of Chaffee Wildlife Tool for additional details). In fact, CPW population estimates reveal that elk populations in Colorado are at an all-time high of over 308,000 with an increase of over 33,000 in just the past seven years.

The paper by Ciuti et al. (2012) (as well as other behavioral ecology papers in the recent peer reviewed literature including Cromsigt et al. 2013; Middleton et al. 2013; Paton et al. 2017; Spitz et al. 2019; Zanette et al. 2019; Zanette and Clinchy 2020) also underscore why the USFS needs to rethink its approach to managing public access to public land in this area. It is the majority of users that should retain full access, rather the minority, recreational hunters, who currently represent just 3% of visitor days in USFS lands in the Rocky Mountain Region (USFS 2020).

4) If the USFS truly wishes that elk or mule deer become less vigilant in human presence (i.e. more habituated), the solution is simple: implement a year-round firearms and hunting closure in those areas where the most important high quality winter range is found. The elk will seek out these areas, as they do park lands, private lands, and urbanized areas where hunting is not a threat and humans are not perceived as predators. The clearest example of this behavioral adaptation to seek out refuges free of hunting pressure (and where humans are not perceived as predators) can be found in Rocky Mountain National Park and the adjoining land of the City of Estes Park, Colorado. Elk and mule deer wander the streets, suburbs, and open space lands unperturbed by all manner of motor vehicles, cyclists and pedestrians. Such a year-round firearms and hunting closure environment would allow a more balanced coexistence of hunting and non-hunting recreation.


In interest of the health of our big game populations, I urge the USFS to drop consideration of the Proposed Action and reconsider the rationale of previous closures to these trails. Instead of unjustified seasonal recreational closures, the USFS should  focus instead on the two issues that are expected to impact elk and mule deer populations in this area: the spread of Chronic Wasting Disease and the soon to be implemented gray wolf reintroductions.


Rob Roy Ramey II, Ph.D.
Wildlife Science International, Inc.



Literature Cited

Cromsigt JPGM, Kuijper DPJ, Adam M, Beschta RL, Churski M, Eycott A, Kerley GIH, Mysterud A, Schmidt K, West K. 2013. Hunting for fear: innovating management of human–wildlife conflicts. Journal of Applied Ecology 50(3):544-549.

Ciuti S, Northrup JM, Muhly TB, Simi S, Musiani M, et al. 2012. Effects of humans on behaviour of wildlife exceed those of natural predators in a landscape of fear. PLoS ONE 7(11): e50611.10.1371/journal.pone.0050611

Middleton AD, Kauffman MJ, McWhirter DE, Cook JG, Cook RC, Nelson AA, Jimenez MD, Klaver RW. 2013. Animal migration amid shifting patterns of phenology and predation: lessons from a Yellowstone elk herd. Ecology, 94(6): 1245–1256.

Paton DG, Ciuti S, Quinn M, Boyce MS. 2017. Hunting exacerbates the response to human disturbance in large herbivores while migrating through a road network. Ecosphere 8(6):e01841. 10.1002/ecs2.1841

Spitz DB, Rowland MM, Clark DA, Wisdom MJ, Smith JB, Brown CL, Levi T. 2019. Behavioral changes and nutritional consequences to elk (Cervus canadensis) avoiding perceived risk from human hunters. Ecosphere 10(9):e02864. 10.1002/ecs2.2864

Thompson MJ, Henderson RE. 1998. Elk Habituation as a Credibility Challenge for Wildlife Professionals. Wildlife Society Bulletin 26(3): 477-483.

U.S. Forest Service (USFS). 2020. Rocky Mountain Region Trails Strategy.

Zanette LY, Hobbs EC, Witterick LE, MacDougall-Shackleton SA, Clinchy M. 2019. Predator-induced fear causes PTSD-like changes in the brains and behaviour of wild animals. Scientific Reports, Nature Research 9:11474

Zanette LY, Clinchy M. 2020. Ecology and Neurobiology of Fear in Free-Living Wildlife. Annual Review of Ecology, Evolution, and Systematics. 51:297–318.



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2022 Ride With Respect Year in Review

Reprinted with permission 
Ride with Respect Year in Review 2022

In 2022, Ride with Respect’s work progressed in every direction, literally and figuratively. Our advocacy of access for responsible recreation stretched from the Arizona border to the Wyoming border, while our education and trail work is laying the ground work to match the scale of motorized use around Moab (see attached photos).

To do more than ever before, RwR has also had to spend more on things ranging from NEPA consultation to heavy equipment. We depend on all trail lovers to chip in, and you can make a tax-deductible donation by writing a check to Ride with Respect, 395 McGill Ave, Moab UT 84532. Please specify if you’d like the receipt to indicate a donation made in 2022.

On top of the many contributions amounting to tens or hundreds of dollars, so far this year has blessed RwR with ten people who contributed between one-thousand and ten-thousand dollars, some of whom have contributed for two decades and counting. We’re counting on new folks to recognize that, even as RwR grows, the organization remains a lean operation and highly-effective way to help save trails.

Finally we give thanks for other organizations’ support of RwR, including the State of Utah OHV Program’s support of OHV trail host volunteers, acquiring incredible tools like an excavator with an off-road trailer, and persevering participation in land management plans. Also in planning matters, RwR continues to enjoy the partnership of the Trails Preservation Alliance, which contributes more than its share. The Grand County Recreation Special Service District funded our maintenance of Sovereign Trail System. Rocky Mountain ATV/MC will provide perks for our OHV trail host volunteers on top of supporting our general operations. Last but not least is a generous grant from Right Rider Access Fund, which is made possible through contributions from MIC, SVIA, and ROHVA. The grant enables RwR to invest in upgraded safety gear for us to maintain trails, educate visitors, monitor conditions, and invite decision-makers to view trails on public lands firsthand.

Trail Work

RwR spent several hundred hours maintaining trails in 2022. On Sovereign Trail, our work included a couple small reroutes of the singletrack, and a couple field trips with managers of the new Utahraptor State Park. The park will eventually charge entrance fees (not just camping fees), but we trust that they’ll improve trails, as their staff has already begun pitching in on Sovereign Trail.

On the Dubinky trail system toward Green River, RwR worked with the BLM to repaint the slickrock blazes and define the designated width (singletrack, ATV, or 4WD) at trail entrances. For three days, we joined the trail crew from Utah’s new Division of Outdoor Recreation (UDOR), which came from Salt Lake City to delineate trails between Crystal Geyser and Tenmile Wash. For another three days, we joined UDOR’s mini-dozer operator to install rolling dips and other tread work on Camp Jackson and Wagon Wheel ATV trails in the Abajo Mountains. We’re pleased to see UDOR’s aim to establish multiple crews around the state, and RwR can continue to help make them as productive as possible.

A half-mile up Gemini Bridges Road, RwR assisted the Moab Friends For Wheelin’ to delineate the free parking area and post rules to respect the property. Property owners Intrepid Potash have generously accommodated public use thus far, so it’s key that we maintain access by refraining from camping or leaving any litter, especially human waste. If nature calls, you can use the vault toilet at the very bottom of Gemini Bridges Road by paying their parking fee. Alternatively, back in the Intrepid Potash parking area, you can use your own portable toilet. Even in more remote areas, you can carry a portable toilet in the form of a disposable sanitation kit (aka WAG bag). Grand County provides bins to dispose of your WAG bags for free. This toilet talk might sound like a load of crap, but when so many recreationists are digging shallow holes behind the same few trees every year, it becomes unsightly and unsanitary (especially if it’s near any kind of water source).


RwR calls out OHV critics for exaggerating or even fabricating negative impacts of riding on other forms of recreation and on the land itself. By the same token, when problems exist, we face them and try to fix them. A small portion of riders absolutely are harming public resources, and they need to be brought into the fold or brought to justice. (To that end, UDOR is dedicating another law-enforcement officer in southeast Utah to join county and federal officers.) Many newer riders don’t know the finer points of a trail ethic, which can also add up, and fortunately Grand County produced a more detailed video about minimum-impact practices.

Also this year, the State of Utah upped its game with the passage of H.B 180, which requires (a) adult OHV operators to complete an online course, (b) all ATVs to have license plates even if they’re not street-legal, and (c) people convicted of driving off of designated routes to repair any damage through community service. You can find out the course requirements on the Utah OHV Program’s website but, since the course is free and takes just half an hour, we encourage everyone to take the course regardless of whether they’re required. RwR provided feedback on an early version of the course, and we’re optimistic that it’ll cover the points everyone should know before they hit the trail. This course along with the license plate and community service requirements should make rider compliance and our ability to advocate access even stronger.

Motorized Trails Committee

In the third year since Grand County established its Motorized Trails Committee (MTC), RwR continued to support it as I (Clif) continued to serve as the chair. RwR thanks all of the MTC members for attending monthly meetings, including county staff, the BLM, and especially the volunteer OHV enthusiasts. County leaders have differed with the MTC on some major issues, sometimes without considering the MTC’s input, but common interests have led to some wins for all parties.

After a couple years of building consensus with the Sand Flats Stewardship Committee and proposing refinements to Hells Revenge and Slickrock Trail, the BLM approved most of the MTC’s requests, which the MTC then implemented. One refinement shown in an episode of At Your Leisure TV was redesignating The Staircase from motorized singletrack to 4WD so that Hells Revenge users could directly return to the entrance after doing the whole slickrock part of the loop. Likewise we redesignated the Black Hole bypass from motorized singletrack to 4WD so that all users would have the option of avoiding exposure to the cliff edge. Also we rerouted the Spillway “dot route” (motorized singletrack alternate of Slickrock Trail) so that riders could park within 100 yards of Mountain View Cave. Finally we reopened the Updraft “dot route” that overlooks the spectacular corridor of Highway 128. Updraft was designated as part of the original Slickrock Trail network over a half-century ago, but it was technically closed by the BLM in 2008, so we appreciate the agency and Sand Flats staff for being open to reopen this inspiring route.

The MTC has faithfully continued to host “rake and ride” trail work each month. Additionally, on Steel Bender (aka Flat Pass) 4WD trail, the MTC made the legal (NE) bypass of Dragon Tail less difficult while blocking off the illegal (SW) bypass. Half the work came from Xtreme 4×4 Tours staff and tow equipment. All these resources were donated, as Grand County has budgeted no funding for the MTC, although the county has budgeted to expand its trail ambassador (education) staff so it can include motorized trails next year.

Moab Camping Management Plans (CMPs)

The BLM proposed Camping Management Plans (CMPs) for the Labyrinth Rims / Gemini Bridges area between Moab and Tenmile Canyon, the Utah Rims area from the Colorado state line to the Westwater put-in road, and the Two Rivers SRMA including several roads that drop down to the Dolores River and Colorado River near Cisco. RwR supports the proposal to limit camping to designated dispersed sites because these areas can’t sustain new levels of camping without defining the sites just as a Travel Management Plan (TMP) defines the routes. Campsites could remain plentiful, dispersed, and free except in specific areas where infrastructure like toilets are needed, which may warrant clustering sites and charging fees in those areas.

However the BLM didn’t pledge to thoroughly inventory the existing sites or indicate which specific sites it plans to designate open or closed. Second it didn’t pledge to provide public review of the inventory or designation of individual sites. Third, if many sites are closed, the proposal would likely displace camping use and impacts to adjacent areas such as north of Tenmile Canyon and west of the Westwater put-in road. Provided a more thorough process, the CMPs should actually encompass larger areas of comparable terrain. Fourth, how the dispersed camping interfaces with designated campgrounds (e.g. no-camping buffers around the campgrounds) or sets the stage to cluster / charge fees for camping in any specific areas should also be subject to public review just like the process of inventorying and designating individual sites. Adding to those four points, RwR partnered with the TPA, COHVCO, and CORE to comprehensively comment.

Grand County’s Motorized Trails Committee (MTC) agreed with the four points above, and recommended them to the county commission. The staff of groups seeking to vastly expand the designation of wilderness (which prohibits mechanized use including bicycling) opposed this request for public review of a thorough campsite inventory and a BLM proposal that actually identifies which sites would be designated open or closed. Fortunately, in this instance, the county commission sided with its MTC. Since then, the BLM has expressed appreciation for the constructive feedback, and pledged to provide more meaningful opportunities for public participation before limiting camping to designated sites in these three planning areas.

San Rafel Desert Travel Management Plan (TMP)

The San Rafael Desert between UT-24 and the Green River is the first Travel Management Plan (TMP) completed from the 2017 settlement agreement, thus setting the stage for the other eleven TMPs in the southeast half of the state. As you may recall from our previous Year In Review, the 2020 San Rafael Desert TMP closed a third of the existing routes. It‘s actually more like half of the existing routes when you exclude the graded roads and highways for which the BLM lacks jurisdiction. True to their “uncompromising” mission, wilderness-expansion groups sued the BLM while OHV groups, the State of Utah, and Emery County intervened in defense of the BLM. The BLM’s Price Field Office staff began to defend the 2020 TMP as reasonable by and large but, by 2022, it became clear that political appointees are directing local staff to essentially throw out much of the work they had performed from 2014 to 2020.

This January the BLM closed another 35 miles of route without doing an environmental assessment because the agency said closures would be temporary and followed by an environmental review that would determine whether each route is open or closed in the long term. OHV groups, the State of Utah, and Emery County appealed the “temporary” closures because this emergency authority is only authorized to prohibit use that will cause a significant adverse effect. In the case of these 35 miles, the BLM only claimed to protect the soil and plants growing on top of the routes themselves. RwR along with the TPA and COHVCO provided a biologist’s report finding only common plants on these old mining roads and motorcycle race courses. Yes, common plants have grown on the routes especially since 2008 when most San Rafael Desert routes were technically closed due to a complete lack of route inventory, and plants even grow on graded roads in the San Rafael Desert due to the nature of migrating sand dunes. Further, the BLM’s rationale could be applied to myriad doubletracks since plants grow in the center hump, yet temporarily closing those doubletracks would be an abuse of the emergency authority. We also pointed out that a closure is “temporary” in name only when it doesn’t even set a timeline goal for the subsequent environmental review. In this case, it appeared that the review would hinge upon the approval of a backroom deal to settle the wilderness-expansion groups’ appeal of the 2020 TMP, which is clearly putting the cart before the horse.

This February the BLM indeed released a settlement deal it had negotiated with the wilderness-expansion groups to the complete exclusion of OHV groups, the State of Utah, and Emery County despite that all of us had intervened on the BLM’s behalf ever since the wilderness-expansion groups sued in 2020. As with the temporary closures, we appealed this new settlement, which requires the BLM to reconsider 195 miles of the routes designated open by the 2020 TMP. In August the BLM finally showed the public the location of the 195 miles of routes, and indicated its preliminary decision to close most of them, but it didn’t indicate the rationale or any analysis that would be found in an environmental assessment as required by NEPA. RwR along with its Colorado partners provided photographs and descriptions of many routes’ recreational value and lack of potential impacts to other social or natural resources.

Without responding to our comments, this October the BLM made very few changes to its preliminary decision, and closed another 120 miles of routes in the San Rafael Desert. The agency’s only explanations were found in the cookie-cutter cells of a spreadsheet, claiming that routes lacked recreational value despite that RwR had painstakingly demonstrated the great value of many routes. The spreadsheet also claims that the routes are “reclaimed” even when the route consists of a wide, non-riparian wash bottom that’s composed of loose sediment. The BLM’s decision blatantly fails to meet NEPA’s requirement to invite public input on a thorough analysis of impacts (which includes the positive impacts of OHV recreation on lifestyles and livelihoods). Naturally OHV groups, the State of Utah, and Emery County appealed this decision which, along with our appeals of the temporary closure and 2022 settlement, ought to compel the BLM to provide proper process and sufficient evidence when closing additional trails. RwR has supported many route closures, sometimes even initiating the closure and implementing it on the ground, but we expect agencies to follow their own rules even when an administration wishes that the legislature had given the agency a different mission.

Labyrinth Rims / Gemini Bridges TMP

The BLM’s 2017 settlement also requires reconsideration of the TMP at Labyrinth Rims / Gemini Bridges, which covers many word-class OHV trails between Moab and Green River. For 22 years, RwR has been very engaged in travel planning there, spending several-thousand hours just in rerouting over a dozen trails away from sensitive resources. As you may recall from our previous Year In Review, the 2008 TMP closed roughly half of the existing routes in Labyrinth Rims / Gemini Bridges, and the most restrictive of the BLM’s preliminary alternatives in 2021 would’ve closed about half of the remaining half of OHV routes when you exclude the nearly 200 miles of graded roads that are outside of the BLM’s jurisdiction. Grand County urged the BLM to consider closing far more than that so, this September, the BLM made its most restrictive alternative more severe by sparing just 495 miles of non-graded routes across the 300,000-acre planning area despite that it’s the primary destination for OHV recreation in southeast Utah.

Grand County’s Motorized Trails Committee dutifully explained how the new more-severe alternative would be completely unnecessary and disastrous for diverse recreation (see the last four pages), but the county commission unanimously voted to send the BLM a letter that supports the new more-severe alternative. Adding insult to injury, the letter claims that “Alternative B still heavily favors motorized recreation.” In 2023, hopefully the couple of incoming commissioners can broaden the perspective of the commission as a whole. Also hopefully the BLM will honestly incorporate comments from RwR and the TPA, that convey the value and integrity of almost all routes in the 2008 TMP. Our comments include a route-specific letter. They also include a wildlife report.

Participating in the Labyrinth Rims / Gemini Bridges TMP alone has cost RwR and the TPA tens of thousands of dollars, which positions us to effectively appeal if the BLM decides to close hundreds of more miles of route. However we’d prefer to defend a BLM decision that more conservatively refines the 2008 TMP so we can focus on the trail work, education, and enforcement efforts that actually achieve conservation.

Ashley National Forest Land Management Plan (LMP)

In national forests, the revision of Land Management Plans (LMPs) or “forest plans” strongly set the direction that TMPs will go. The Ashley is a rather large national forest that already has the High Uintas Wilderness area that occupies over a quarter-million acres of the Ashley, yet this national forest contains few rugged routes that are connected for OHV loops. Clearly the current LMP for the Ashley has made modest trail development difficult, yet the draft LMP would make it even more difficult in most ways, as RwR and other OHV groups explained in our joint comments. For example the draft alternatives would zone even fewer acres in a motorized classification of the Recreation Opportunity Spectrum, which is a prerequisite to even considering the development of a motorized trail on any of those acres for decades to come. RwR identified a half-dozen areas that would be zoned as motorized in only one of the draft alternatives despite that each area has historic motorized use and would be needed for connectivity, such as a motorized corridor between the High Uintas Wilderness and the Uintah and Ouray Reservation to allow any east-west travel by OHV. RwR found motorized zoning to be totally suitable when we visited these corridors with the guidance of local OHV advocates. These historic and potential connections are in fact part of the trails master plans that Uintah, Daggett, and Duchesne counties have spent years developing with USFS input, yet all of the draft alternatives would preemptively block the master plans. The agency’s next draft ought to leave a path open for them to consider such development in the coming decades.

Bears Ears National Monument Management Plan (MMP)

Currently the Bears Ears National Monument (BENM) occupies 1.36 million acres of BLM and USFS land including a couple-dozen ATV trails developed by the local ATV club SPEAR, national-forest singletracks like Vega Creek / Shay Mountain / Indian Creek, and Lockhart Basin 4WD road up to and including Chicken Corners. As you may recall from our previous Year In Review, the State of Utah is challenging the unilateral designation of this monument, and BlueRibbon Coalition has joined this effort. Hopefully it can persuade presidents to reserve their Antiquities Act authority for areas that can’t be protected by some other means, as such areas are few and far between in the modern era.

In the meantime, RwR is faithfully participating in the development of a Monument Management Plan (MMP) for Bears Ears. The existing plans, including an MMP for the smaller version of BENM developed from 2018 to 2020, are already quite restrictive. We would still be open to further restrictions so long as a compelling case is made for the change, but in fact no case was made, as the new draft MMP acknowledges no change. Instead it portrays several of these further restrictions as already being in place despite that the existing plans clearly state otherwise. How can the public evaluate proposed rules when the agencies misrepresent current rules? This falsification of the baseline feels fitting for this monument that, to many longtime stewards of the area, was proclaimed under the false pretense that monument status is necessary to protect antiquities. As with the San Rafael Desert TMP, it seems like the BENM staff would know better, but they’re following marching orders from political appointees.

Whatever the explanation, here are four examples of this erroneous baseline. In terms of the Recreation Opportunity Spectrum (ROS), currently 90% of the USFS acreage is zoned as motorized, yet the draft MMP claims that it’s only 50%, plus it claims that motorized use can take place only in motorized zones when in fact the current definitions allow for exceptions of motorized use in non-motorized zones. If uncorrected, routes like Shay Mountain Singletrack would be summarily closed before travel planning has even begun.

Second, the draft MMP incorrectly claims that motorized use is currently prohibited in Inventoried Roadless Areas (IRAs), despite that the majority of motorized singletrack in the Abajo Mountains is in IRAs. After all, the 2001 roadless rule intended only to prevent road construction, not motorized trail construction (let alone to close existing motorized trails). While the USFS is free to propose that motorized travel be prohibited in IRAs, it can’t pretend that such a prohibition is already in place.

Third, the draft plan makes an oxymoronic claim about BLM Lands with Wilderness Characteristics (LWC) that the plans currently in place had found to be unsuitable in terms of managing for those wilderness characteristics. (Areas that the current plans had found suitable to manage wilderness characteristics are called MWC.) The draft plan claims that currently such areas are “managed to minimize impacts on wilderness characteristics while still allowing discretionary uses.” Actually neither the BLM’s 2008 RMP nor the 2020 MMP direct the BLM to minimize impacts to wilderness characteristics in LWC areas, only in MWC areas.

Fourth, the draft MMP incorrectly portrays the BLM’s San Juan Recreation Management Zone area to be currently designated as OHV closed when in fact most of that area is designated as OHV limited. Designating that area as OHV closed would eliminate several dirt roads that access the river, precluding any discussion during the subsequent TMP review. We look forward to the BENM planners’ recognition of the current rules that are in place, and that these rules are generally adequate for the goals that were claimed by those who advocated for a monument in the first place. What’s lacking more than rules and plans are the resources and teamwork to implement them, particularly as the monument proclamations have diverted resources away from truly caretaking the Bears Ears toward battling the Antiquities Act.

RwR’s comments outlined these and other concerns with the draft MMP as well as our concerns with the proposal from the Bears Ears Inter-Tribal Coalition (BEITC) on behalf of the Bears Ears Commission. The BEITC is funded by wilderness-expansion groups, and its proposal for the MMP aligns with the policy pursuits of those groups. Those groups have also greatly influenced the majority of San Juan County commissioners in recent years. Next year will bring two new commissioners, providing even more ethnic diversity, with indigenous, Latina, and Anglo commissioners. We are optimistic that the commission will also be even more independent-minded when representing the interests of their county community. Although the divisiveness of monument proclamations may understandably linger, there’s potential for improvements independent of monument status, as most people support more recreational infrastructure, education, and enforcement. RwR’s efforts lay a foundation for such management despite the Antiquities Act’s amplification of the political pendulum in the administrative branch.


Progress on public lands has been inconsistent, and it’s far from certain, but it’s still worth pursuing in a principled manner. We appreciate the support that so many trail riders have entrusted in us, as RwR couldn’t do it without you. Happy Trails and Happy New Year.

Clif Koontz
Executive Director
Ride with Respect
395 McGill Avenue
Moab, Utah 84532
435-259-8334 land

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