Michelle Kerns, Superintendent
Glen Canyon National Recreation Area
P.O. Box 1507
Page, AZ 86040
RE: Glen Canyon National Recreation Area; Motor Vehicles (NPS-2024-0005-0001)
Dear Superintendent Kerns:
Please accept this correspondence from the above organizations as our official comments regarding the National Park Service (NPS) proposal to amend special regulations for the Glen Canyon National Recreation Area (the “recreation area”) to update rules about the use of motor vehicles on roads and off roads on designated routes and areas (the “proposed rules”).
1. Background of Our Organizations
In our comments, the “Organizations” will refer to the following four groups:
Colorado Off Road Enterprise (CORE) is a motorized action group based out of Buena Vista Colorado whose mission is to keep trails open for all users to enjoy. CORE achieves this through trail adoptions, trail maintenance projects, education, stewardship, outreach, and collaborative efforts.
The Colorado Off-Highway Vehicle Coalition (COHVCO) is a grassroots advocacy organization of approximately 2,500 members seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of off-highway motorized recreation throughout Colorado. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations.
Ride with Respect (RwR) was founded in 2002 to conserve shared-use trails and their surroundings. Since then, over 750 individuals have contributed money or volunteered time to the organization. On state and federal lands including the boundary with Arches National Park, RwR has educated visitors and performed over twenty-thousand hours of high-quality trail work on public lands.
The Trails Preservation Alliance (TPA) is an advocacy organization created to be a viable partner to public lands managers, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of motorized trail riding and multiple use recreation. The TPA acts as an advocate for the sport and takes necessary action to ensure that the USFS and BLM allocate a fair and equitable percentage of public lands to diverse multiple-use recreation opportunities.
2. Introduction
Since before the recreation area was established in 1972, it has been important for recreational travel by 4WD vehicles and off-highway vehicles (OHVs) from motorcycles to dune buggies, and its importance has grown as OHVs have become more popular and capable of covering greater distances.
3. Purpose of the Recreation Area
Congress established the recreation area in 1972 “to provide for the public outdoor recreation use and enjoyment of Lake Powell and lands adjacent thereto in the states of Arizona and Utah and to preserve the scenic, scientific, and historic features contributing to the public enjoyment of the area” (emphasis added). Congress clearly intended to meaningfully accommodate motorboats on Lake Powell and motor vehicles on land.
The proposed rules contradict this recreational purpose, and they would manage the recreation area like a national park, apparently to satisfy the demands of groups seeking to vastly expand the designation of wilderness and its proxies. The October 26th blog of the Southern Utah Wilderness Alliance (SUWA) states:
To be precise, it sits between Grand Staircase-Escalante National Monument to the west, Capitol Reef National Park to north, Canyonlands National Park to the northeast, and Bears Ears National Monument to the east.
Each of these surrounding areas are renowned for their stunning scenery, diverse flora and fauna, cultural sites, and outstanding recreation opportunities. They are also managed to protect these objects and qualities. Glen Canyon possesses very similar landscapes and values, and yet the National Park Service (NPS) has not always managed the Area in a manner similar to its neighbors.
The recreation area should be managed differently than the parks because it’s not a park.
4. History of OHV Use
The recreation area was open to cross-country OHV use until 2021. Then the NPS limited nearly all of the area to designated routes, which the Organizations support, but the resulting travel plan is extremely sparse. The 388 miles of designated routes, assuming an average route width of 20 feet, occupies 940 acres. When combined with the 450 acres of Lone Rock’s OHV open area, the drivable portion is 1190 acres of a 1,254,117-acre recreation area. In other words, the drivable portion is 0.0009% of the recreation area, which is less than 1% of 1% of 1% of the recreation area. Thus further restricting OHVs is simply unacceptable.
5. No Justification for Further Restrictions
The NPS has demonstrated no need for the proposed rules to prohibit OHV use of any designated routes. Given the infinitesimal footprint of the 388 miles of route, we see no significant adverse impacts, let alone impacts that could be minimized only by prohibiting OHV use.
In fact, the routes benefit not only motorized recreation, but also non-motorized recreation (as motorized routes are needed to reach most of the recreation by day-hiking or even by a weekend backpacking trip) and management (as active management requires visiting areas efficiently).
Further, for all kinds of recreation and management, OHVs are the most suitable way of traveling on rugged routes. They’re designed for this kind of terrain, so they’re more likely to negotiate an obstacle rather than bypassing it off-trail, and they’re less likely to get stuck or require search and rescue.
Where mitigation is needed, minimum-impact education and route maintenance (or reshaping or relocating routes) are quite effective. Every year, the Utah Division of Outdoor Recreation offers millions of dollars of OHV grants for this purpose.
6. No Analysis of Consequences to Recreation and Local Economies
The NPS has failed to take a hard look at the negative consequences of its proposed rules to recreation and the economy of nearby communities like Hanksville, Ticaboo, and Blanding. The rationale that prohibiting OHVs on 25 miles of routes leaves 94% of routes open is of no consolation because it would still reduce the carrying capacity of the route despite the exponential growth of OHV recreation. Further, the subject 25 miles includes many of the most important routes in the recreation area for connectivity and for their own recreational value. Whether for a short jaunt from one’s campsite, or for a multi-day overlanding type of trip, these routes provide memories that last a lifetime. They enrich the lives of visitors, and they diversify the economies of surrounding towns, as motorized recreationists tend to spend even more than non-motorized recreationists per day.
7. Connectivity to surrounding BLM Lands.
The subject 25 miles of route provide critical access to the surrounding BLM lands. The recreation area extends 135 miles northeast to southwest, and extends 80 miles southeast to northwest, so it needs to accommodate through-traffic. For example, Big Ridge, Upper Flint Trail, and Sunset Pass (to North Hatch Point as part of the Poison Spring Loop) are spectacular routes that provide the only north-south travel for OHV opportunities that are primarily on BLM land.
The route up Cove Canyon provides the only access to the BLM route GABD0499, which is open in all four alternatives of the BLM’s draft Henry Mountains/Fremont Gorge Travel Management Plan, thus the BLM has no intention of closing it in the coming years.
The road to Johns Canyon accesses incredible terrain for all kinds of recreation on BLM land and in the recreation area all the way up to Slickhorn Canyon.
8. Value of the Routes Themselves
The subject 25 miles of route have great recreational value in their own right. Routes that don’t reach BLM land still lead to points of interest like views from Ticaboo Mesa, Muley Point, and Dry Mesa. Then there’s the recreational value along the way, providing the only means of access for those with limited mobility, even providing physical engagement for those with full mobility. OHV riding and driving can provide a sense of flow with the trail and connection to its surroundings, plus some degree of physical and mental challenge negotiating obstacles. Of course it also enables people to see more within their limited free time.
9. State and County Interests
The subject 25 miles of route existed prior to establishment of the recreation area, and some of them are even maintained to an improved standard by the counties and State of Utah (e.g. Big Ridge, Flint Trail, Sunset Pass, Ticaboo Mesa, and Johns Canyon). The R.S. 2477 bellwether case in Utah District Court recently favored Garfield and Kane counties, putting onus on federal land managers to refute R.S. 2477 claims rather than operating as if the claims are unaffected by closing more routes. The NPS would be wise to avoid closing such routes to what is arguably the most suitable and most popular class of vehicle, the OHV.
10. Conclusion
Some rules may be fine, such as quiet hours from 10pm to 6am at Lone Rock Beach, but prohibiting OHVs on the subject 25 miles of route is unwarranted and would harm the public interest. The Organizations urge you to maintain OHV access and engage us to assist your management of recreation across this inspiring area.
Sincerely,
Clif Koontz
Executive Director
Ride with Respect
Chad Hixon
Executive Director
Trails Preservation Alliance
Marcus Trusty
President/Founder
Colorado Off Road Enterprise
Scott Jones, Esq.
CSA Executive Director
COHVCO Authorized Representative