Little Snake Field Office
Attention: South Sand Wash Open OHV Area Recreation Area Management Plan
455 Emerson St.
Craig, CO 81625
RE: South Sand Wash OHV Area RAMP
Dear Sirs:
Please accept this correspondence as the support of the Organizations for Alternative A of the Proposal. While we support Alternative A of the Proposal, the Organizations are concerned with some portions of the Proposal, which starts to alter the direction and intent of the SRMA as defined in the RMP. While the Organizations are concerned with a possible redefinition of the SRMA characteristics, the Organizations have also attached new research that we have undertaken that we hope will be valuable to planners moving forward with the recreational management in the area outlined in the Proposal.
Prior to addressing the specific concerns, the Organizations have regarding the Proposal, we believe a summary of each Organization is needed. The Colorado Off-Highway Vehicle Coalition (“COHVCO”) is a grassroots advocacy organization of approximately 250,000 registered OHV users in Colorado 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. The Trail Preservation Alliance (“TPA”) is a largely volunteer organization whose intention is to be a viable partner, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of trail riding. The TPA acts as an advocate of the sport and takes the necessary action to ensure that the USFS and BLM allocate to trail riding a fair and equitable percentage of access to public lands. CORE is an entirely volunteer nonprofit motorized action group out of Buena Vista Colorado. Our mission is to keep trails open for all users to enjoy. For purposes of these comments TPA, CORE and COHVCO will be referred to as “the Organizations.”
1. The Organizations support the provided level of analysis for the Proposal.
The Organizations were somewhat surprised to see several questions in the Proposal regarding the sufficiency of an EA to support the Proposal for NEPA purposes. Given that the Proposal is addressing an existing SRMA designation in the newly updated Field Office RMP and is analyzing changes on less than 200 acres of lands, the use of an EA would be highly cautious level of NEPA analysis. Much of the goals and objectives outlined in the Proposal could be undertaken with the use of a Categorical Exclusion or Categorical Exclusion with a file if an aggressive posture was taken on NEPA interpretation and compliance. We support the use of an EA to avoid any future assertion that the management decisions in the planning area was not undertaken and reviewed in a strategic and thoughtful manner.
While the Proposal seeks input on issues such as wild horses and possible amendment of the exiting RMP to alter the characteristics of the SRMA, these are factors that are outside the purpose and need of the Proposal. If the decision would be made to amend the existing RMP to address these issues, then the existing level of analysis would be insufficient. The Organizations would oppose the revision of the RMP in this manner as the RAMP plan is basically seeking to implement the RMP that was recently completed.
2. Scope of Proposal should not alter the SRMA characteristics and values.
In several locations the Proposal approaches discussions about possible reallocation of values in the SRMA, and this is concerning for the Organizations as the SRMA is one of the few targeted areas for motorized usage in the RMP or the western portions of Colorado more generally. These characteristics are highly valuable to the motorized community. The characteristics of SRMA are clearly defined in the following provisions in the RMP:
“South Sand Wash (35,510 acres) will be managed as a SRMA to provide OHV experiences in the Yampa Valley. Management of the SRMA is summarized in the table below, with additional management direction following (Map 17).
Management Applicable to Both Zones
Marketing will be coordinated with local OHV groups, commercial motorized vehicle suppliers, BLM community partners, and Moffat County to provide maps, brochures, interpretation opportunities, and road/trail planning and development. The area will be available for mineral location, oil and gas leasing, and nonenergy leasables. ROWs will be determined on a case-by-case basis.
Zone 1 Management
Zone 1 is the open play area. The niche will be community, where Yampa Valley residents depend on public lands primarily for OHV recreation. Objectives will include off-road motorized vehicle recreational experiences.
Experiences will include enjoying risk-taking adventure, enjoying the closeness of family, and developing riding skills and abilities. Benefits will include an enhanced sense of personal freedom, a restoration of mind from unwanted stress, a greater sense of adventure, improved maintenance of physical facilities, and positive contributions to the local economy. The physical, social, and administrative prescribed setting character will be rural. The area will be on or near improved country roads and a highway. Group sizes will range from 26 to 50 people and people would seem to be everywhere. There is conspicuous and large-scale landscape alteration from OHV use. Area maps and brochures, and occasional regulatory signing will be present. Enforcement and staff presence will be routine. Under the activity-planning framework for management, a comprehensive management plan will be developed. Management will be geared towards providing family-oriented and skill developing activities for visitors to the area. Main access roads and trails through the area will be identified and signed. Monitoring will determine if or when open recreation use approaches or exceeds resource capacity. OHV use will be open. Developed recreation sites will be closed to all mineral actions. The area will have a Class IV VRM designation.
Zone 2 Management
Zone 2 is the designated roads and trails area. The niche will be community, where Yampa Valley residents depend on public lands primarily for OHV recreation. Objectives will include single-track and double-track OHV riding, from novice to expert levels. Experiences will include enjoying risk-taking adventure and new challenges and temporarily escaping from everyday responsibilities. Benefits will include greater retention of desired recreational experience; a reduction in the negative impacts from such things as litter, trampling of vegetation, and unplanned trails; positive contributions to the local economy; and an enhanced sense of personal freedom. The physical, social, and administrative prescribed setting character will be middle to front country. Recreation will be on or near improved country roads and contact with people will be eminent, but still intermittent. There will be from 7 to 29 encounters expected a day during peak season and users may be unnerved but may not necessarily move off routes, areas, or sites to accommodate others. Area maps and brochures, occasional regulatory signing, and a designated marked trail system will be present. Four-wheel drives, all-terrain vehicles, dirt bikes and some two-wheel drive vehicles will be predominant. Enforcement and staff presence will be routine. Under the activity planning framework for management, a comprehensive management plan will be developed. Management will be geared towards enhancing OHV trail riding activities for visitors to the area. Together with user groups and local government, there will be a system of designated trails identified and signed to accommodate a wide range of vehicle types and riding levels. Crucial winter range and other seasonally limited wildlife habitat areas will be closed to surface disturbing activities. Monitoring will ensure that user experiences and expectations are being met and that resources are being protected. The area will be available for mineral location, but it will not be available for coal leasing. OHV use will be limited to designated roads and trails. The area will have a Class III VRM designation.”[1]
The Organizations would note that the concerning provisions of the Proposal about realigning the values of the SRMA to align with larger goals of the entire RMP would include:
“Goal A – Provide a diversity of outdoor recreational opportunities, activities, and experiences for various user groups, unorganized visitors, and affected communities, which will impact their residences, economies, and the environment. Objectives for achieving this goal include:
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- Increase managed motorized and non-motorized use trails;
- Focus the development of non-motorized and non-mechanized trails in backcountry areas or where public demand warrants;
- Provide legal public access opportunities for recreational uses;
Manage for special recreation permit (SRP) services;
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- Identify strategies and decisions that may be applied to protect or preserve primitive and semi-primitive areas that provide solitude and backcountry opportunities; and
- Manage motorized recreation to reduce impacts on big game hunt quality and harvest success on BLM-administered lands.”[2]
The Organizations are concerned that if these values of the general Field Office planning effort were applied without recognition of the values identified for protection and expansion in the SRMA, this would undermine the value of the RMP as many of these general planning values of the RMP are achieved outside the SRMA planning area. It should be noted that the SRMA area encompasses only 35,000 acres on a Field Office that covers more than 1.3 million acres. By focusing recreational activities in smaller areas of the FO, other values can be improved throughout the planning area.
The Organizations remain open to multiple uses of any public lands for all forms of recreation regardless of the particular SRMA designation as the SRMA designation elevates particular values in these areas but the SMRA at issue also does not exclude any recreational uses. The Organizations would be highly concerned if the Proposal sought to realign the SRMA values in a manner that created exclusive use areas for values that are not protected in the SRMA. This would be a significant alteration of the RMP and we submit outside the scope of the RAMP plan. We would also note that since the 2011 RMP, the mountain bike community has seen extensive expansion of opportunities on the Emerald Mountain SRMA. There has been no expansion of motorized usage in the Emerald Mountain area. While the Emerald Mountain area is not immediately adjacent to Craig, this is a short bus ride away and easily available for users of the planning area. Any asserted imbalance in access to desired opportunities is equally relevant as the motorized community in and around Steamboat often is coming to the South Sand Wash area to ride.
When the value of the South Sand Wash open area is addressed at the state level, the value of motorized opportunities in this area only expands. Only 8% of all trails in the State of Colorado are open to motorized single track.[3] We are aware that often this imbalance is not recognized when more localized planning in undertaken. As the Organizations noted in their scoping comments, open motorized riding areas, such as South sand Wash are almost unheard of in Colorado, making motorized access to the area highly valuable currently and of growing value into the future. As noted in the survey of motorized desired opportunities submitted as Exhibit B of these comments, many opportunities being sought, such as a designated trials riding area or OHV rock crawling area cannot be supported in any area outside an open area. This only increases the value of the existing SRMA designations and values being protected in the RMP.
3. Support for development of trail head facilities and recreational infrastructure.
The Proposal seeks to address trailhead type facilities and allows the development of fee sites at some point in the future at these locations. While the Organizations are often concerned about fees being charged for areas with minimal infrastructure, increased trailhead infrastructure and types of infrastructure developments have been a growing question for the motorized community. Lower-level trailhead improvements are intended to be supported by the good management crews provided to the FO in partnership with the CPW OHV grants but our users are often willing to pay more for more services as well. In order to understand how these requests could be addressed, COHVCO undertook a survey of the motorized community to develop a more complete understanding of the opportunity and needs and possible support for various aspects associated with the development of these resources. As a result of these generalized types of questions from various managers about what the motorized community would be willing to pay for particular levels of services, COHVCO undertook a survey of the motorized community as part of the 2023 update of the Economic Contribution study that has been a strategic resource developed with USFS, BLM CPW and funded with an OHV grant. A copy of this newly released 2023 Economic Contribution Study is attached as Exhibit “A” to these comments.
Since the 2016 Economic Contribution study was completed, one of the most common questions and issues we have faced is understanding the recreational services the public was willing to pay additional monies to support, such as maintained parking areas, designated camping infrastructure with limited improvements or fully developed camping opportunities with hook ups and showers and other heightened levels of support facilities. These questions expand beyond general recreational infrastructure to include targeted recreational opportunities that are inconsistent with a designated trail network area, such as a rock crawling or trials motorcycle area or a tot/training area.
COHVCO was able to obtain responses from approximately 2700 motorized users as part of the economic contribution study update around questions and topics such as this. Many similar questions and concerns area raised in the Proposal in its planning for the future of the area. The Organizations have also provided a complete copy of the full survey results as we believe these results will be highly valuable for the Proposal, given the overlap of many of the questions and issues being addressed. This full report of the survey is attached as Exhibit “B”. the Organizations would welcome further refinement of these types of questions as the planning for the area moves forward.
4. Wild Horses
The Organizations had the opportunity to review the comments provided in the preliminary scoping for the effort. It did not surprise us that wild horses appear to again be a major concern raised in the comments. This issue appears in almost any planning effort that BLM undertakes throughout the Western United States. We cannot overlook the almost consistent identification of by many comments made by the public that the planning area should prioritize wild horse management. This is at best a horrible over simplification of the challenges BLM is facing with Wild Horse management as removing the SRMA designation would not alter the challenges that have faced wild horses and burros throughout the western US. 10% of the SRMA is also identified as a wild horse area and this is the area that is designated as existing routes only for recreational usage.
The Organizations would also vigorously assert that the planning area is one of the shrinking number of locations that wild horses can be viewed easily by the public in a nature habitat area. The access to the planning area provided by the existing trails and recreational infrastructure is a critical part of this unique recreational experience. This ability is an important tool for the management of wild horses given the ability to interact in this way builds public awareness of the issues facing wild horses and would exemplify how recreation and conservation are aligned in achieving important goals on this issue.
5. Conclusions
Please accept this correspondence as the support of the Organizations for Alternative A of the Proposal. While we support Alternative A of the Proposal, the Organizations are concerned with some portions of the Proposal, which starts to alter the direction and intent of the SRMA as defined in the RMP. While the Organizations are concerned with a possible redefinition of the SRMA characteristics, the Organizations have also attached new research that we have undertaken that we hope will be valuable to planners moving forward with the Proposal.
Please feel free to contact Scott Jones, Esq. at 518-281-5810 or via email at scott.jones46@yahoo.com or Chad Hixon at 719-221-8329 or via email at chad@coloradotpa.org if you should wish to discuss these matters further.
Sincerely,
Scott Jones, Esq.
Authorized Representative
Colorado Off-Highway Vehicle Coalition
Chad Hixon
Executive Director
Trails Preservation Alliance
Marcus Trusty
President
CORE
[1] See, Little Snake FO RMP at pg. 48
[2] See, Proposal at pg. 3.
[3] Colorado Off-Highway Trail Opportunity Plan (COTOP) | Trails Preservation Alliance