USFS rationale for seasonal closures on select single-track motorcycle routes on the Uncompahgre Plateau

To: Chad Hixon
Trails Preservation Alliance

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

RE: USFS rationale for seasonal closures on select single-track motorcycle routes on the Uncompahgre Plateau. 

28 January 2025

Question #1: Why are the following routes only open for motorcycles from July 1st through Labor Day each year when they are open to other uses, including horseback riding, mountain biking, hiking, and hunting?

Uncompahgre South side: Clear Creek (#516), Paradox (#126), Buck (#149), Red Canyon #118, and Powerline (#541).

Uncompahgre North side: Long Canyon (#621) and Beaver Dam (#627).

Short Answer:
The source of the short, July 1 to September 2 season for motorcycle travel on Clear Creek #516, Paradox #126, Buck #149, Red Canyon #118, Powerline #541, Long Canyon #621 and Beaver Dam #627, all date back to the Uncompahgre National Forest Travel Plan FEIS in 2000. (https://www.fs.usda.gov/project/gmug/?project=33457).

The rationale provided in the EIS for the closures before July 1st was to protect elk calving habitat. The rationale for the fall closures after September 1st was: 1) to provide “elk security areas” or 2) to “reduce user conflicts” among “vehicle supported hunter(s)” and “backcountry and hiker hunter(s)” during the fall hunting season.

Additionally, closing of some trails from September 1st to July 1st was intended to be a “mitigation measure” for having motorcycle routes in “Semi-Primitive Non-Motorized Areas” (SPNM). These areas are at least 2,500 acres in size. The USFS rationale was that although motorized (motorcycle) routes passed through these areas and were therefore inconsistent with SPNM designations, this inconsistency would be “mitigated” by only allowing two months of use: from July 1st to Labor Day. No rationale was provided as to why two months of use was selected. See Appendix 1 for a list of trails and their status.

Background information:
Seasonal elk calving habitat restrictions, before July 1st:
Although there are no data that show a cause and effect of motorcycle trail use and elk calf mortality, seasonal restrictions before July 1st are intended to prevent disturbance to elk during their typical calving period. This rationale is obviously not worth arguing against because of high country snow restricting access anyway.

Elk security areas during the fall hunting season:
The concept of providing “elk security areas” – as it was applied to excluding motorcycle use after September 1st from the above-listed trails that the 2000 EIS claimed pass though elk security areas – is based on a logical fallacy.  That is, elk were assumed to require “refuges” from motorcycle trail use but not from hunting, which causes the supposed need for a “refuge” in the first place. Meanwhile, foot, horseback, and bicycle use are allowed to continue on the same trails with no restrictions, along with off-trail elk and mule deer hunting. 

Elk security areas in the 2000 EIS were based on 1980’s-era studies of elk pellet counts at various distances to roads in areas where elk had been hunted. The pellet count results were subsequently incorporated into a simplistic “elk habitat capacity” model based on questionable assumptions. Not surprisingly, analyses showed that elk pellets tended to be found away from roads because hunters drive on roads to access areas to hunt and roads occupy cleared areas that elk tend to avoid in areas where they are hunted. While hunting is arguably necessary for managing wild populations, the USFS (and CPW) fail to acknowledge the well-established fact in the scientific literature that hunting results in the adverse conditioning of elk and mule deer to perceive humans as potential predators, and therefore adjust their behavior and habitat use to avoid them. That is why both elk and mule deer will seek out private land, including agricultural land, where they are not hunted and are also generally unconcerned with humans in national parks where hunting is not allowed. 

It was assumed, but there is no research to show, that the creation of elk security areas are necessary to maintain a sustainable elk population. On the Uncompahgre Plateau, CPW data show that elk numbers increased approximately threefold between 1980 and 2000, well before any elk security areas were created by the USFS. That alone is refutation of their supposed need. This is a critical flaw in the USFS’s rationale for the designation of these security areas and imposing trail restrictions based on them.

Two other critical flaws in the USFS’s rationale are: 1) the prioritization of elk over other species and 2) the prioritization of elk hunting over other recreational uses on the Uncompahgre Plateau where the 2024 Visitor Use Report for Grand Mesa, Uncompahgre and Gunnison National

<sup>1. It is important to remember that the studies cited in the 2000 EIS and 2024 GMUG Plan on the recreational disturbance of elk are inherently biased because the research was conducted only in populations of elk that have been hunted and none that are un-hunted. Or, the cited studies that were reviews of said research. Additionally, radio-collared elk in the cited studies had been captured, restrained and fitted with radio-collars by humans, typically without sedation. Thus, those elk had been conditioned to view humans as predators in two ways: from being captured and handled by humans, and from being hunted.
2. Elk security areas on the Uncompahgre Plateau were justified in the EIS based on what would now be considered to be a primitive, elk-only habitat capacity model (the HABCAP computer model). The HABCAP model was described on pages 3-112 to 3-116 of the EIS. It was based on three variables: 1) Road Density Index (RDI) which was based on miles of roads and guestimates as to the frequency of use rather than actual data, 2) Forage Value Index (FVI) and 3) Cover Value Index (CVI) which were based on visual estimates of vegetation type and cover (for FVI and CVI see page R4-6 of https://www.fs.usda.gov/fmsc/ftp/fvs/docs/gtr/NFS_Reg_Veg_Class.pdf). Aside from the questionable methodology, no causal link was ever established between HABCAP results and elk numbers, actual elk habitat utilization, or population size. The HABCAP analyses would be difficult for the USFS to defend today.</sup> 

Forests reported that hunters there represent less than 3% of the forest users and user-days. The USFS’s prioritization of elk is in conflict with CPW’s population data which shows that elk have been consistently increasing there for four and a half decades (See Figure E20-1 below from CPW’s Elk Herd Management Plans Colorado Parks and Wildlife Southwest Region, 2023). On the Uncompahgre, the elk population has increased four-fold since 1980, to a high (prehunt) number of 15,085 in 2022, with 9-18% of that population harvested annually by hunters. Clearly, this population is not threatened or declining. 

Contrary to CPW and hunter advocacy group claims that elk populations in Colorado are threatened by non-hunting recreation trail use, the fact is that the statewide elk population has

^{3. https://apps.fs.usda.gov/nvum/results/ReportCache/2019_A02004_Master_Report.pdf (See Table 13 on page 21.)}

consistently increased since 1980. According to CPW Director Jeff Davis, “the overall statewide post-hunt elk population is projected to be at a 20-year high in 2024.” The Uncompahgre and statewide elk population increases have occurred even with an average of 10% of the population annually harvested (killed off) by hunters along with the undocumented percentage that are wounded and subsequently die (CPW data for elk GMUs 61 and 62: 2019-2023). 
And finally, although the 2024 GMUG Revised Land Management Plan now uses the term “big game security areas” instead of “elk security areas” it is still clear that the USFS’s primary rationale for these is to increase elk hunting opportunities. Mule deer and other species are not mentioned in this rationale. The following excerpt is from the 2024 Plan:

Best available science documents a relationship between big game hunting opportunity and the emphasis in wildlife management areas on unfragmented habitat and big game security areas. As summarized in Canfield et al. (1999: 6.13): “Youmans (1992:7) has declared, ‘Emphasis on maintaining fall security areas and secure migration corridors is essential to meeting statewide demands for public hunting opportunity, maintaining a variety of recreational experiences and maintaining a diverse bull age structure.’ When security is inadequate, elk may become increasingly vulnerable to hunter harvest and, as Lonner and Cada (1982) pointed out, ‘A lengthy hunting season has little meaning if the majority of the harvest occurs in the first few days.’ Thus, poor security can lead to a decrease in hunter opportunity and the inability of managers to meet objectives for sex and age structure.” 

Big game security areas were not mapped in the 2024 Plan and they do not appear as a category on any of the current CPW high priority habitat maps. Big game security areas in the 2024 GMUG Plan are simply concepts of purported value to big game populations absent of any actual quantifiable population-level benefit to them, and no sound scientific basis for imposing fall seasonal restrictions on trail use based upon them. 

In contrast to elk, the mule deer population on the Uncompahgre Plateau has experienced a four-fold decline since 1980. There are numerous scientific papers that point to competitive exclusion of mule deer due to increasing elk densities, yet this issue has been ignored by the USFS in their 2000 EIS and 2024 Plan, and by CPW in their recent herd management plans. Lacking citation to any data to support their assertions, CPW attributes the mule deer decline to poor range conditions due to drought, competition with livestock, “other” wildlife, increasing recreation, and development/habitat loss. CPW does not acknowledge that as elk numbers increase, deer numbers will inevitably decline due to competition – more specifically, competitive exclusion, a phenomenon in which mule deer avoid areas where elk concentrate. Being excluded from high quality habitat, their nutritional intake suffers, as does fawn survival. Thus, CPW’s population objectives for these two species are mutually incompatible, yet CPW

<sup>4. https://cpw.widen.net/view/pdf/nklnwz8kgw/Item.10_Memo_2025-2029-Big_Game_Season_Structure.pdf?u=xyuvvu
5. https://www.fs.usda.gov/main/gmug/landmanagement/planning See Appendix 12 Footnotes Regarding Best Available Scientific Information, on page 11-2.
6. https://www.arcgis.com/apps/instant/basic/index.html?appid=d4ab1b022c7f473880d0aa5f18937d33
7. https://cpw.state.co.us/hunting/big-game/deer/conservation-and-management
https://cpw.widencollective.com/assets/share/asset/hi0bimjmhc</sup>

prefers to blame other land uses (on multiple-use USFS and BLM lands) for mule deer declines and poor-quality winter range for both species. We further note that the four-fold mule deer decline has continued despite restricting motorcycle use during the fall based on security areas since they were established in the 2000 EIS and ROD.

The objective of CPW’s herd management plans are to increase both elk and deer numbers on the Uncompahgre Plateau, however, this is planned without any data to show that the range’s carrying capacity can tolerate any additional increases.  Similarly, CPW provided no analysis of additional elk impacts to farmers already experiencing elk damage to hay fields and livestock forage, except to “continue to offer game damage and private-land-only licenses to increase landowner tolerance and keep hunting pressure on private lands to redistribute elk on to public lands.” And finally, CPW’s 2023 stated plan to “stabilize this [E-20 elk herd] near current population levels” is misleading. That is because the objective of the previous 2006 herd management plan set a range of 8,500 – 9,500 elk, whereas the 2023 plan increased that objective to 11,000 – 15,000 elk, a 23 to 36 percent increase.

Implications of Chronic Wasting Disease in elk and mule deer populations to the future of recreation on federal land in Colorado.
Within the foreseeable future, the spread of Chronic Wasting Disease (CWD) through elk and mule deer herds, and the increasing infection rates within populations, will result in population declines to both species, including those on the Uncompahgre Plateau. CWD is a 100% fatal neurological disease that is spread among cervid species (i.e. elk, mule deer, white tailed deer, and moose) and an infectious agent that persists in its infectivity in the environment for decades. High population density leads to increasing rates of infection, spread among populations and with spillover to other species, eventually leading to population declines. Mule deer are more susceptible than elk and subsequently decline at a faster rate. There is no cure, no vaccine and no known genetic resistance that will halt its spread. 

Although CPW’s 2018 Response Plan to CWD stated that it provides “recommendations to control CWD prevalence while managing towards population and sex ratio objectives” the Plan has not stopped or demonstrably slowed the spread of CWD across the state, nor decreased its incidence within herds. The spread of CWD and its increasing rates of infection in populations is shown in CPW’s annual reports on the disease (See figures below). For example, on the Uncompahgre Plateau in 2023, Chronic Wasting Disease (CWD) was found in 10-20% of mule deer, a dramatic 5 to 15% increase over the previous year. In that same year, CWD was found to be infecting Uncompahgre Plateau elk (GMU 61 and 62). Meanwhile, CPW’s recent (2023)

<sup>8. Edmunds DR, Kauffman MJ, Schumaker BA, Lindzey FG, Cook WE, Kreeger TJ, et al. (2016) Chronic Wasting Disease Drives Population Decline of White-Tailed Deer. PLoS ONE 11(8): e0161127. doi:10.1371/journal.pone.0161127
Proffitt, K.M., Grigg, J.L., Garrott, R.A., Hamlin, K.L., Cunninham, J., Gude, J.A. and Jourdonnais, C. (2010), Changes in Elk Resource Selection and Distributions Associated With a Late-Season Elk Hunt. The Journal of Wildlife Management, 74: 210-218. https://doi.org/10.2193/2008-593
Cook, J.D., and Cross, P.C., eds., 2025, Decision analysis in support of the National Elk Refuge bison and elk management plan: U.S. Geological Survey Scientific Investigations Report 2024–5119, 5 chap. (A–E), variously paged, https://doi.org/10.3133/sir20245119.
9. https://cpw.widen.net/s/d7b55k9dcm/colorado_chronic_wasting_disease_response_plan
10. https://cpw.widen.net/s/whmbls5dnf/biggame, page 21</sup>

elk and mule deer herd management plans for Southwestern Colorado have continued to call for increasing population sizes for both species, despite the fact that increasing the size and density of these populations will also result in increasing the rate and spread of CWD infections. Increasing the hunting harvest of male elk and mule deer can only slow the spread of CWD to a minor degree but slowing the spread of CWD is a competing interest with CPW’s herd management objectives to provide more hunter opportunities (and a steady revenue stream from the sale of elk and mule deer licenses). Thus, CWD continues to spread across Colorado.

CWD is significant to the future of recreational activities on USFS land for the following reasons: First, CPW exerts a strong influence on USFS (and BLM) land use policies and the large-scale seasonal restrictions for big game on USFS land of the Uncompahgre Plateau for security areas and winter habitat are proof of this. Second, CPW’s priority, as a state enterprise agency, has been to increase opportunities for its primary constituents, hunters and fishermen, and revenue from them. Hunting is the priority in CPW’s elk and mule deer herd management plans for Southwestern Colorado. Third, CPW has promoted a narrative in elk and mule deer herd management plans and other documents that motorized and unmotorized recreation on public lands, as currently managed, is a threat to big game populations that requires additional regulation. This narrative has been made by CPW in its herd management plans and by big game hunting organizations. Yet, CPW fails to provide any big game population data that shows recreation as the cause of any population decline in Colorado, nor do they provide a plausible cause and effect mechanism by which it could occur. If left unchallenged, CPW’s narrative and their influence on USFS land use policies regarding non-hunting recreation, will likely result in additional restrictions as mule deer and elk populations eventually decline due to CWD. 

CPW never suggests that managing elk at a lower population density could potentially help to stabilize the current mule deer population decline. 

User conflicts:
The 2024 GMUG Plan did not mention any conflicts between single track motorcycle trail use and other users.

The only specific user conflict discussed in the 2000 EIS was between hunters that use motorized trail access, versus hunters that do not (the later presumably preferring a more wilderness type hunting experience). However, no data or other confirmation of this “user conflict” was documented in the EIS. 

No mention was made of the overcrowding of hunters and increasing pressure on elk, particularly on the eastern side of the Uncompahgre Plateau (GMU 62) where in 2023 alone, 5,072 elk hunters hunted for a combined total of 32,381 hunter-days in the field. In comparison, that is nearly five times the number of elk hunters and six times the number of hunter days as on the west side of the Uncompahgre Plateau (1,114 hunters and 5,333 hunter-days), which is managed as a “quality hunt” area, with fewer hunters and a higher annual harvest of elk. Even more hunters and hunter-days were reported in the early 2000s. These statistics underscore the

<sup>11. https://cpw.state.co.us/hunting/big-game/deer/conservation-and-management
12. Cooley, C. P., A. Holland, M. Cowardin, M. Flenner, T. Balzer, J. Stiver, E. Slezak, B. Marette, D. Neumann, T. Elm and J. Holst. 2020. Status Report: Big Game Winter Range and Migration Corridors. Colorado Parks and Wildlife.
13. The following excerpts are from CPWs 2023 elk and 2024 herd management plans. “CPW regularly communicates with land management agencies such as the USFS and BLM, landowners, county governments, CDOT, and NGOs and will continue to collaborate with these government agencies and organizations to achieve management goals. These agencies can help with large-scale habitat management projects to improve carrying capacity and regulate recreation and grazing on public lands, which could bolster elk populations on public lands.” (CPW 2023, page 73). The exact wording appears in the herd management plan for mule deer except for the last sentence which reads, “…, which could bolster struggling deer populations such as D-19.” (CPW 2024, pages 29 and 95). 
14. https://www.trcp.org/2022/09/27/40-important-colorado-elk-habitat-affected-trail-use/</sup>

fact that hunting pressure, rather than light motorcycle use, is the driver of elk behavior and habitat use during the fall hunting season on the Uncompahgre Plateau, including the displacement of elk and mule deer onto private lands that hunters cannot access. And finally, since publication of the 2000 EIS it has become increasingly apparent that CPW’s sale of over-the-counter elk tags sold to residents and non-residents has contributed to issues with hunter-overcrowding and loss of resident hunting opportunities. 

The entire basis of the USFS’s wildlife habitat protection scheme in the 2000 EIS, only involved elk. The reasons for this is three-fold: elk are desirable species for hunters, CPW has obtained a substantial portion of its revenue from the sale of elk hunting licenses, and CPW has traditionally exerted a strong influence on USFS land use decisions. CPW’s revenue from elk licenses, especially the higher-priced non-resident elk licenses, has been one of the single most important revenue streams for CPW. For example, the price of a 2024 nonresident elk license was $803.39, whereas the resident elk license cost $66.12, ta 12-fold difference in price. Although final number sold is not yet published, the total number of licenses allocated for 2024 was 107,700, not including private land tags, with 75% of licenses going to resident and 25% to non-resident hunters. The resulting revenue was at least $27 million. Larger number of elk hunting licenses have been sold in the past with a higher proportion of those licenses going to non-residents (up to 35%) and 210,000 rifle licenses sold. Clearly, CPW has had a longstanding financial incentive to increase the elk population, promote hunting, and derive its substantial annual funding stream from license sales.

Question #2: On what basis could the season restrictions potentially be lifted?

Answer: 

Elk security areas
The seasonal restrictions for spring calving, although questionable, may not be worth the fight. However, the rationales provided for some of the fall restrictions originally based on elk security areas (now renamed big game security areas in the 2024 GMUG Plan) could be challenged. Those are not based upon any data that show motorcycles traveling along established trails during the fall would have a negative demographic effect on the elk population, especially given that 10% of the Uncompahgre population is killed by hunters annually (Range: 9 to 18 percent) and despite that level of take, the population is still increasing.

^{15. https://publiclandjurisdiction.com/cpw-votes-to-choke-out-resident-hunters/ 
https://eastmans.com/colorado-no-more-over-the-counter-elk-tags/
https://www.gohunt.com/browse/tips-and-tricks/colorado-2025-2029-new-hunting-season-dates-and-other-big-chages-how-will-they-impact-you
https://www.backcountryhunters.org/colorado_bha_tag_allocation_observations_information}

^{16. In a May 31, 2024, memo to the Parks and Wildlife Commission, CPW Director Jeff Davis wrote: “In the early 2000s, total rifle license sales for elk peaked around 210,000 (67% resident; 33% nonresident). In 2023, total rifle license sales for elk have declined to about 126,000, or ~80,000 fewer licenses than in the early 2000s. This decline in license sales is not indicative of a declining elk population. In fact, the overall statewide post-hunt elk population is projected to be at a 20-year high in 2024.” https://cpw.widen.net/view/pdf/nklnwz8kgw/Item.10_Memo_2025-2029-Big_Game_Season_Structure.pdf?u=xyuvvu}

The 2000 EIS utilized a very simplistic and outdated modeling of “habitat capability” and “habitat effectiveness” for elk, and elk only. It was based upon rough estimates of vegetation type and cover, roads, and distance from motorized roads and trails. These results were then incorporated into a habitat capacity analysis (HABCAP), the results of which can be found in Appendix F. Simple line maps of analysis units and their ranking can be found based on the HABCAP results under each plan alternative (Beginning on page F-16, pdf page 451). It is difficult to tell which trails traverse each analysis unit due to the low resolution of the maps and there are no GIS files associated with the EIS (See Appendix 2 for a map of the Fall hunting season HABCAP results). The 2024 GMUG Land Management Plan does not mention this outdated analysis and presents no new analysis. In only mentions big game security areas as one of its guidelines for big game and forest wide direction. There are no specific fall restrictions listed for elk or mule deer. Winter habitat restrictions begin December 1st (see Table 7 (Big game timing restrictions for severe winter range, critical winter range, winter concentration areas, and migration corridors). Therefore, it appears that opening the Uncompahgre motorcycle trails of interest to Fall seasonal usage would not be in conflict with the Plan, if the rationale and analyses from the 2000 EIS can be overturned for being based on erroneous assumptions and analyses. 
Mitigation for trails in Semi-Primitive Non-Motorized Areas
Finally, the closing of some trails from September 1st to July 1st was intended to be a “mitigation measure” for having motorcycle routes in “Semi-Primitive Non-Motorized Areas” (SPNM). The USFS rationale was that although motorized (motorcycle) routes passed through these areas and were therefore inconsistent with SPNM designations, this inconsistency would be “mitigated” by only allowing two months of use: from July 1st to Labor Day. No rationale was provided as to why two months of use was selected. 

^{17. Big Game Species: Desired Conditions
FW-DC-SPEC-12: Habitat blocks of sufficient size and quality exist across the landscape to support wildlife populations. Travel routes provide necessary access while maintaining relatively undisturbed high-quality habitat blocks—greater than 0.62 mile (1,000 m) from open motorized system routes and 0.41 mile (660 m) from open non-motorized system routes—sufficient in size to provide necessary security areas for populations of big game and other species. Relatively undisturbed migration and movement corridors exist across the landscape that provide sufficient security and habitat quality to allow for relatively unabated movement of big game and other species. See also chapter 3, section Wildlife Management Areas – MA 3.2; the Forestwide desired conditions for ecosystem connectivity ECO-05 and for rangelands RNG-01; and the Forestwide objective for native species diversity SPEC-03. See also plan appendix 12 for supporting best available science.
Guidelines
FW-GDL-SPEC-15: To maintain desired distribution for big game, ecological conditions for big game species identified as a Species of Conservation Concern (SCC), and long-term population persistence for big game not identified as SCC, manage disturbance impacts to bighorn sheep, Rocky Mountain elk, mule deer, pronghorn antelope in production areas during their reproductive period (table 6), migration corridors when migratory movements occur, and severe and critical winter range and winter concentration areas during the winter (table 7). The areas described are delineated by Colorado Parks and Wildlife and are updated as data or conditions change; timing limitations could be applied to additional areas as identified in coordination with Colorado Parks and Wildlife. Permitted livestock grazing is not considered a displacing disturbance; impacts to wildlife habitat are managed through direction in the Rangelands, Forage, and Grazing sections, among others. For management of existing recreational use, see FW-GDL-REC-07 and GDL-REC-08 for adaptive management thresholds. [From Chapter 2, pages 43-44 of 2024 GMUG Revised Land Management Plan, https://www.fs.usda.gov/main/gmug/landmanagement/planning]}

 Appendix 1. Status of Uncompahgre motorcycle trails of interest.

Appendix 2. Habitat capacity results from Appendix F of 2000 EIS, for fall hunting season (PDF page 458). This questionable analysis was central to justifying fall seasonal restrictions on numerous travel routes on the Uncompahgre Plateau. The description of the analysis begins on page 3-112 of the EIS. As discussed on page 3-131, the increased motorized vehicle traffic during the fall hunting season is primarily due to the influx of hunters, which drives down the habitat capability index and increased presumed need to restrict motorized travel, including single track motorcycle trails. Thus, the USFS penalized non-hunting, recreation motorcycle use due to a presumed problem that its prioritization of hunting created in the first place. The term elk or big game security areas are misnomers because elk (and mule deer) are still hunted within them.

USFS rationale for seasonal closures on select single-track motorcycle routes on the Uncompahgre Plateau