Representative Garcia
200 East Colfax – RM 307
Denver CO 80203
Representative Bacon
200 East Colfax – RM 307
Denver CO 80203
Senator Weissman
200 East Colfax
Denver CO 80203
RE: HB25-1101 Disbursements to nongovernmental entities
Dear Senators and Representatives:
The above Organizations would like to express our concerns around HB25-1101. Prior to addressing our concerns with the Proposal, the Organizations believe a brief summary of our Organizations is warranted. The Colorado Off-Highway Vehicle Coalition (“COHVCO”) is a grassroots advocacy organization representing the OHV community 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 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 the necessary action to ensure that the USFS and BLM allocate a fair and equitable percentage of public lands access to diverse multiple-use trail recreational opportunities. Colorado Snowmobile Association (“CSA”) was founded in 1970 to unite winter motorized recreationists across the state to enjoy their passion. CSA has also become the voice of organized snowmobiling seeking to advance, promote and preserve the sport of snowmobiling through work with Federal and state land management agencies and local, state and federal legislators telling the truth about our sport. CORE is a motorized action group dedicated to keeping motorized trails open in Central Colorado and the region.
The Organizations have partnered with CPW in the creation and operation of two voluntary registration programs for snowmobiles and OHVs, each of which have provided a large number of grants to volunteer organizations, nonprofits, federal, state and local government partners for many decades. CSA partnered with CPW in 1972 to create the winter grooming program with the passage of 33-14-101 et seq. More information on this program is available here: Snowmobile Program Grants | Colorado Parks and Wildlife. The Summer motorized users formed a similar program with the passage of 33-14.5-101 et seq in 1988. More information on this program is available here: Off- Highway Vehicle Grants | Colorado Parks and Wildlife.
1. The Proposal could negatively impact existing provisions allowing grant fund advances up to 100%.
The Organizations first concern around the Proposal is advances are set at a minimum of 35% retainer, which is well below the amount traditionally provided in the Programs addressed above. Our non-profit partners have been allowed at least 50% advance on funds available through these grant programs as most of our clubs simply lack the funding to absorb costs to start efforts/projects. These grants fund a wide range of efforts and beneficial projects from volunteer days to clubs hiring contractors to perform desperately needed trail work and undertaking educational events. These user funded grant programs and the advances they provide to our nonprofit clubs and volunteers are critical to achieving these goals. If you would desire, we can provide several grant applications where the project is funding maintenance or contractor crews to undertake maintenance on federal public lands.
In certain circumstances, our nonprofit clubs can receive 100% of their grant award in advance of the projects as often the project is purchasing a piece of highly specialized trail equipment that can be used for summer or winter trail maintenance. The need for this advance is critical as clubs often lack the resources and ability to buy these units and having to take payments puts the clubs at a competitive disadvantage compared to other sellers. Sellers of these pieces of equipment simply are unwilling or unable to delay payments on these pieces of equipment as often these units are in high demand and can be easily sold to other buyers who have 100% of the cash needed for purchase available.
The Organizations are also concerned about the evolving nature of the federal land managers in these grant programs, as the programs hire hundreds of seasonal employees to work with US Forest Service and BLM offices across the state. These grant programs have been critical to providing high quality recreational opportunities on public lands for many years. The challenges surrounding hiring, filling, and retaining these positions through the federal managers are well publicized. If the federal land managers are unable to resolve these challenges, it is entirely possible that non-profit partner clubs will be seeking to hire seasonal employees to provide maintenance services. This situation is concerning for our partner clubs and we would like to provide those clubs the maximum amount of flexibility in funding if the clubs should move forward in providing crews and resources that the federal agencies are increasingly unable to do.
2. More paperwork would be required under the Program which would exacerbate a known limitations of our volunteers and partnerships.
The Organizations are also concerned that the Proposal would significantly expand, increase and complicate the amount of additional paperwork that would be required for any grants that are awarded. Much of the proposed required information and documentation is unrelated to the purpose and need of the grant programs and would result in significant burden on the volunteers that are often managing crews and projects under these grants. Administrative costs for all grants are already capped at 5% of the grant award and the organizations would be opposed to any increase in this cap as the users who fund the program an efficient and effective program that accomplishes on-the- ground projects and does not expand bureaucracy. The Organizations are also aware that CPW’s efforts to manage these programs is also at their capacity for administrative costs. Managing more information will simply result in additional costs for agency partners as well. The Organizations are aware that the largest concern raised by grant applicants is the volume of information that is already required to obtain funding. Current grant applications exceed 20 pages in length and must include specific, detailed information that must be provided as part of the application, such as bids for work, comprehensive cost estimates or specific information about a piece of equipment that might be purchased with the funds.
The Organizations have been working with CPW to perform a Six Sigma Lean process on the entire grant process to make the entire effort more effective on the ground and more efficient in its management process. We hope this effort will yield a grant program that is exceptionally efficient for partners to use for projects and minimizes the overhead necessary for any grant project. These funds are going to be more critically needed than ever before in the next several years, given the funding challenges facing federal land managers.
The Organizations and our partners remain committed to providing high quality recreational resources and opportunities on both state and federal public lands while protecting resources and would welcome discussions on how to further these goals and objectives with new tools and resources. If you have questions, please feel free to contact Scott Jones, Esq. (518-281-5810 / scott.jones46@yahoo.com) or Chad Hixon (719-221-8329/Chad@Coloradotpa.org)
Respectfully Submitted,
Scott Jones, Esq.
CSA Executive Director
COHVCO Authorized Representative
Chad Hixon
TPA Executive Director
Marcus Trusty
CORE President