October | 2025 | Trails Preservation Alliance

Labyrinth Rims/Gemini Bridges Travel Management Plan

October 23, 2025 in News

October 23rd, 2025

Bureau of Land Management
Moab Field Office
82 E Dogwood Ave
Moab, UT 84532

Re: Labyrinth Rims/Gemini Bridges Travel Management Plan EA #DOI-BLM-UT-Y010-2020-0097-EA

Dear BLM Planning Team:

Please accept this correspondence from the above organizations as our official comments regarding the BLM’s reassessment of its Travel Management Plan (TMP) in the Labyrinth Rims/Gemini Bridges planning area.

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. RwR has educated visitors and performed over twenty-thousand hours of high-quality trail work on public lands including several-thousand hours in the planning area such as rerouting over a dozen trails away from sensitive resources through travel-plan amendments of the 2008 RMP.

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

The Organizations applaud the BLM for reassessing the motorized routes closed or limited in its Labyrinth Rims/Gemini Bridges planning area. Many of these routes have been quite beneficial for Off-Highway Vehicle (OHV) riding and other forms of recreation without significant adverse effects thanks to basic trail maintenance efforts, and more could be done. Reopening them would establish a more manageable trail system that provides an adequate quantity, quality, and variety of routes including iconic trails from the Dead Cow motorized singletrack to the Mashed Potatoes section of the 3-D 4WD trail.

3. Exhibits

The Organizations generally support the comments of the Motorized Trails Committee of Grand County, Utah (MTC), which we have enclosed as exhibits 1-4 and incorporated into these comments to be analyzed by the BLM, not merely as a reference document. The MTC comments highlight a minority of the closed or limited routes as high priority, which should be reopened along with routes most important to the State of Utah as RS2477 rights of way. The high-priority routes and comments on each route are based on decades of experience assisting the BLM’s management, not only by our organizations, but other local groups including the Moab Friends For Wheelin’ and Red Rock 4-Wheelers.

The Organizations also submit a plant and wildlife report, which is attached as Exhibit 5, that provides a clear rationale to reopen many routes. When commissioning the report, we asked the wildlife biologist to focus on a half-dozen routes that have great recreational value along with wildlife concerns, and we hope that the report is useful when reassessing other routes in the planning area.

Finally the Organizations resubmit our Labyrinth Rims/Gemini Bridges TMP comments from October 21st, 2022, which we have enclosed as Exhibit 6, since most of them apply to this reassessment (such as Section 21 on pages 68 and 69 in which an Emery County commissioner who was instrumental in the Dingell Act recounts the legislation’s provisions against buffering wilderness or managing Scenic river designations as if they were Wild).

The Organizations may individually submit additional comments on this reassessment. Given the 30-day comment period, we do not have time to submit additional information such as the hundreds of photographs that we have showing the majority of routes identified by the MTC as high priority, but we would be happy to provide it upon request.

4. Conclusion

In the wake of sweeping closures across Labyrinth Rims/Gemini Bridge, The Organizations commend the BLM for further investigating the routes and input of recreationists who have enjoyed them for generations. From the river to the rims, the sustainable solution for most of these routes is to restore access, fostering stewardship of the routes and the landscape alike.

Sincerely,