Author Archive | Administrator

March 31, 2015

Colorado Parks & Wildlife
Att: Director Broscheid
1313 Sherman Street, 6th Floor
Denver, CO 80203
via email @ dnr_cpw_planning@state.co.us

RE: CPW Strategic Plan Revision

Dear Director Broscheid;

Please accept this correspondence as the comments of the above Organizations with regard to the development of the combined strategic plan for Colorado Parks and Wildlife. The Organizations welcome this opportunity to provide written comment on the new strategic plan as often discussions that have occurred in the public hearings throughout the state are rapid in nature and often these settings make it difficult to fully analyze issues and challenges discussed in the meetings. The Organizations have welcomed the frank and candid discussions that the series of public meetings have allowed the public to have with CPW employees and managers. While there are many aspects to be addressed in the CPW Strategic Plan, the Organizations believe the Path Forward document did a reasonable job in summarizing these issues and that this analysis remains relevant moving forward. The Organizations comments will center on the critical need to maintain current programs at their historically high levels of performance in order to avoid significant damages to volunteer partnerships that have taken years to develop in association with the program. Often these volunteer partnerships are valued well in excess of the monetary disbursements of the program. The Organizations believe that failing to maintain services at historically high levels will impair any efforts to achieve financial sustainability of the merged agency.

The Organizations are aware that the CPW trails committee and CPW staff have taken a far more active role in addressing and resolving many of the concerns that are raised in these comments. These issues have been very slowly increasing over the last several years and recently have rapidly deteriorated for many reasons. The Organizations believe that the scale of problems and the speed they have impacted the program have taken all interested parties by surprise. The Organizations believe these issues may be present in many other aspects of the program and are important enough to warrant commentary in order to allow planners to address other programs that might be similarly situated.

Prior to addressing the specific concerns on the Strategic Plan, a brief history of the Organizations will help given structure to the concerns raised in these comments. Colorado Snowmobile Association (“CSA”) was founded in 1970 to unite winter motorized recreationists across the state to enjoy their passion. CSA currently has 2,500 members representing the 30,000 registered snowmobile users in the State of Colorado. CSA has become the voice of organized snowmobiling seeking to advance, promote and preserve the sport of snowmobiling by working with Federal and state land management agencies and local, state and federal legislators.

The Colorado Off-Highway Vehicle Coalition (“COHVCO”) is a grassroots advocacy organization of representing the 150,000 registered OHV user in the State of Colorado. COHVCO seeks 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 100 percent 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 insure that the USFS and BLM allocate to trail riding a fair and equitable percentage of access to public lands. TPA is very concerned with the fee proposal increase as TPA believes that any fee for a motorized usage area will have a significant precedential nature in terms of fees that may be developed for other areas in the future.

While the Organizations are most directly concerned with multiple use access to public lands, a large percentage of our members are very active in the hunting, fishing and camping communities within Colorado. CSA, COHVCO and TPA will be collectively referred to as the Organizations for purposes of these comments.

1. Overview
The merger of Colorado Parks and Colorado Division of Wildlife has been a major change for the recreational community in Colorado as these were two very different organizations and missions that played a vital role in Colorado recreational opportunities both on State and Federal lands. While these are very different organizations and missions, there is overlap of efforts and concerns of what has been the traditional user groups as many of the trails based users groups are actively involved in the hunting and fishing activity base. For many of these users they are simply unable to identify themselves as a hunter or fisher or a trails user. Trails usage is simply woven into their outdoor recreational experience. Another area of overlap between these user groups is that both the hunting and fishing community and the trail based community have embraced the user pay model for maintaining and improving their recreational experience.

The Trails Program has historically bridged gaps between the programs as the trails network is a critical component of the outdoor recreational cultural that has been so strong in Colorado as trails are a critical component of almost all types of backcountry recreation. CPW’s recently completed State Comprehensive Outdoor Recreation Plan (SCORP) documented through a public opinion poll that trails based recreational activities are the most popular outdoor recreational activities on Colorado, totaling 250,000,000 activity days per year by Coloradans alone. That is 20 times more activity days per year than any other outdoor recreational activity addressed in that poll including fishing and hunting, yet CPW’s offerings through the trail grant program, through its trails web site and outreach programs is extremely weak compared to the support CPW devotes to hunting and wildlife issues.

The Organizations are aware that the legislation governing the merger of Colorado Parks and Colorado Wildlife provided significant guidance and structure for the merger of the two agencies moving forward. The Organizations believe the statutory mandate governing this process is highly relevant to our concerns, as the mandate provides as follows:

“(11) (a) In addition to discharging its regular duties and functions, the commission shall specifically discuss and formulate a five-year strategic plan to address ongoing or new issues resulting after, and identify increased efficiencies and cost savings that may be realized from, the 2011 merger of the former division of wildlife and the former division of parks and outdoor recreation into the division of parks and wildlife. The strategic plan must address how the merger has affected policies, objectives, strategies, and estimated annual fiscal costs and savings associated with the duties and programs of the division.”¹

Representatives of the Organizations were able to attend almost all of the public meetings in 2011 regarding the merger of Parks and Wildlife and have again been actively participating in the meetings and public process supporting the new strategic plan development.

In 2011 the merger of then DOW and Parks was very concerning to a wide range of users and as a result numerous assertions to the effect that avoiding erosion of the effectiveness of CPW would be high priorities in the merger were made by then Director Rick Cables and DNR Director Mike King. The Organizations were also actively involved in interim processes with CPW, such as the Partners in the Outdoors meetings and committees, in attempts to make sure that CPW continued to provide high quality services and build volunteer partnerships. The issues in these comments are concerns that have been held by the trails users throughout the process and directly impact the policy, objectives, strategies and savings achieved through the merger.

The Organizations are intimately familiar with the national recognition that the CPW trails program has consistently been the recipient of and that the fact that the CPW program is the envy of almost every other trails program and that this program plays an integral part in the management of federal lands in Colorado, where the bulk of Colorado recreational opportunities are provided. The distinguished nature of this program is not abnormal within CPW, as CPW has consistently been a nationally recognized leader in a wide range of issues including Endangered Species Issues and research, which has recently been again affirmed with CPW taking a leading role in the Gunnison and Greater Sage Grouse listing process.

2a. The Organizations are concerned over the erosion of the CPW Trails Program.

The Organizations are concerned about the erosion of the effectiveness of the Trails Program to provide funding and resources necessary for the maintenance of trails in Colorado since the 2011 merger. It has been the Organizations experience that this erosion is the result of numerous factors impacting the program rather than a single particular change. The Organizations are concerned that while the scale of the grant program has more than doubled since its inception, staffing for the program has reduced significantly. Regional Trail Coordinators were once completely managed by the Trails Program but this important resources have been made joint reports under the new organizational structures. These FTE were often playing a critical role in making the grant program work and were often able to adjust their duties to make projects work. Since the merger, there has been no replacement for these FTE and these FTE are no longer in the Denver metro region to assist in the critical role of simply making projects work. While the Trails Coordinators provide a good example of staffing issues, these issue are by no means limited to these positions.

The Organizations are also aware that the funding streams from the trails program, the timing and simplicity of which has been exceptionally critical to the effectiveness of the program overall, have become very problematic. Too often this funding is very late, difficult to obtain and sometimes simply never reaching the projects that are the basis of the grant. Simply getting approval of budgets and contracts in place after these grants have been fully approved is difficult and slow. Often accountings of grants are submitted to auditors or contracts are sought to be formed and it is literally months before any review or feedback occurs from anyone outside the program. Often this horribly delayed feedback raises concerns that involve at best minutia or concerns completely unrelated to the project.

Too often staff outside the CPW trails program are completely unfamiliar with the CPW trails program or the levels of review that Trails Grants have been undertaken before any contracts are attempted to be drawn. The Organizations are aware that often Trails Program staff are completely unable to address basic issues in this contracting process, which makes the Organizations believe input from the program managers is simply not given the appropriate weight in the balancing of interests and issues.

2b. Impacts of erosion of trails program effectiveness are becoming evident in reductions in volunteer support for Trails Program.

Many of the issues raised in these comments were recently moved forward by State Trails Committee who is now actively working with CPW staff to resolve them as quickly as possible. We applaud the Trails Committee for immediately partnering to resolve these concerns and support their efforts in taking the forefront of issue but the Organizations are concerned that too often these issues are landscape level and could be impacting other programs in a similar manner, just not at levels that can be as easily identified. Resolution of these types of systemic inefficiencies are critical in achieving the goals of the merger and maintaining high quality services.

The Organizations have been heavily involved in the development and implementation of the CPW Trails Program since its creation in 1985. It has been the Organizations experience that the Trails Program has been successful due to the partnerships that are formed between users, state program representatives and federal land managers. While the State Trails program provides significant funding for trail building and maintenance, the monetary value of this funding has always been significantly less than the volunteer hours and matching funding that are brought to bear in the grant process. As a comparison, in 2012 the trails program awarded approximately $4.2 million in direct funding of projects to partners which was matched and leveraged against almost $28 million in volunteer labor contributions to achieving trail maintenance goals on the ground.

The Organizations are deeply troubled that numerous factors have contributed to the recent erosion of the CPW Trails grant program. The trails grant program started almost 30 years ago as a program with grants of about $1.5 million dollars per year coming from motorized users and volunteer efforts of the users were instrumental in getting the program passed into law and implemented on the ground. Today, this is a program that awards approximately $7-8 million dollars in grant funding to federal, state and local government agencies and non-profit partners. The overwhelming portion of money from this program is raised from the voluntary registration program that has been developed for the registration of OHVs and snowmobiles and the refund of federal gas tax monies through the Federal Recreational Trails Program. Many of these users who are the primary funding source for the program also partner with the program and volunteer significant time on the ground to make the program the success that it is. Over life of program it has become the national benchmark for what a trails program should be. Last year the Organizations had the privilege to award Tom Metsa NOHVCC Program administrator of the year award at the trails committee meeting in Salida. This year the CPW trails program was nominated as the program of the year by the Coalition of Recreational Trails.

While the funding provided by the program is critical in resolving many management issues, the volunteering and goodwill of the program has become much more valuable than any direct monetary grants. Research places a value of $28 million annually volunteered to support the program. The Organizations submit this is a low estimate and the true value of the volunteer efforts leveraging these grants is much higher. The Organizations assert with a high degree of confidence that while trails users are more than willing to volunteer for projects, they are not great at accurately tracking this support. Trails users volunteered for projects because the program works on the ground and effectively maintains the trails we are all so passionate about. These volunteers have consistently leveraged the “on the ground” impacts from the monetary grant funds awarded to produce projects that are consistently providing efforts valued at far more than just the amount of money granted by the program. This leveraging of grants appears to have been forgotten or overlooked in the recent desire to fully account for monetary funding awarded.

The winter grooming program performed in partnership with Colorado Snowmobile Association provides a great example of this leveraging of funds by volunteers. The program funds basic grooming activities and capital equipment purchases at 29 locations throughout state and this program often provides the sole means for the public to access federal lands in the winter, making this program an integral part of the Colorado backcountry winter recreational experience. Without volunteers the Organizations have to wonder if grooming could be provided at 10 of these locations with the money from the grant program. Volunteers drive groomers for thousands of miles a year often at night in poor weather conditions. When the groomers break it is the same volunteers that are often in the middle of no place laying in the snow fixing the broken equipment so it can continue grooming. These are jobs that would be difficult to fill under any circumstances but we have volunteers doing it because they believe in the program. Often these same volunteer raise significant additional funding for grooming operations to supplement money from the state program, which is never enough to maintain equipment and cover operational expenses. This type of support is critical to the grooming program as grooming equipment needs to be fixed an moving even if there is not money in the bank account to cover those costs. Volunteers simply go raise necessary funding.

Strength of the funding portion of the program was consistent funding in times of rapidly diminishing federal budgets. This funding was available in a timely manner relative to the projects. The program always had minimal administrative burdens to insure that funds actually went to trails and were not lost in administration of the program and flexibility was accorded program managers to work with volunteers. This flexibility was critical as many of the projects are highly time sensitive and weather dependent. This flexibility also made people want to support the projects and made the project such a success. These are exactly the areas were recent changes in administration have eroded these programmatic strengths.

Recent delays in funding and increasing administrative responsibilities associated with the program have had serious impacts on the program and the Organizations are concerned that the desire to track every penny in the program in a manner similar to the way the state would account for road building will have a massive negative impact on the program overall. When the snow flies the grooming equipment needs to move. When the snow melts the good management crews need to be out on the ground cutting trees off trails. Last year good management crews not funded at all and money for the purchase of new winter grooming equipment was not received by clubs until the grooming season was almost over. Over the several years previous, grant funding had slowly gotten later and later each year until for many it simply never came last year.

While a new standard or documentation requirement in the grant process may only take a few minutes to implement or require checking a box on form or budget, the Organizations are concerned that there has not been a review of the cumulative weight that years of new standards or requirements is having on the volunteers who make the program work on the ground. It has always been assumed the volunteers will simply make it work. The Organizations are concerned that the requirements for a grant are becoming so heavy and the process so slow that volunteers simply cannot make it work anymore. The Organizations are aware that fixing the negative impacts to volunteer support when a standard does not work or administrative burdens too high, may take years and result in far more damage to the volunteer support for the program than the benefit that ever could be achieved from the direct grant. While we are good at finding volunteers for fixing trails the volunteer support for completing a lot of paperwork after the project was completed has become increasingly difficult to raise. As a result of the lack of flexibility in the program volunteers have already started to walk away in frustration.

Currently, COHVCO has two grants being processed that have been impacted by many of these delays in funding getting on the ground or to the project. We simply passed on doing our annual COHVCO workshop two years ago due to delays in reimbursements for previous years events. The money was simply not there to bridge the gaps in the funding streams. We have concerns that if the funding issues for this year’s workshop are not quickly resolved we will not be able to have the event at all. It is tough to make plans for the event or organize volunteers if the event host cannot confirm the event is going to occur.

The COHVCO economic contribution grant has also run into many delays and hurdles, such as needing proof of motor vehicle insurance for a project that will be almost completely completed on line. We have also had to address questions from those above the trails program staff regarding if our grant was fair and reasonable for the state and resolve attempts to completely restructure the grant budget after it has been approved by the OHV subcommittee, this committee, the CPW commission and the Colorado Legislature as part of the long bill. The administrators above the trails staff seemed completely unaware that if we fulfilled their request by trails program regulation we would have to get approval of all the committees again. As a result we are still waiting for our first advance of funds. To further complicate the grant , we have recently learned that our contact person with our contractor has moved on to other employment. While the Organizations are sure we will resolve this issue, these are the types of burdens that fall to volunteers because of funding delays or additional grant requirements. These are the types of issues that must be resolved to make the grant work. Volunteers have historically been there to fill this role but again the Organizations are concerned that volunteers may not be there in the future.

The Organizations concerns about the erosion of the trails program effectiveness impacting volunteer support are not unfounded. Recent issues with the Rout Powder Riders (RPR) Snowmobile Club, which has provided winter grooming services under contract with the Hahns Peak Bears Ears Ranger District on one of the top ten snowmobile destinations in the western united states for more than 30 years provides a concrete example of these impacts. RPR won a grant to replace their aging grooming equipment in 2012 from the winter grooming grant program and vigorously moved forward with that grant to insure that new equipment could be in place to comply with contractual obligations. Unfortunately, RPR was not aware that funding from the CPW grant program would be later than it ever has been before and the club would not receive any money until the end of March despite contractual obligations and the grooming season starting in November of the prior year. While the clubs efforts were not perfect in many facets of the accounting process, these efforts were critical in insuring grooming would occur that year and saved the CPW program literally tens of thousands of dollars. Even with these savings the club was able to provide exactly the piece of equipment that was sought in the grant in a timely manner and insure that the equipment was going to be in place to benefit the public for many years to come. Despite these clear benefits and the long history of partnership between RPR and the CPW grooming program, no resolution could be achieved on these accounting issues and delays in grant funding, forcing the sale of the grooming equipment by RPR that they had just acquired and put thousands of dollars of repair costs into. The Organizations are aware that efforts for a perfect accounting of the RPR grant may have looked good on paper, these efforts have had catastrophic impacts on the volunteers with the club as often questions in the accounting were difficult and accusatory and RPR voted to cease being a grooming club next year. These types of situations simply must be avoided at all costs.

For the Organizations, there is a foundational question regarding the model for the CPW grant program moving forward. Do we want to continue with the volunteer program that has funding resources, which has proven to be hugely successful over the last three decades or do we want the grant program to become a small funding source with no volunteer support and a heavy administrative burden? The Organizations think we should stay with the program model that has a proven winning track record and has been nationally recognized as the model for how a program should run. The Organizations have to admit that the basis of this situation with the grant program is unclear. The Organizations can confirm that if we are given the opportunity to partner with CPW to fix the problems that have recently manifested impacts to continue the grant program in its current form, we will do so. We are asking that the opportunity to fix the existing program be provided and we need your help in that request and insure that protections are in place in the strategic planning process to insure that similar issues do not recur in the future in any part of CPW activities.

3. Conclusion.

The Organizations submit that the strategic planning process provides the opportunity for CPW to refocus programmatic resources to insure that the intent of the trails program is carried forward in compliance with statutory requirements of merger legislation. The Organizations also believe that refocusing resources will allow trails to be reflected as a critical component of all recreational activity in Colorado. While the Organizations are aware that some issues, such as changes in accounting systems, may not be related to the merger or strategic plans, the merger has not streamlined resolving these issues. The Organizations submit that identification of these types of systemic problems is critical is resolving them permanently. The Organizations vigorously assert that a refocusing of resources will insure that the recent erosion of the trails program effectiveness is rapidly counteracted and further negative impacts to the volunteer support is avoided. While the $7 million per year the CPW grant program provides in direct funding is important, the Organizations believe it is the $28 million in volunteer efforts that partner in the application of this funding to on the ground projects is more valuable to maintaining the high quality recreational opportunities and services to the public that has made the CPW trails program a model for trail programs nationwide.

Please feel free to contact Scott Jones, Esq at 518-281-5810 or via email at scott.jones46@yahoo.com or via USPS at 508 Ashford Drive, Longmont, Colorado 80504 for further discussions about these comments.

Sincerely,
Scott Jones, Esq.
COHVCO & TPA Authorized Representative
CSA Vice President

Jerry Abboud
COHVCO Executive Director

D.E. Riggle
Director of Operations
Trails Preservation Alliance

Randall Miller
President
Colorado Snowmobile Association

1 See, CRS §33-9-101(11)a

Colorado’s recreational trails are amongst the best in the world and their value has been acknowledged by Governor Hickenlooper in his State of the State address in 2015 when he referred to the importance of recreational trails systems. So what is missing from this focus on trails that can be greatly improved by a revision to current practices in the Trails Program by way of strategic planning?

CPW is the state agency responsible for trails, but it is clearly apparent that Wildlife has taken the lion’s share of time and effort while the old “Parks” is relegated to a poor player. Number one is to understand and address the fact that trails are a far bigger recreational activity in Colorado and generated at least as much money as hunting and angling. (See SCORRP Plan and the discussion of dollars toward the end of these comments)

All of Colorado’s trails programs support 250,000,000 activity days per year. The Trails Program suffers from lack of personnel and resources. It is subject to a draconian grant process that makes it all but impossible for non-profit grantees to meet the ridiculous accounting requirements, insurance, delayed payment and failing to provide enough grant money to even begin the projects! It was never the vision to take direct USER funded monies and then ask volunteers to meet requirements of a $500,000,000 highway construction project to obtain them. People are dropping out of the snowmobile and OHV programs because they simply cannot function under the current system.

We are at a point where it is not far from requiring bridge loans to complete projects, which of course is ridiculous and impossible. So where is CPW in this situation; absent without leave. The trails coordinators paid out of trails funds have been co-opted by Regional Wildlife managers. The trails program is 8th page news on the CPW website, it all appears to be about antlers and fish.

Much of Colorado’s finest motorized and non motorized trails are on federal government land….land the feds cannot maintain and if not for our Trails Program will be lost. How would the public know that, CPW apparently doesn’t. We have a leadership team in CPW and where is there a seat at the table for the Trails Program and I am not speaking of the Assistant Director of Parks who must juggle all recreational matters by himself? We have Wildlife members on the Team in numbers, yet not a single soul to represent as huge a recreational activity as trails…unconscionable.

We supported the merger and it appears to be a big mistake and worthy of a revisit by the General Assembly unless we have a Strategic Plan that seriously encompasses recreation, of which trails are a huge part. Please do not feel that because your initiated focus groups in the middle of the week that you are getting a crisp clear picture. The deck is stacked because most trail users do not have an idea in hell that CPW is the agency charged with trails and just how did we get to that point; because YOU have failed miserably to promote the greatest opportunities in Colorado because Wildlife runs the show. In short your trails promotion and education are the backwaters of state recreation.
Colorado’s motorized Trails Programs are recognized as among the best in the nation. Who knows? Not even our own citizens.

Allow me explain just one piece of the Trails Programs; the OHV program and ask yourself did you even know this?

CPW’s Motorized Trails Program

A user fee system for the purchase of OHV registrations and use permits was instituted in 1990. Over the past twenty-five years collections for the Off-highway Vehicle (OHV) Recreation Fund has grown to $4.5 million per year. The benefits generated from this funding are many:

• User generated fees directly support OHV riding opportunities in Colorado.
• User generated fees directly support many volunteer and non-profit organizations devoted to OHV trail maintenance and education programs.
• The fund has been used to plan and accelerate the adoption of motor vehicle use maps and trail systems for federal lands throughout Colorado, this process would not have been completed as quickly without this funding.
• OHV funding is essentially the principal trails funding mechanism for the BLM’s trails program in Colorado.
• OHV funding provided to the US Forest Service allows that agency to direct most if not all of the trails funding it receives in its annual federal funding allocation to the maintenance of non-motorized trails. Without OHV funding, non-motorized trails on Forest Service lands would suffer.
• Colorado’s OHV program is a model program that is the envy of many western states.
• The fund has been used to address many environmental issues through the construction of bridges and the rerouting of historic trails out of riparian areas and sensitive habitats.
• The fund supports aggressive education and enforcement efforts.
• OHV recreation in Colorado is completely self-supported by this funding.

How do you expect older hunters and anglers to get around the backcountry? You will lose what little you have without focusing on trails. Old legs use ATVs and ROVs and the public that does not like them is inevitably going to be a small minority. Where is your planning for that inevitability?

What is the role of the State Trails Committee? If you pull out your statutes you will see they are to advise the CPW Commission on all things trails, yet they have been relegated to being grant scorers. How do you so under use your advisory committee so that they are never asked to go out to their constituents, identify problems and seek solutions? We can fix problems, but not without using a tool box that is right under your nose. Better define their role will be a great place to start.
Twenty-eight thousand working volunteer trail hours a year by both the motorized and non-motorized trails communities and these folks deserve more than a passing nod. The non-motorized trails program has lost half its funding in 10 years. Where is the Strategic Plan on that and where is the Commission?

Perhaps most pathetic of all is the CPW’s ancient MOU between it and the federal agencies. It seems like the 1963 agreement, yes, that is correct, an agreement that predates JFK’s death by two days, has never been thoroughly revised to meet the needs of a world that is over 50 years past due on an update. Most of Colorado’s trails are on federal land and CPW doesn’t communicate with them unless the issue deals with wildlife.

A study performed by Southwick Associates for Colorado Parks and Wildlife compiled a number of data sources that quantified the economic contribution of outdoor recreation in Colorado documenting that outdoor recreation constitutes a substantial part of the Colorado economy. The total economic output associated with outdoor recreation was estimated to be $34.5 billion dollars per year, contributing directly $19.9 billion dollars to the Gross Domestic Product of the state. This economic activity supports over 313,000 jobs in the state, which represents 13.2% of the entire labor force in Colorado and produces $12.4 billion dollars in salaries and wages. In addition, this output contributes $4.9 billion dollars in local, state and federal tax revenue.

That same study provided the following: Outdoor recreation includes a diverse set of activities that participants pursue in Colorado. Of particular interest for this study are the contributions of fishing, hunting, and wildlife watching. These three activities together produce over $5 billion dollars of economic output, which supports nearly 50,000 jobs within the state. Wildlife watching alone contributes $2.2 billion dollars in economic output per year, supporting over 19,000 jobs in Colorado. (and how do you get out to those great vantage points? I believe people use trails).

Why were hunting, fishing and wildlife watching the only outdoor recreational activities singled out for more detailed studies in that effort? Taking the difference between the total economic output of $35.5 billion dollars and the $5 billion generated by these three specific pursuits, approximately $30 billion is generated by other outdoor recreational activities.

Knowing that trails related activities are the most popular and most important outdoor recreational activity in Colorado, why doesn’t CPW put more emphasis on trials promotion particularly given the implied financial benefit to the state derived from trails related recreation?

In 2009, the Colorado Off-Highway Vehicle Coalition (COHVCO) convened an economic contribution study for motorized trail recreation in Colorado. That study estimated the total economic benefit derived from motorized recreation in Colorado was just over $1 billion in 2009. Given that motorized recreation is not as popular as non-motorized trail recreation, as shown by the recent SCORP (percentage of Colorado residents participating in walking activities 66%, hiking-backpacking 52%, fishing 36%, wildlife viewing 19%, ATV riding 17%), the multiplier impact of non-motorized trail recreation to the state’s economic related benefit is likely 10 times that of motorized recreation or twice that of hunting, fishing and wildlife watching. Ironically, hunting did not make the list of the top fifteen most popular outdoor recreational pursuits cited by the public in the 2014 SCORP public poll. Yet trails related outdoor recreational support from CPW remains weak and largely ignored.

Important trails agenda and trails related focus areas for CPW:

• tableTrails are the most important and most popular outdoor recreational activities in Colorado and nationwide, CPW should do more to promote trails activities and its trails accomplishments directly through CPW’s programs and website ;
• tableTrails based recreation promotes healthy lifestyles particularly among urban and underserved communities in relation to outdoor recreation;
• tableTrails are the most logical means for gaining greater use and access to the outdoors especially in underserved urban areas and in communities that traditionally don’t participate in routine outdoor recreation;
• table Trails can and should be used as multi-modal transportation corridors to and from urban areas to promote and encourage more non-auto based commuting to ease traffic congestion, build healthy lifestyles and promote better air quality;
• table Exploring, accommodating and encouraging new and evolving trails based recreation such as E-bikes or fat tire bikes;
• table Colorado’s Recreational Trails Committee is an underutilized state resource that should be tasked to assist DNR and CPW to assist in promoting a statewide trails and outdoor recreation agenda;

So please pay attention to one of your greatest resources.

Jerry Abboud
President
Colorado Off-highway Vehicle Coalition

March 11, 2015

BLM Grand Junction Field Office
Att: Chris Pipkin
2815 H Road
Grand Junction, CO 81506

Re: Tabeguache Trail-Highway 141 Connector Route
Project #: DOI-BLM-CO-130-2013-0042 EA

Dear Mr. Pipkin;
Please accept this correspondence as the comments of the above noted Organizations vigorously supporting the opening of a route connecting the Tabaguache Trail to Highway 141, hereinafter referred to as “the Proposal”. Prior to addressing specific comments on the project, a brief summary of the Organizations is necessary to provide context for these comments. COHVCO is a grassroots advocacy organization representing the 150,000 plus registered OHVs in the State of Colorado. COHVCO is 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.

TPA is a 100 percent 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 insure that the USFS and BLM allocate to trail riding a fair and equitable percentage of access to public lands. For the purposes of these comments, COHVCO and TPA will be referred to as the Organizations.

The Organizations vigorously support the preferred alternative of the EA, as the Organizations believe this connector trail will significantly increase the overall quality of multiple use recreational trails in the planning area. While the connector trail will significantly increase opportunities for trail riders in the planning area, the Organizations do not believe that these new connections will greatly increase visitation to the area. The Organizations also believe that the completion of this project, which has been under analysis for an extended period of time, will be a significant step forward in mending relations between the multiple use community and the GJFO which have been strained after the release of the DRMP. The Proposal provides an exceptionally complete review of the planning that has occurred over the decades of management documents that have addressed this project.

The Organizations further support the closure of the existing route in the planning area to all usage upon completion of the new connector trail. The Organizations believe this closure will avoid management of redundant trails that infringe on private property and are difficult and costly to maintain and may be negatively impacting natural resources in the planning area. The Organizations further believe that closure of the route will simplify management of all travel in the planning area by providing a single high quality route for all recreational usage and increased access for land managers performing maintenance in the area.

The Organizations submit that wildlife populations will not be negatively impacted by the proposal, as the Proposal addresses less than 1 mile of trail. A review of the CPW wildlife management plans in the proposal area reveals that deer populations are below targets but that threats to the species are completely unrelated to recreational activity. These threats consistently include private land development and interspecies competition. The herd management plans also note that many in the hunting community are seeking better access to the planning area for hunting, which is entirely consistent with the scope and intent of the Proposal.

While the population of big horn sheep on the GJFO has not warranted the development of a herd specific management plan by CPW, CPW has developed a statewide management plan for the big horn sheep. This plan clearly notes that motorized routes are a low priority management issue, as the primary threat to big horn sheep is a virus easily transferred from domestic herd animals. The CPW statewide big horn sheep plan explicitly states:

“Bighorn sheep managers generally agree that bacterial pneumonia (also called “pasteurellosis”) is the main reason for Rocky Mountain bighorn sheep population declines across much of the west in recent decades…. There are a number of strains of Pasteurellaceae commonly carried by domestic sheep and goats that are highly pathogenic to bighorns, and introduction of a pathogenic strain or another novel pathogen into populations can cause all-age die-offs and lead to low lamb recruitment. Based on a substantial volume of literature, one of the most important aspects of wild sheep management is to keep these species separated from domestic sheep and goats.”¹

The statewide sheep management plan does discuss other factors that maybe impacting sheep. These factors are summarized as:

“Other problems such as unregulated harvest, overgrazing, competition with other livestock, plant community succession and forestation of native ranges, and increasing human development of winter ranges have been identified as contributing to bighorn sheep declines either historically or presently.”²

Given the clarity of this document , any assertion that the Proposal would negatively impact big horn sheep would be difficult at best and falls well short of creating a sufficient basis to restrict access or not move forward with the Proposal. Given that motorized recreation is unrelated to the primary threats to the big horn sheep, the Organizations believe that the proposed monitoring of populations for impacts related to motorized recreation provides more than sufficient protection for these species.

In conclusion, the Organizations vigorously support the preferred alternative and would hope that trail construction could be completed this summer on the project. While the connection is a short distance of trail, the construction of the connector would be highly valued by the recreational community as the connection would significantly improve the quality of multiple use recreation in the proposal area.

If you have questions please feel free to contact: Scott Jones, Esq., 508 Ashford Drive, Longmont CO 80504. His phone is (518)281-5810 and email is scott.jones46@yahoo.com.

Sincerely,

Scott Jones, Esq.
COHVCO Authorized Representative

D.E. Riggle
Director of Operations
Trails Preservation Alliance

1 George et al; Colorado Division of Wildlife; Colorado Bighorn Sheep Management Plan 2009-2019; February 2009
at pg 2
2 Id at pg 1.

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March 4, 2015

Rigby, Idaho (March 4, 2015) – KLIM Technical Riding Gear announced today the signing of a five-year partnership with Colorado-based Trail Preservation Alliance (TPA) to enhance trail preservation, stand up for public access rights, promote responsible recreation and initiate ambassador programs.

As part of the partnership, KLIM will now be an official partner of the annual Colorado 600 Trail Symposium and Ride, a five-day ride and trail symposium through the mountains of southwestern Colorado.Each day during the Colorado 600, riders learn about what is facing the trail riding enthusiast and the issues facing trail use in Colorado. Riders can bring several motorcycles to the event that will allow them to choose the type of trail they would like to ride each day.

“KLIM is committed to the preservation of access and promotes responsible, motorized trail use,” said Mark Kincart, KLIM’s Motorcycle Promotions Coordinator. “Partnering with the TPA will be a great step forward for KLIM to preserve trail systems and trail use for future generations of off-road users. The TPA is a perfect partner for KLIM.”

Don Riggle, Stan Simpson and the TPA Board of Directors shared in the excitement. “It’s great to form this strategic alliance with the premier off road apparel company, KLIM,” said Don Riggle. “This multi-year agreement will help to insure the continued success of the TPA mission.”

To learn more about the Trail Preservation Alliance, visit www.coloradotp.org. To see what they accomplished in 2014, read their 2014 End of Year Report here: http://coloradotpa.org/news/news/tpa-2014-end-of-year-report.html

KLIM TECHNICAL RIDING GEAR IS THE GLOBAL LEADER IN DESIGNING, DEVELOPING AND MANUFACTURING THE MOST ADVANCED MOTOR SPORTS APPAREL FOR THE SNOWMOBILE AND MOTORCYCLE RIDER. UTILIZING THE WORLD’S HIGHEST TECHNOLOGIES IN WATERPROOF, BREATHABLE, DURABLE AND COMFORTABLE MATERIALS, KLIM BUILDS GEAR FOR THE MOST DEMANDING RIDERS.

Dirtrider Magazine, April 2015
Reprinted with permission
Download the PDF of the article to see images
More on this months magazine and to subscribe to Dirt Rider: www.dirtrider.com

GAINING GROUND
Success Stories from The Colorado 600

Story By Chris Denison
Photos By Chris Denison and Dave Martin

POP QUIZ:
HOW MUCH IS RIDING A MOTORCYCLE OFF ROAD WORTH TO YOU?
The above question is simple enough, but it’s also tougher than an adamantium skid plate. Sure, most riders can put a price on the various elements of a riding program—$100 for a tire, $8,000 for a bike, $25,000 for a pickup truck—but ask them to quantify the value of land access and the most you’ll get is a blank stare. The sad fact is that public riding areas—both tracks and trails—are rapidly being taken away from responsible OHV users by highly funded, blindly supported environmental extremists, and yet the average off-road motorcycle rider is content to make a small annual donation and then leave the heavy lifting to the “hard-core trail guys.” This is a model that is doomed for failure, as there is a lot of work to do to protect the sport but not nearly enough people or resources to get it all done.

Fortunately, there are signs—faint signs but signs nonetheless—that the tide may be turning in our favor. An increased number of riders are waking up to the fact that if they don’t take action now, there won’t be any public riding areas left for them, their children, or their grandchildren to enjoy. Local communities and land managers are beginning to embrace off-road recreation for its economic value, and the general public is starting to see that we aren’t just a bunch of lawless hooligans. Riders everywhere are mobilizing and fighting back against rampant land closures. Many of those closures are politically or financially motivated and are borderline unlawful. Positive changes are being made, and the bulk of the progress can be credited to the actions of our sport’s most vehement supporters.

The sport’s top advocates have long believed in an age-old conviction that what happens to the trails in the Rocky Mountains is what eventually happens in the rest of the country. Following this belief, one can regard Montana, Idaho, Wyoming, Colorado, Utah, and New Mexico as the front lines of the war for the future of our sport, with Colorado’s trail-rich outdoor areas as some of the most critical ground to keep. It is here, in the hottest part of the action, that we find the Trails Preservation Alliance, a highly focused, nonprofit organization that works to educate riders, protect off-road areas, and support clubs and trail systems that are in need, as well as to fight off the attacks of the environmentalist groups who want to shut our sport down.

Those of you who have been reading Dirt Rider for a while have likely heard of the Trails Preservation Alliance (TPA) before; its leaders, Don Riggle and Stan Simpson, are well known for standing up to bullying environmental groups and rallying, educating, and empowering off-road riders. One of their most valuable means of accomplishing this is the Colorado 600, a weeklong trail symposium during which the sport’s best and brightest advocates gather to work through current issues, share successful strategies, and enjoy some prime single-track riding before taking all this newfound information back to their respective local areas.

At the most recent running of this annual event much of the focus was on the numerous successes the off-road community has achieved as of late. This was evident before the event even began, as the mandatory tech inspection revealed some interesting results. “Several years ago, we were sound testing our riders’ bikes at 102 dBA, and we had a failure rate of over 40 percent,” explains Riggle, who limits the number of participants on the ride and personally reviews each application. “But thanks to consistently educating riders as to the benefits of the ‘less sound, more ground’ mantra, we’ve seen some major improvements. For example, at the most recent CO 600, we tested more than 120 bikes and only had one machine that required modifications to meet our current limit. And the current sound limit is 95 dBA, which is a lot quieter than what it was a few years back when everyone was failing the same test!” Not only is this proof that many off-road riders have been able to achieve a noticeable decrease in bike sound, but it also provides a glimpse at the kind of thinking that has helped to make loud bikes on trails a rare occurrence.

A veteran of the AMA, Simpson knows all too well how difficult it can be to reach and retain new members. But due to the consistent efforts of the TPA to sup-port OHV organizations—in 2014, the TPA donated tens of thousands of dollars to various groups—interest in trails preservation is on the rise. “In a time when several off-road membership organizations are finding it difficult to gain financial support, the TPA is actually gaining in the number of supporters of the mission we have focused upon,” Simpson says. “Additionally, the involvement of the TPA has become a recognized factor in the legal proceedings related to use and retention of trails in the Colorado region. The growing number of volunteers who step up to assist the TPA is a great trend that tells us to stay the course we started down several years ago. In addition, we have found it necessary to turn down a large number of applicants each year for the CO 600 event, which shows us there are a greater number of eager trail ambassadors out there than ever before. We see this as a real indicator that we are doing things the right way and are making a difference in the future of off-road riding in the Rockies!” There are many who wish that the Colorado 600 would be opened to more participants, but by keeping the event small and personal, Riggle and Simpson have found that they are best able to reach the core participants who come to the ride to learn how best to save the sport.

Another individual who is doing the work of many in keeping public lands open for motorized access is John Bongiovanni, a former Chairman of the Board of Directors for the Colorado Off-Highway Vehicle Coalition (COHVCO). Bongiovanni is a regular at the Colorado 600, and he recently gave a talk to all in attendance regarding some positive developments in OHV tourism. The main goal here is to get economically challenged rural communities to realize that OHV enthusiasts can provide a critical source of revenue. Once they get a taste of this, they fight harder than ever to help keep our public lands open to motorized use. “Rio Blanco County has been my favorite success story,” Bongiovanni recalls of the Meeker, Colorado, group. “They were the first to step forward and take me up on my offer to build an OHV tourism strategy, and they have been doing great with over 250 miles of OHV trails called the Wagon Wheel Trail System. Go check them out! I believe that spreading the word about the positive impact of OHV tourism is a key part of keeping our public lands open. We need more than just enthusiasts fighting for access. We need the communities across the country to stand up and fight to keep our public lands open!”

Bongiovanni’s message to these communities is one of increased prosperity and quality tourism, but it’s also heavily reliant on off-road riders to spread the message. “When you are out enjoying our public lands, go into OHV-friendly towns to buy gas, groceries, motel rooms, etc. Also, be sure to tell the community who you are and that you are a responsible citizen who has chosen to spend hard-earned money in their community. It really does make a difference.” Of course, one of the most important aspects of OHV tourism is respect to the local riders in an area. Anytime you travel to a new trail system to ride, it’s critical to keep in mind that every local trail system has a local club that is responsible for keeping that area open. Not only do you need to be a good steward and treat these trails like they were your own, but it’s also important to support the fund-raising efforts of these local organizations, many of which are operating on shoestring budgets.

One of the members of the symposium’s audience, Bill Hearne, realizes just how much of an impact these local organizations can make. Hearne will take what he’s learned at the CO 600 back home with him to South Dakota, where he will share his newfound info with riders from his local club. As one of just a handful of attendees who has been to every Colorado 600, Hearne enjoys catching up with old friends at the event but says that its distinguishing feature is the educational value. “I don’t have near as much anti-OHV pushback in my state as the folks in Colorado have,” Hearne says. “However, I feel a personal commitment to do my part in the Black Hills. My main challenge is developing new and positive relationships with new or recently promoted Forest Service managers, as this is a constantly changing pool of people. But I’ve learned that a single person can achieve results with consistent and forceful action. Since starting the process, we have made great strides in developing more single-track (about a 300-percent increase), fully developing the Dakota Adventure Loop (dakotaadventureloop.com), and creating another high-dollar fund-raising event: The Dakota 600. Come ride with me!”

While the Colorado 600 might seem like a war room full of generals, not everyone at the event is an old hand. Colorado 600 rookie Richard Crouse made the long trek from New Jersey to the event, and the experience had a profound impact on him. “The OHV knowledge I gained from the 600 is truly priceless,” Crouse says. “After experiencing the CO 600 I am eyes wide open to the present-day issues in the OHV world. I was amazed by the amount of knowledge shared by the members and participants. I would encourage startup OHV clubs and new riders to contact the leaders of the CO 600, who set the standard for OHV activism and have a wealth of knowledge that spans 30-plus years. Also, it’s important that we all stay in close contact with those who manage the lands we ride on. They are mandatory to keep on the OHV team.”

It goes without saying that the riding conditions at the Colorado 600 are absolutely epic, with several days of enjoying the local trail system while also learning from the most passionate OHV supporters in the country. Each morning, the group enjoys a big breakfast together while being addressed by a guest speaker, after which the mass of bikers splits into several different guided rides, ranging from long-distance adventure journeys to full on AA-level enduro loops.

During my adventures at this year’s 600, I spent considerable time both on and off the trail with Scott Bright, who is chairman of the Rocky Mountain Enduro Circuit, and Jim Rios, owner of Billet Racing Products (BRP). Both are Colorado-based business owners who are actively involved in the preservation of the sport,
and each one had good things to say about the current direction of our efforts. “I have seen some amazing things happening, especially in the way people and communities look at OHVs and the riders,” Rios notes. “We were once looked at as reckless motorcycle riders, glared at, and even given the evil eye, but that seems to be changing. More and more people are seeing the caliber and quality of people that ride off-road motorcycles, not to mention the enormous economic impact we provide when we bring our families, motorcycles, and RVs to a small town and fill their restaurants and buy their fuel, food, and drinks. These towns are now welcoming us with open arms and smiles of appreciation, and I couldn’t be happier with that.”

Bright, who was instrumental in opening up and maintaining the area of Colorado where the 600 takes place, agrees with Rios’ outlook. “I am hopeful for the future of motorized single-track in Colorado because of organizations like the TPA,” Scott says. “With a little bit of money and some very coordinated efforts, we have been able to fight back the monstrous Wilderness Societies that would like the motorcycle industry to go away forever. It is a lot like the original Americans that used very focused guerilla-warfare maneuvers against the vastly superior British armies; rather than constantly fighting to keep from losing trails, we are to a point where we can gain some trails back that have been closed for some time. Yes, we do have the occasional losses, and those don’t go down without a major fight. We are gaining ground, and I am grateful for that, and I see hope for my kids and their riding opportunities.”

Despite his optimism, Bright is firm about maintaining our commitment to fighting for OHV access. “We are just now starting to gain some momentum, and now is not the time to sit back and watch this movement idle along in first gear!” Bright cautions. “We need people to pull out checkbooks and pile on the donations then get active about voting, working on trails, and being proactive in terms of protecting our sport. Keep in mind that the TPA is looking to expand into other states; imagine starting your own local club in California, Oregon, or Washington, and getting funded by the TPA to start engaging the local Forest Service about opening up some trails. Think of what could be done if riders from
every state stepped up to do this! There are a lot of victories right around the corner, but we have to stay on the gas and work together in order to achieve them. Letting up now is not an option!”

In the end, the Colorado 600 is a success because it provides a powerful catalyst for positive change in our sport while also maintaining a clear and defined mission: to preserve motorized recreation for future generations. In a time when some OHV users have written off their individual efforts as, “just a drop in the bucket,” the Trails Preservation Alliance is doing an incredible job of educating the leaders of our sport and arming them with new knowledge to bestow upon other OHV activists. This ripple effect is leading to trails being opened— and, in many cases, closed trails being reopened—as well as improved relations with forest service managers, increased opportunities for young enthusiasts, and more support than ever for local clubs.

Naturally, though, every participant leaves the Colorado 600 wondering what can be done to mobilize OHV enthusiasts on a national scale. There are currently dozens of national organizations, yet the off-road community needs just one gigantic group to carry the ball for us. Will the AMA reorganize so as to merge with other national organizations, increase membership, and be the single unifying representative of OHV enthusiasts? Or will the OEMs and dealers be the ones to join forces, rally the troops, and take a collective stand against the onslaught of threats to the way we enjoy the outdoors? The way that things will unfold is not yet clear, though it’s extremely evident that groups like the Trails Preservation Alliance—and the highly successful Colorado 600 event—are making positive forward progress toward advancing our access and sticking up for off-road riders. One thing is definitely certain: Now is the time for every single man, woman, and child to get and remain active in the fight to protect the future of our sport. And if you think the environmentalists are going to give you a fair shake, then I’ve got a nice lightweight adamantium skid plate I’d like to sell you.

WANT MORE? To see what the Trails Preservation Alliance is doing (in great detail), look over the 2014 End of year report in the news section at www.coloradotpa.org and check out colorado600.org to learn more about the event. You can also catch the complete video at dirtrider.com.

Rocky Mountain ATV MC article: The Trail Preservation Alliance Colorado 600: Protecting our Right to Ride

(Reprinted with permission, be sure to check out the article to see all the photos.)

In our line of work, we are lucky to get to be involved in some pretty cool events from time to time. Rocky Mountain ATV/MC was invited again this year to attend the 2014 Trail Preservation Alliance Colorado 600 trail symposium and ride – a five day event to raise awareness for and help preserve motorized, single-track trails open to riders in Colorado and Utah. The event takes place every year in South Fork, Colorado and is headed up by Don Riggle of the TPA, AMA board member Stan Simpson and the organizational efforts of the Texas Sidewinders MC. Important organizations such as the AMA and the Colorado Off-Highway Vehicle Coalition (COVHCO) are represented during the symposium as well.

Motivation from the Masters
Each day of the symposium started off with a delicious breakfast while we listened to a speaker who presented information focused on land use. We learned about local success stories and ways that we could each make a difference. Don Riggle is an impressive speaker – his presence commands your attention, but we are always a captive and eager audience as Don and Stan speak to us. It is always nice to have a group of like-minded individuals capable of incremental changes within their own circles of influence all together in one room.
After the morning symposium each day we’d get to go on epic rides. We’d all separate into groups and happily head off for an opportunity to enjoy the very thing we work so hard to preserve.

Time to Ride!
The first day on the trails we rode Miner’s Creek, just outside of Creede. It was a beautiful and challenging ride. We got the chance to finally ride with a couple that we’d met before and heard a lot about, Greg and Sue. I’d never had a chance to hit the trails with them before, but I’d heard a lot about Sue’s abilities on a bike. From the perspective of a father of three girls that ride, I was very curious to witness her skills myself. I wasn’t disappointed – as the day progressed I learned that Sue is an animal! I went from hoping that someday my girls could ride a trail as gnarly as this to hoping I could keep up with a mid-sixties grandma!

After a great first day of riding, we met back up at the motel for dinner. This year we were staying at the South Fork Lodge and it was an awesome experience. The owners of the property were great and took good care of us. After dinner we went out and relaxed around the fire or soaked in the hot tub to unwind.

Crossing Engineer Pass
Day two started out with a sketchy forecast and a good chance of rain, especially in the high country. But we are always up for adventure! Plus, there were three of us, which is the magic number of course, or so I’m told – one to crash, one to stay with the one that crashed, and one to go for help…

The dark clouds made for some stunning backdrops. The vistas were amazing in every direction. We made the trek from South Fork to Lake City figuring we might get a little wet on our way over the nearly 12,800 ft Engineer Pass. Well, we got way beyond a little wet – we were soaked to the bone.

Although it doesn’t look like it, we had the chance to see some amazing waterfalls. We could see all the way to the top of the mountain peak where the water turned in to a small rivulet. Then we could see it progressively turn in to a roaring river only feet away. Gnarly! I wish we took more pictures but it really was survival mode at that point to get two BMW GS 1200 Adventures and a KTM 950 Adventure up and over the pass. The temp dropped to the mid 30’s and visibility was awful. But the weather improved and the temps rose as we worked our way down towards Animas Forks and Silverton.

After finishing a quick lunch in Silverton, we headed towards Durango. The clouds cleared off the peaks enough to reveal snow on them! We narrowly missed a full on rodeo trying to herd those enormous bikes down a snowy, slick and scary pass! Yikes!

After that, we decided we’d had enough off road for the day and took the pavement around to Pagosa Springs, Wolf Creek Pass and on in to South Fork. Awesome day!

A Tribute in the Forest
Day three turned out to be one filled with a lot of emotion. Riggle is a retired Colonel and many at the event were Veterans of our military. We were led to a Vietnam memorial that is accessed at the end of a dirt road in the middle of the forest. The site was absolutely amazing. The reverence I felt at that remote memorial is a feeling I will always remember. I felt truly honored to be able to go with those men and experience that place. The ride was fun as well but everything was overshadowed by the overall gratitude and respect I was feeling for our Veterans. The memorial honors not only our American Soldiers, but our allies as well. As I sat down to write this article and did some research on the Internet, I discovered that this monument was built in a faraway place to be kept somewhat secret and sacred. Because this is a special monument in a special place, I don’t want to show any disrespect. If you have a desire to go and see this monument, find a Vietnam Veteran and ask him to show it to you.

Trials or Trails?
Day four had us back on the little bikes. We went on a ride with Jason Elliot and a local who showed up on a CRF230 with a trials tire, mentioning that his background was trials. I have been on rides with guys like this before and it usually means gnarly, tight trails…I was correct.

We spent most of the time in Alder Creek. I didn’t notice many alder trees – switch backs and boulders were all I could see. I finally noticed one tree when the remains of a stump somehow lodged between my forks and front tire and stopped me in my tracks.

Concluding Another Great Symposium
That final day of riding ended with a big banquet at the local country club. It was topped off by Chris Denison from Dirt Rider magazine as our final guest speaker. His speech was focused on success stories and it was a refreshing way to finish up a great symposium.

This year’s Colorado 600 trail symposium and ride ended up being like the rest: enlightening and a lot of fun! We can’t wait for next year!

Congratulations to the Kara Riders in Wyoming!

The Colorado TPA and Wyoming trail riders have been jointly associated for years, trying to save our sport.

Article republished with permission from Blue Ribbon Coalition (www.sharetrails.org)

BOISE, ID — When the snow clears in the coming spring, Wyoming riders will again enjoy the opportunity to traverse Trail 38 on the Bighorn National Forest, thanks to the Inyan Kara Riders-BlueRibbon Coalition (BRC) legal effort. Trail 38, a 4.5 mile section of rare Wyoming single-track, was closed in the Spring of 2012 through a Tongue District Ranger letter purporting to change the Trail’s designation to non-motorized. Following unsuccessful outreach and correspondence to the Forest Service, local riders contacted the BRC to evaluate their options. On August 6, 2014, the BRC Legal Team filed a lawsuit in the U.S. District of Wyoming, alleging that the non-motorized designation of Trail 38 violated federal laws and regulations. Rather than answer the complaint, the Forest Service withdrew its designation, and Trail 38 reverted to its earlier motorized status.

“We are pleasantly surprised by the Forest Service’s quick and decisive choice to avoid protracted litigation,” said J.R. Riggins, a named plaintiff in the suit and leader of the Wyoming rider’s effort. “Cynics sometimes think that litigation is an expensive exercise in symbolic futility, but our ability to resume summer trips on Trail 38 serves as a tangible reminder that a well-designed courtroom effort can make a difference on the ground,” Riggins observed.

Since 1997, the BRC Legal Program has appeared across the nation to fight recreation closures and defend pro-trail agency decisions. Many cases involve defense against attacks from anti-access groups. Some, like Trail 38, are efforts to go “on offense” and establish or restore access opportunities which has occurred at least 14 times. The BRC Legal Program total investment in access is at 1.7 million dollars spent and counting.

The plaintiffs in the Trail 38 effort were represented by Paul Turcke of Boise, Idaho, who has been lead counsel for BRC since the Legal Program’s inception, and local counsel Harriet Hageman and Stacia Berry of Hageman Law in Cheyenne. These lawyers previously joined forces to represent recreation interests in support of the State of Wyoming’s challenge to the 2001 Clinton-Gore Roadless Rule. The parties to the suit have reached an initial agreement on a settlement, which is undergoing final approval by federal government officials.

###

The BlueRibbon Coalition (BRC) is a national non-profit organization that champions responsible recreation and encourages a strong conservation ethic and individual stewardship, while providing leadership in efforts to keep outdoor recreation alive and well — all sports; all trails.  With members in all 50 states, BRC is focused on building enthusiast involvement with organizational efforts through membership, outreach, education and collaboration among recreationists. 1-800-BLUERIB –  www.BlueRibbonCoalition.Org.

Contact:
Paul Turcke, Esq.
208-331-1800
pat@msbtlaw.com

Message from USDA Forest Service regarding update to Basalt to Gypsum Singletrack:

Dear Interested Participant:

A Draft Decision Notice/Finding of No Significant Impact (DN/FONSI) regarding the projects analyzed in the Basalt to Gypsum Motorized Singletrack Environmental Assessment (EA) are complete and are available for your review. Project Design Criteria (PDC) are included with the DN/FONSI. There will be no further comment period on this project, but individuals who submitted timely and specific written comments during the prior scoping period will have eligibility to file an objection under 36 CFR §218.8. Objections to the documents must be received within 45 days of the legal notice published today in the Glenwood Post Independent newspaper.

The EA analyzed the establishment of motorized singletrack trails and a parking area, wetland restoration and rehabilitation of non-system routes on approximately 9 acres. These actions are proposed to be implemented on the Aspen-Sopris and Eagle-Holy Cross Ranger Districts of the White River National Forest (WRNF). The selected alternative (Alternative 2) includes the following activities:

• Construction of an approximately 80’ x 200’ parking area, near the beginning of the Red Table Road, National Forest System Road (NFSR) 514 on the north side of County Road 10 near Cottonwood Pass;
• Reconstruction of a total of 8.2 miles of motorized trail at the “Green Gate Trail”, and the “Milepost 1 Trail”, to create a more logical and sustainable trail system;
• Restoration of a wetland impacted by the existing parking area at the junction of NFSR 514 and County Road 10 and;
• Rehabilitation of approximately 27 miles of trail.

All elements of the proposed action would be implemented by the WRNF, and their partners, beginning in 2015. The responsible official with approval authority for these activities is Scott Fitzwilliams, Forest Supervisor on the WRNF.

Objections, including attachments, must be filed via mail, fax, email, hand-delivery, express delivery, or messenger service (Monday through Friday, 8:00 a.m. to 4:30 p.m., excluding holidays) to: Reviewing Officer, Dan Jirón, Regional Forester, USDA Forest Service, Rocky Mountain Region, 740 Simms, Golden, CO 80401; FAX: (303) 275-5134, or email r02f15admin_review@fs.fed.us.

Thank you for your interest and participation in this project. Hard copies of the EA can be reviewed upon request at the Sopris Ranger Station, the Forest Supervisor’s office, and Eagle Ranger stations. The EA is also available online at: http://www.fs.fed.us/nepa/nepa_project_exp.php?project=41619. If you have any questions or comments, please contact Jon Thompson at jonthompson@fs.fed.us or (970)404-3172.

Sincerely,
SCOTT G FITZWILLIAMS
Forest Supervisor

January 1, 2015

Derek Padilla, District Ranger Dolores Ranger District
29211 Highway 184
Dolores, CO 81323
January 30, 2015

RE: Rico-West Dolores Roads and Trails Travel Management; Comments to Proposed Action

Dear Ranger Padilla and ID Team:

We submit the following comments regarding the Proposed Action, Travel Management for the Rico-West Dolores Roads and Trails, December, 2014 (the “PA”). We submit these comments on behalf of our clients the Trails Preservation Alliance (“TPA”), Colorado Off Highway Vehicle Coalition (“COHVCO”), Public Access Preservation Association (“PAPA”), San Juan Trail Riders (“SJTR”), and the Blue Ribbon Coalition (“BRC”). We appreciate the opportunity to provide comments and to work wih the Forest Service to ensure that the public is afforded appropriate continuing motorized recreation and access opportunities in the Rico-West Dolores Area (“RWD”).

These comments are supplemental to, and independent of, any submitted separately by the above-named organizations, or any of their members. The agency shall independently evaluate and respond to all such comments. An effective response to such comments will be essential to the long-term success of travel management in the RWD. Please direct any correspondence regarding these comments to Paul Turcke via the above-listed contact information or pat@ msbtlaw.com.

INTRODUCTION

We are disappointed by the PA. We have expended meaningful resources alongside the Forest Service defending against the unjustified and unnecessarily elaborate claims in Backcountry Hunters and Anglers, Colorado Chapter v. U.S. Forest Service, Case No. 1l-CV- 3139 (D.Colo.) and Nos. 13-1216 & 14-1137 (10th Cir.) (the “CBHA litigation”). The singular plaintiff in that litigation does not represent a significant constituency of users in the RWD or beyond . Notably absent from that litigation has been an array of “first tier” environmental groups or legal counsel, as is frequently seen in cases of this nature that are a high priority to the “nonmotorized” user community. Rather, this is an aberrational lawsuit that has been aggressively, yet to this point unsuccessfully, advanced by an outlier group. We applaud the efforts of the Forest Service, and its legal counsel, in all aspects of the response to the CBHA litigation.

Despite the foregoing, the PA contains significant and unjustified concessions that cannot be viewed as anything other than capitulation to the plaintiffs in the CBHA litigation, or their closely-aligned special interests such as the for-profit, and world renown, operations of the Dunton Hot Springs LLC. The restrictions in the PA, such as seasonal closures for aggressively hunted ungulate populations, or nonmotorized buffers around the Town of Rico, stand as glaring reversals of prior agency determinations and/or closely parallel specific requests from anti­ motorized advocates. Whether intentional or not, the Forest Service sends the message through this PA that the agency will capitulate to litigation, and more aggressive litigation will prompt greater capitulation by the agency. We ask the agency to carefully reconsider this message.

There are lawsuits and then there are lawsuits. We are not so naYve as to ignore the fact that some lawsuits are well-conceived and well-executed, and raise substantial procedural/resource concerns while representing meaningful risk to orderly agency operations. Without downplaying the importance of its opportunities or resources, the RWD does not present such delicate challenges. The alleged bases for change, such as elk populations or claims of user conflict, are among “bottom of the barrel” tools in the bucket of anti-access advocates. The RWD effort is not driven by listed, or even sensitive, species concerns. Elk in the RWD are thriving, and if anything are hunted too successfully by too many humans. The RWD, San Juan Forest, and State of Colorado offer world-class opportunities for nonmotorized recreation and adventure. The RWD project is largely an exercise in social engineering, not management of resources facing meaningful risk.

Closely associated with the litigation is the fact that this effort follows from the agency’s self-imposed remand of the 2009 TMP. We interpret this remand, based on our own experience but more importantly on the agency’s representations in the CBHA litigation, as being driven by procedural concerns. Inother words, there is nothing that was substantially wrong with the on­ the-ground components of the 2009 decision, so much as the manner in which they were packaged.

Fortunately, this process is at its earliest stages. There is ample time to steer it back on course. It may provide procedural cover to include components of the PA within the range of alternatives, but it is essential that the Forest Service create an alternative that will modify or eliminate certain elements of the PA, and reinstate some of the well-conceived elements of the 2009 TMP. A well-designed process can maintain the few remaining, highly desirable motorized recreation opportunities in the RWD while highlighting, and enhancing, the RWD’s similarly desirable nonmotorized recreation opportunities. There is ample room for diverse recreation in the RWD.

OVERVIEW ON TRAVEL PLANNING

This project addresses the multiple purposes of revisiting travel planning for the RWD following remand of the 2009 TMP and adoption of the 2013 Forest Plan, consistent with national policy articulated in the 2005 Travel Management Rule (“TMR”) (70 Fed. Reg. 68264 et seq., Nov. 9, 2005; 36 CFR Parts 212, 251, 261 and 295). It is important to note at the outset that the TMR is not a “closure” directive as portrayed by some preservationist special interests.

Then-Chief Dale Bosworth stated upon release of the TMR that “[1]and Managers will use the new rule to continue to work with motorized sports enthusiasts, conservations, state and local officials and others to provide responsible motorized recreational experiences in national forests and grasslands for the long run.” USDA Forest Service, News Releases, “USDA Releases Final Rule for Motorized Recreation in National Forests & Grasslands,” dated November 2, 2005. “A managed system of roads, trails and area designated for motor vehicle use will better protect natural and cultural resources, address use conflicts, and secure sustainable opportunities for public enjoyment of national forests and grasslands.” Travel Management Rule Final Communication Plan, November 2, 2005, p.5. In fact, “it is Forest Service Policy to provide to diversity of road and trail opportunities for experiencing a variety of environments and modes of travel consistent with the National Forest recreation role and land capability.” Forest Service Manual 2353.03(2); see also, 70 Fed. Reg. 68264 (“motor vehicles are a legitimate and appropriate way for people to enjoy their National Forests in the right places and with the proper management.”). The Forest Service should be planning for a managed system, and working with all groups, including OHV enthusiasts, in order to comply with not only the agency’s own directives and the Travel Management Rule, but the policies behind the Rule.

In summary, the TMR is designed to address the threat of “unmanaged recreation” and to put the agency in a position to be pro-active in addressing what is now a dominant use of the National Forest System. Properly understood, the TMR is not intended to reflect some broad agency policy against motorized travel, or to wipe the slate clean of appropriate access that has existed for decades within Forest System units. The TMR is not a closure direction, but a means for the agency to make improvements to better ensure sustainable travel networks on Forest Service lands.

GENERAL COMMENT THEMES

There are several key elements within the PA, or issues implicated by it, that we wish to stress at the scoping phase. Again, the time to address and properly plan for these issues is now.

(1) The Seasonal Motorized Travel Closure is Excessive and Unjustified.

The Forest Service is proposing to restrict access on single-track motorcycle trails from September 9 through June 30, allowing motorcycle access only from July 1 to September 8. PA at 5. The alleged justifications for this closure are concerns expressed by “some hunters …that motor noise on the single track trails disturbs their hunting experience.” Id. Second, the agency claims the Forest Plan “emphasizes providing for elk production habitat during the time of year when elk are calving.” Id. There is not even a rational basis to defend these purported bases for the dramatic seasonal restrictions proposed.

Starting with the second justification, there is no rational basis to suggest that elk calving or other habitat needs are not amply met in the RWD. To now assert differently would have the Forest Service dramatically contradicting its sworn testimony in the CBHA litigation:

It is generally accepted big game require a minimum functional security area size of 250 acres. The spaces between the current designated road and trail system provide a total of 157,568 acres of security areas spread across the Rico-West area (the smallest is around 450 acres and the average size is around 5.000 acres). In my professional option the movement of big game populations for seasonal migration and the use of production and foraging areas is not restrained by the 14 [motorcycle] trails, based on the size of the land spaces in between that provide for security.

Declaration oflvan Messinger at 6, Docket No. 34-7, CBHA v. USFS, Case No. 11-CV-3139 (D.Colo.) (attached as Exhibit “A” hereto). Further, the PA fails to recognize or discuss the fact that concerns about elk habitat security focus on human disturbance, not solely motorized disturbance. Again, as Mr. Messinger testified, “[i]f motorcycle use was removed, the trails would continue to be used by hikers, horseback riders and mountain bikers so there would still be a disturbance to wildlife from humans.” Id. at 7.

Our clients have carefully scrutinized the wildlife-based rationale for seasonal restrictions, including working with our wildlife biologist consultant, John Monarch. We incorporate Mr. Monarch’s comments by reference herein. In short, Mr. Monarch breaks the elk equation into several key elements. The first important element is that there is essentially no “problem” that needs fixing with RWD (or larger DAU 24) elk herds. Even if there was some issue, the USPS has not, and cannot, demonstrate that long-existing single-track motorcycle riding is a causative factor that can be rationally singled out for restrictions. We ask the Forest Service to carefully review the points made by Mr. Monarch and consider whether it will serve the resource, the user community, or the agencies well to continue on the rationale outlined in the PA.

The concerns about ill-defined concerns from “some hunters” are an even flimsier justification for closing these trails for nearly ten months of the year. CPW manages elk hunting with a decided emphasis on maximizing hunter opportunity, and perhaps not coincidentally, hunting-derived revenue. The RWD game management units are not controlled hunting units and are not managed for low tag numbers and the related relative solitude and “high quality” hunting experience. Elk hunters in the RWD, like much of Colorado, should expect to encounter numerous other hunters, many of whom will be employing a motorized means of conveyance, which may often display registration from outside the State of Colorado. For the Forest Service to claim it is responding to a need to create “higher quality” elk hunting experiences in the RWD by instituting motorized closures is well outside the range of credible agency behavior that we see in travel planning.

It is essential that the Forest Service immediately rethink the PA’s emphasis and configuration of seasonal restrictions. There is no defensible justification for these restrictions, and our clients will oppose them through any all available procedures.

(2) It is Inappropriate to Create a non-motorized Buffer around the Town of Rico.

The PA reflects an apparent Forest Service determination that the Town of Rico has requested a 3 mile “motor free” zone around its borders. We question whether the Town has properly formalized this request, and if so it is at the urging of special interests like the Rico Alpine Society or business owners hoping to expand or create their own markets catering to non-motorized devotees.

Our clients have attempted to create and maintain a mutually respectful and beneficial relationship with both residents and “officials” in the Town of Rico. We are not aware that the Town has conducted a meaningful public process to formulate a position on the PA or RWD planning. To the extent there is some suggestion of such an effort, it predates the 2009 TMP and is of questionable present validity.

We can appreciate that backcountry communities in Colorado desire a diversity of recreational experiences, and that this includes meaningful opportunities for non-motorized recreation, including both short loops or “day trips” as well as “staging” or access corridors for more extended backcountry experiences. However, these opportunities do not necessitate elimination of motorized access. The Forest Service should carefully determine the array of Rico routes that can support a robust and diverse transportation network and recreation experience, including motorized access/recreation.

(3) Subjective User Conflict is Not a Defensible Basis for Motorized Closures.

There is some indication the Forest Service is relying on subjective “user conflict” to justify certain trail closures. There is no basis in logic or the law to do this. Our organizations have spent decades fighting this issue, and we will do so here. “User conflict” is intentionally manufactured by anti-access advocates. The RWD generally contains well designed and long traveled trails that do not have public safety or other true conflicts between uses. The entire RWD is “open” to non-motorized travel, there is a simple answer for those who wish to avoid motorized traffic – stay away from the handful of motorized trails.

While anti-access forces still attempt to recirculate a handful of long-ago rulings on this topic, the fact is that “user conflict” claims have been recently and forcefully rejected by the courts. In Wild Wilderness v. Allen, 12 F.Supp .3d 1309, 1330 (D.Or. 2014), the court found that “tradeoffs between motorized and non-motorized users have already occurred and will continue in the future. The record demonstrates that the Forest Service is continuing a long, inclusive process to manage winter recreation use on the Cascade Lakes Highway.” The court’s decision may be viewed at:

www.snowmobilers.org

A more recent decision in the 10th Circuit upheld the Forest Service designation of long­ existing motorized access along the Albany Trail against preservationist claims of user conflict. Biodiversity Conservation Alliance v. U.S. Forest Service, 765 F.3d 1264, 1275 (10th Cir. 2014). This motorized designation was upheld, even where the Albany Trail traverses an Inventoried Roadless Area which anti-access advocates regularly seek to imbue with quasi-Wilderness status.

We urge the Forest Service to understand the full extent of its discretionary authority, and exercise that authority in focusing on a management approach in the same spirit as the Kapka Butte and Albany Trail projects.

(4) The Remaining RWD Motorized Trails Have Received Sustainable Motorized Travel for Decades, and Ample non-motorized Recreation Opportunities Abound.

The routes that remain for motorized access in the RWD have receive motorized access since the first motorized vehicles could first access them. Many others have been closed. The Forest Service featured this fact in defending the lawsuit, acknowledging that the currently designated motorized routes in the RWD “are generally 18 inches or less in width and have historically been open to shared uses of hiking, horse-back riding, mountain biking, and motorcycle use for decades.” Declaration of Mark W. Stiles at 10, Docket No. 34-2, CBHA v. USFS, Case No. 11-CV-3139 (D.Colo .)(attached as Exhibit “B” hereto).

The RWD and Colorado are a mecca for Wilderness and non-motorized recreation opportunity. If users are frustrated by the existence of continuing motorized use on currently designated routes in the RWD, it is because they have not become properly informed about the management prescriptions in the area and/or have formed unrealistic expectations centered on their own individual desires. The agency has taken numerous measures “to inform and educate trail users of what to expect on a shared-use trail” and agency staff “have heard from the public of many examples of courteous recreation behavior across all types of use…[and] have also heard of examples of poor share the trail behavior across all types of uses.” Declaration of Penelope K. Wu at 7, Docket No. 34-5, CBHA v. USFS, Case No. 11-CV-3139 (D.Colo.)(attached as Exhibit “C” hereto). Ms. Wu insightfully opined that negative impacts attributed to motorcycle noise are “in the ‘ear of the listener’ in terms of tolerance or acceptance of vehicle noise” and that “[n]oise is acceptable in an area managed for multiple uses including motorcycles and is typical of other motorized trails on the San Juan National Forest.” Id. at 8. On the National Forest System and our broader culture, we cannot and should not capitulate to the uninformed, subjective desires of a small minority of chronically dissatisfied individuals. If the Forest Service wishes to breed a culture of discontent, conflict and litigation, then the PA represents the perfect next step.

(5) The Agency Duty to “Minimize” Need Not Unduly Restrict Remaining Access.

It is both legally and pragmatically essential that the agency use its discretionary authority to formally establish a sustainable, yet functional, network of designated routes. It is likely that various preservationist and anti-access special interests will incant a litany of alleged legal violations designed to stymie adoption of or any meaningful network of vehicle routes in the project area. They are certainly entitled to voice their opinions, but the agency should carefully evaluate any such claims and realize they are often thinly veiled efforts to advance an agenda that includes significantly reducing, if not eliminating, recreational use of vehicles in the National Forest System. The agency is empowered to reject these anti-access positions through correct interpretation of the law, as reflected in various recent court decisions.

A favored line of recent attack has been through the “minimization criteria.” The minimization criteria have been around since 1972 and long received only passing interest, but have acquired teeth largely through recent litigation involving similar regulatory language addressing management of the National Forest System. See, 36 CFR § 212.55(b) (requiring agency to “consider effects…with the objective of minimizing” a variety of factors including damage to soil, watershed, vegetation and other forest resources; harassment of wildlife and significant disruption of wildlife habitats; conflicts between motor vehicle and other uses; and conflicts among different classes of motor vehicle uses). In particular, this renewed interest springs in large part from the decision by a U.S. Magistrate declaring invalid the Salmon Challis NF travel decision. This decision was issued in 2011, and is published as Idaho Conservation League v. Guzman, 766 F.Supp.2d 1056 (D.Idaho 2011). In short, that decision rejected the Forest Service effort to characterize the minimization criteria as providing broad guidance (“consider with objective of minimizing”) and interpreted the language as requiring the agency to show, in its NEPA analysis, how it applied the minimization factors in selecting from decision options for specific routes. There have been several more decisions that have followed similar reasoning, which have only come from federal district courts. The 9th Circuit has on three (3) occasions heard cases involving the OHV “minimization criteria” and has declined to follow the Guzman court’s reasoning in two of those cases, with the third still under advisement following argument on November 7, 2013.

The agency has broad discretion applying the minimization criteria and is certainly not obligated to restrict motorized access, particularly in response to the subjective complaints or other “evidence” provided by self-interested non-motorized use advocates. Several decisions reflect this important truth, most notably the two (2) 9th Circuit decisions on the topic, both issued in unpublished memorandum dispositions. See, The Pryors Coalition v. Weldon, 803 F.Supp.2d 1184 CD.Mont. 2011), aff’d , 551 Fed.Appx. 426 (9th Cir. 2014); The Wilderness Soc’y v. BLM , 822 F.Supp.2d 933, aff’d , 526 Fed.Appx. 790 (9th Cir. 2013). Relatedly, non-motorized recreationists have no inherent “right” to exclusive use, or any use, that exceeds or trumps those of other recreationists. See, Bicycle Trails Council of Marin v. Babbitt, 82 F.3d 1445 (9th Cir. 1994) (rejecting challenge to NPS management plan restrictions on bike access). The agency cannot be strong-armed into motorized use closures or restrictions , and a well-reasoned and documented balance affording reasonable opportunities to a spectrum of recreational uses will be upheld by the courts. Our clients were among the parties to the Pryors case, and a copy of the Circuit’s decision can be viewed at:

www.sharetrails.org

The fact is that “minimization” has not recently been a productive line of argument for anti-access advocates, and for several years the courts have been ruling in favor of the Forest Service and other agencies on these issues. There are no recent litigation developments that should cause a different outcome in the RWD. Decades of Wilderness designation and closures have already “minimized” the impacts of motorized recreation in the RWD. The Forest Service should avoid capitulating to false cries for new closures based on a myopic interpretation of the minimization duty.

SPECIFIC ROUTE COMMENTS

There are many route-specific elements of the PA that should be modified. This process is an excellent opportunity for the Forest Service to establish a well-designed, diverse road and trail system that can meet user needs while properly shaping their behavior long into the future. Our clients and their members will provide extensive and detailed input on these issues, and we will simply summarize some of their key observations.

(A) Specific Route Proposals in the PA Should be Modified.

The project area is subdivided into 9 different areas. The proposals are acceptable for some areas. The areas/routes that need changes are briefly described below:

Area 2 – Winter Trail 202, West Fall 640 and East Fall 646 should remain open in their current motorized designation. The Winter Trail reroute should be non-motorized, and an additional non-motorized trail should be constructed between this reroute and the Burro Ridge Trailhead. This offers a “motor free” experience and access to the Lizard Head Wilderness.

Area 3 – Spring Creek 627, Morrison 610, and Loading Pen 738 should be designated as motorized single-track.

Area 4 – Wildcat 207 should not be eliminated but rather extended southward to the railroad right of way. One or both sections of the Ryman Trail should be single-track motorized and connect Calico South 211 and Priest Gulch 645. Burnett Creek 641 should be designated as motorized single-track.

Area 5 – Sackrider 6 should remain a motorized section of the Calico 208 trail. Any non-motorized redesignation of Horse Creek 626 should be offset by addition of replacement motorized trail miles somewhere in the system.

Area 9 – The lower Bear Creek Trail 145 should not be non-motorized, but we would accept this redesignation if a bypass or suitable replacement motorized trail miles could be added.

(B) Certain Components of the 2009 TMP Should be Reinstated.

In addition to the specific routes described above, there are elements of the 2009 TMP that appear to have been unnecessarily or unwisely removed from the PA. Some of these are discussed in (A) above, but at the risk of redundancy we wish to identify the list of these 2009 TMP routes that appear to have been omitted from the PA.

Specifically, we are concerned about the following elements:

Priest Gulch Cut-Off
Wildcat
Winter
West Fall Creek
East Fall Creek
Sockrider section of Callico Trail
Spring Creek Extension to FS 692
Grindstone Loop
Ryman Creek
Burnett Creek and Trailhead

CONCLUSION

We sincerely hope the Forest Service does not carry forth the primary themes of the PA. Doing so will insure continuing dispute and litigation over the RWD trails. Instead, the Forest Service has the opportunity to await the final resolution of the CBHA litigation, to make modifications along the lines proposed by our clients, and to bring consistency and closure to RWD travel planning.

Sincerely,
MOORE SMTIB BUXTON & TURCKE, CHTD.

Download the PDF (above) to see the letter in it’s entirety including the Exhibits.

January 30, 2015

Att:
Derek Padilla
District Ranger 29211 Hwy 184
Dolores, CO 81323

RE: Dolores Ranger District Travel Management

Dear Mr. Padilla:

Please accept this correspondence as the comments of the Colorado Off-Highway Vehicle Coalition with regard to the proposed action for Travel Management for Rico/West Delores Roads and Trails (“The Proposal”). The comments are submitted in conjunction with the comments from the San Juan Trail Riders, Public Access Preservation Association and Trail Preservation Alliance. The specific portions of those comments have not been reproduced here simply to avoid repetition but are fully supported by COHVCO. COHVCO vigorously support the route specific comments submitted by the San Juan Trail Riders and Public Access Preservation Association relative to the Proposal. COHVCO vigorously support any new trails that are to be opened in the Proposal, such as the loop adjacent to FR533. It is COHVCO’s position that the public lands within the Proposal area provide recreational opportunities that highly valued by the single track motorized community due to large scale closures of single track trails in areas outside the planning area.

COHVCO is concerned that after a review of the management history of the Proposal area that the area has been repeatedly analyzed for a variety of management changes, and these management analysis have repeatedly declined to expand quiet usage of the area. These recent management reviews include determinations that the area was not suitable for upper tier roadless area designation, was not eligible for management for Wilderness Characteristics and was suitable for motorized recreation. COHVCO is very concerned that even with the clarity of recent landscape management analysis that the Proposal provides for a significant decline in motorized recreational opportunities. While COHVCO appreciates new routes in the Proposal, these are simply not sufficient to offset lost routes.

COHVCO is vigorously opposed to the closure of any trails as part of the Proposal. It is COHVCO’s position that many of the closures are not based on best available science and would note that in our opinion the Proposal consistently places non-motorized interests ahead of multiple use interests based on a mere assertion of conflict regarding the particular route. It is COHVCO’s position that often conflicts between users are overstated in the planning area, and are the result of opposition to multiple use management requirements for the area rather than actual conflict between users. COHVCO and their partners have a long history of partnering with the USFS to address trail related concerns in the area and are aware that often many of the previous opposition to trails has been found to be completely without merit after further investigation. COHVCO vigorously asserts that any closures to be adopted under the Proposal must be vigorously reviewed to insure the closures are addressing actual conflicts and the management proposed will actually mitigate the management issue in a manner consistent with the extensive recent analysis of the Proposal area.

Prior to addressing our specific concerns on the Proposal, a brief summary of COHVCO will add context to our comments. The Colorado Off-Highway Vehicle Coalition (“COHVCO”) is a grassroots advocacy organization of approximately 150,000 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.

1a. A complete assessment of landscape level changes to all recreational opportunities must be made in the Proposal to address recent SJNF Forest Plan determinations and other recent inventories.

COHVCO believes a brief review of broader landscape level planning changes in the San Juan NF Resource Management Plan(“RMP”) is necessary in order to establish context and structure for many of the site specific comments both in this document and related comments. It is COHVCO position that there are significant new areas for many uses that traditionally conflict with motorized usage, the RMP provides significant additional nonmotorized areas expanding the extensive opportunities for these activities that already exist. These nonmotorized opportunities simply are not being utilized for reasons that are not clear to the Organizations. Proper methods for the utilization of these new opportunity areas simply must be addressed prior to determinations of the necessity of closures in the analysis areas. It is also the Organization position that the Proposal area has been repeatedly recently analyzed for possible expansion of quiet usage, both in the RMP and Colorado Roadless Rule analysis, and the Proposal area has been repeatedly found to be an area where expanded quiet usage was an unsuitable usage of the area.

The USFS planning rule clearly establishes that these broader level opportunities must be included in any localized planning determinations. Section 219.6 of the new planning rule specifically states as follows:

“219.6 Assessments. Assessments may range from narrow in scope to comprehensive, depending on the issue or set of issues to be evaluated, and should consider relevant ecological, economic, and social conditions, trends, and sustainability within the context of the broader landscape.”

It is COHVCO’s position that quiet use recreational users already have exceptional recreational opportunities in the SJNF, such as the Weminuche Wilderness which is the single largest Wilderness area in the State of Colorado and is a reasonable distance from the planning area. Additionally, the Lizard Head Wilderness Area is almost immediately adjacent to the Proposal area. USFS research indicates that visitation to these areas is exceptionally low as only 4% of all SJNF visits are to a Wilderness area, while a significant portion of the SJNF is designated Wilderness.¹  These are areas that must be looked at as primary opportunity areas for the expansion of quiet use recreation and solitude as these factors were the basis for the Congressional designations of these areas.

The historical opportunities for quiet use recreation within the broader landscape are significant and were significantly expanded in the recently adopted San Juan NF Forest Plan which provides for an 83% increase in areas that are unsuitable for motorized recreational usage. The RMP provided the following breakdown of these changes:

The RMP graphically reflects the suitability of the Proposal area for motorized usage as follows:

 ²

The RMP also provides specific detail into the process for analysis and review of routes in areas that continued to be identified as suitable for motorized recreation. The RMP clearly states that the treatment of roads in trails in areas that are suitable as follows:

“The existing road and trail networks in suitable areas on NFS lands generally meet current and anticipated future transportation needs, so unmanaged routes in these areas generally would be prioritized for decommissioning.”3

It is COHVCO’s position that the RMP has created a presumption of continued usage of routes in suitable areas, in a manner similar to the presumption that any new routes would not be adopted. It is COHVCO’s position the presumption weighs heavily in favor of maintaining existing trails and heightens the burden that must be met in order to close any route.

COHVCO agrees with the Proposal that the relevant portions of the RMP provides the following localized management standards for usage of multiple use routes in the planning area:

“A variety of looped single- and two-track opportunities for motorized and mechanized recreation exist at a range of elevations, offering different levels of difficulty. Motorized and mechanized opportunities are balanced with opportunities for foot and horseback access to areas of relative quiet and solitude at a variety of elevations. Much of the primary access to these areas is shared, based on mutual courtesy and on a strong stewardship ethic that is primarily self-enforced and maintained by individuals and user groups.”⁴

COHVCO vigorously asserts that the RMP specifically recognizes that the trails in the Proposal area are to be multiple use and are only used to access areas of solitude. These routes simply are not designed or intended to provide solitude or a quiet recreational experience by themselves, but may provide primary access to other routes that provide these opportunities. It is COHVCO’s position that many of the routes that are to be closed are not just the primary access, but are the only access to these areas.

COHVCO vigorously asserts the Proposal seeks to expand a type of usage in the Proposal area that the RMP specifically analyzed and found was not a suitable usage of the area. Mainly, quiet recreational activity and expanded areas of solitude. Significant portion of the planning area was reviewed for Wilderness Characteristics under alternative C as part of the RMP development and found unsuitable for such activity in the final RMP. ⁵ If the Proposal area had been found suitable for Wilderness Characteristics, COHVCO believes closure of routes would have been more appropriate management in site specific analysis. It is COHVCO position that determinations of unsuitability of the area for expanded non-motorized opportunities weighs heavily against expanding quiet usage opportunities as the Proposal area has been found unsuitable for such activity. As previously noted trail access to the Proposal area was already identified for continued current levels of multiple usage in the RMP, making closure of these routes based on asserted user conflict concerns based on impaired quiet usage of these routes a violation of the RMP standards. It is COHVCO’s position that closing routes in a suitable area for motorized recreation should be as difficult as opening routes in a Wilderness Characteristics area. COHVCO again notes that Alternative C of the RMP specifically reviewed the planning area and possible expansion of quiet usages and determined that this was not proper usage of the area. These determinations must be honored.

After implementation of the RMP at the landscape level, almost 50% of the SJNF has been found unsuitable for motorized recreation and there is a presumption that any routes in areas that are unsuitable for motorized recreation will be removed. The RMP provides a similar presumption in favor of maintaining multiple use access in areas suitable for motorized usage. The Proposal area was one of few areas where there was not a significant expansion of areas found unsuitable for motorized recreation, making this an important area to the multiple use community. COHVCO respectfully asserts that any claim of conflict or other necessity of closing routes in an area that has been found suitable must be exceptionally well documented and address a valid management issue related to the particular route being analyzed pursuant to relevant management standards. COHVCO submits that generalized non-specific concerns, such as those referenced on several routes in the Proposal area are simply insufficient to close routes in areas recently found suitable for multiple use management.

1b. The Proposal area was recently inventoried and found unsuitable for upper tier roadless area designation as part of the Colorado Roadless Rule review.

In addition to the review of the Proposal area that was undertaken as part of the RMP for possible Wilderness Characteristics management and a review of the motorized suitability, significant portions of the Proposal area was also reviewed for possible designation as an upper tier roadless area under the Colorado Roadless Rule (“CRR”) proposal. Upper Tier Roadless management would have mandated management where quiet usage was the target. Again the analysis concluded that the Proposal area was not suitable for expanded quiet use recreation that is provided by an Upper Tier Roadless area and the Proposal area should be managed as a Roadless area where the existing roads are permitted to continue and multiple use trail development could be expanded. This determination is exceptionally relevant to the management of the Proposal area as motorized trails and routes are a characteristic of Colorado Roadless areas, but are not permitted in an Upper Tier Roadless area.

Colorado Roadless Rule specifically states usage of a CRR area is as follows:

Roadless Area Characteristics: Resources or features that are often present in and characterize Colorado Roadless Areas, including: (5) Primitive, semi-primitive nonmotorized, and semi-primitive motorized classes of dispersed recreation;⁶

While motorized usage of an upper tier area is not prohibited, there are more restrictions on motorized usage of these areas as recreational usage is directed towards quieter usage . Final version of Colorado Roadless area reflected upper tier and Colorado Roadless areas as follows:

⁷

COHVCO submits the final boundary map above does an exceptional job of displaying the exceptional opportunities within the planning landscape for quiet usage. It is COHVCO’s position that this analysis again provides clear management guidance that must be governing the targeted usage of the area and route specific balancing of interests in the Proposal area.

The CRR again provides site specific analysis of the Proposal area and concludes that management for quiet usage of the area is not warranted due to existing levels of development. Given that the CRR concluded that the area is unsuitable for expanded solitude and the FRMP specifically found the area suitable for continued multiple use access in a manner similar to current levels, it is COHVCO’s position that these determinations provide no basis for the closure of routes based on conflicts with quiet usage expectations. COHVCO vigorously asserts that education of those going to the area as to the management history and significant opportunities for quiet usage at the landscape level are avenues that must be explored in mitigating conflict and that closure should only be pursued as the last avenue to address these issues.

2a. The entire proposal area is closed to multiple usage concerns conflicting with wildlife winter range but wildlife winter range only encompasses a small portion of the planning area.

COHVCO is opposed to the proposed blanket closure of all routes for wheeled travel in the Proposal area on the basis that this usage conflict with or degrades the quality of winter range for wildlife. COHVCO is aware the usage of a wheeled vehicle on a groomed snowmobile route can result in significant conflict between snowmobilers and wheeled OHV users, and do not oppose the closure of groomed routes to wheeled travel. However, COHVCO is vigorously opposed to seasonal closures of routes outside winter range in order to protect the quality of winter range when the quality of that winter range simply is not impacted by motorized usage. COHVCO is simply are unable to locate any viable relationship between multiple use routes outside winter range and improvement of the quality of winter range that might not be adjacent. COHVCO would also note that significant portions of the winter range are simply on private lands and beyond the scope of the planning proposal.

CPW data from relevant game management plans for Mule Deer indicates boundaries for the winter range and reproduction areas for wildlife that are used in the general planning area as follows:

 ⁸

Elk Winter Range boundaries are now available from a wide range of sources to the general public. Third party contractors translate information from CPW regarding winter range areas into mapping for a wide range of applications and public usage. These boundaries of elk winter range are reflected as follows:

COHVCO is opposed to overly broad seasonal closures of routes in the Proposal area. as many wheeled users enjoy accessing trails that may be overall impassable in terms of travel from locations A to B, simply in order to use their vehicles in attempts to cross snowdrifts that might be blocking the routes at some point early or late in the riding seasons. These are unique early and late season riding experiences that are highly valued by multiple use recreational activities. COHVCO vigorously asserts that users opportunity to attempt to cross snowdrifts should only be lost based on best available science. COHVCO would also note that many hunters also use these routes to access hunting opportunities that CPW is now providing for late season hunting, such as youth hunts and private land tags.

2b. Populations of game animals and hunter success in the Proposal area appear stable and above average for the state of Colorado.

Colorado Parks and Wildlife provides significant information regarding the success of hunters for a wide range of methods of hunting. CPW research indicates that hunting success in the Proposal area is significantly above statewide averages.

For Archery Season 2013
Unit 70 Hunters 712 – Success rate 21% – 5yr average 18%
Unit 71 Hunters 839 – Success rate 18% – 5yr average 13%

For Archery Season 2012
Unit 70 Hunters 597 – Success rate 20% – 5yr average 18%
Unit 71 Hunters 844 – Success rate 13% – 5yr average 13%

For Muzzle Loader Season 2013
Unit 70 Hunters 220 – Success rate 36% – 5 year average 20%
Unit 71 Hunters 304 – Success rate 16% – 5 year average 19%

For Muzzle Loader Season 2012
Unit 70 Hunters 240 – Success rate 29% – 5 year average 20%
Unit 71 Hunters 355 – Success rate 25% – 5 year average 19%

For all rifle seasons 2013
Unit 70 – Success average 31.25% – 5yr average 38.5% Unit 71 – Success average 18% – 5yr average 23.25%

For all rifle seasons 2012
Unit 70 – Success average 34.25% – 5yr average 38.5% Unit 71 – Success average 14% – 5 year average 23.25%

COHVCO vigorously asserts that failures of hunters to fill tags is simply does not support management changes as hunter success in the Proposal area has been and remains above statewide averages. COHVCO submit that this information provides no basis for management change but rather clearly shows that current levels of motorized recreation are not impacting wildlife population levels and there is no need to further restrict acces

3. Economic impacts to local communities of proposed changes in access must be addressed.

Pursuant to Forest Service regulations and NEPA, the economic impacts of any Proposal must be analyzed into the planning and decision making process. The negative impacts of the Proposal to surrounding communities must be addressed in the EA as the Proposal seeks to alter many existing heavily used multiple use routes for the benefit of smaller user groups. Risks to local economies from closures of these routes to multiple use recreational interests expands as non-motorized users spend approximately 25% of the average amounts spent by multiple use recreational users. It is COHVCO’s position that any small negative economic impacts to local communities will have a disproportionate impact on local communities that are overly reliant on recreational spending for support of the community.

COHVCO believes a brief summary of the standards that are applied by Courts reviewing agency NEPA analysis is relevant to this discussion as the courts have consistently directly applied the NEPA regulations to EA type review. Relevant court rulings have concluded:

“an EIS serves two functions. First, it ensures that agencies take a hard look at the environmental effects of proposed projects. Second, it ensures that relevant information regarding proposed projects is available to members of the public so that they may play a role in the decision making process. Robertson, 490 U.S. at 349, 109 S.Ct. at 1845. For an EIS to serve these functions, it is essential that the EIS not be based on misleading economic assumptions.”⁹

Prior to addressing more specific NEPA related concerns involved in the Proposal, COHVCO believes a brief summary of the inherent complexity of any economic analysis is warranted. The basic complexity of any economic determinations and the size of the calculations to be made are summarized by the Western Governors Associations’ recreational economic contributions study as follows:

“How is “economic impact” calculated? Many people might think of a consumer buying equipment – a tent, fishing pole, ATV, bicycle, boat, snowboard or rifle. However, the impact is much more complex than the manufacture and sale of gear and vehicles. Gas stations, restaurants, hotels, river guides and ski resorts benefit from outdoor recreation. In total, equipment and travel expenditures represent billions in direct sales that create jobs, income, tax revenues and other economic benefits.”¹⁰

The Western Governors’ Association released its Get Out West report in conjunction with its economic impact study of recreation on public lands in the Western United States which specifically identified that proper valuation is a significant management concern as follows:

“Several managers stated that one of the biggest challenges they face is “the undervaluation of outdoor recreation” relative to other land uses.”¹¹

COHVCO and TPA have developed a high quality analysis of recreational spending from the motorized community. This research has concluded that OHV recreational usage provides $129 in annual revenue to southwestern Colorado and accounts for 1,564 jobs. A complete copy of the 2013 report is submitted with these comments. These are significant contributions that are the result of the high quality riding opportunities that the area has been providing for a long period of time. Any impacts to these significant contributions simply must be addressed in the Proposal.

The USFS has conducted extensive research into comparative spending profiles of various recreational users as part of the NVUM process, and this research is highly valuable to planners in terms of comparing spending profiles of users and allowing planners to estimate changes in visitation and impacts that this has on local economies. The works of Drs. Styne and White performed in conjunction with NVUM research provide the following conclusions in their research on comparative user group spending:

 ¹²

It should also be noted that the Stynes and White work provided a itemized breakdown of most spending categories identified above to allow for more meaningful analysis and application of this information. These itemized breakdowns add further credibility to the Stynes and White works and provide a clear basis for a negative impact from closing motorized trails. These works also specifically provide examples of how these varying spending profiles are to be integrated into site specific plans.

4. The USFS has already determined that Travel Management closures are ineffective for addressing many of the issues sought to be managed in the Proposal

COHVCO believes that a complete analysis of the basis of user conflicts must be undertaken in order to insure that the problems sought to be mitigated by the Proposal are actually improved. COHVCO would note that previous attempts to mitigate impacts to resources and user conflicts undertaken in June of 2010 resulted in the USFS being sued by those that believed these determinations did not go far enough in protecting the type of recreation those user groups were seeking. This should be avoided and a primary tool in avoiding ineffective closures being applied, mainly educating users as to recreational opportunities in the landscape area, which have significantly increased, is not explored.

The US Forest Service’s Rocky Mountain Research Station has recently released extensive analysis of the effectiveness of travel management restrictions on addressing sensitive species related issues. These conclusions specifically found that travel management was not effective in addressing these issues and the species related concerns were often beyond the scope of travel management to address. The Research Station conclusions specifically stated as follows:

“Actions such as limiting grazing or closing OHV trails have historically been some of the primary tools used by land managers in southern Nevada to reduce the effects of anthropogenic stressors on species of conservation concern….. It is evident from this body of research that very little is known about the relative threats posed to, or the mitigation actions needed to protect, virtually any species, except perhaps the desert tortoise. Too often research jumps immediately to mitigation strategies without first determining what specific factors pose the greatest threats and are the most important to mitigate. In addition, the evaluation of potential threats typically focuses upon the usual anthropogenic suspects (e.g. OHVs, livestock grazing, invasive species, and climate change) without first carefully considering which factors are most likely to pose the greatest threats.”¹³

COHVCO would be remiss in not noting the relationship that the Research Stations conclusion has with the management within this Proposal. Numerous references in the Proposal are made regarding possible user conflicts on trails and this being the basis for the removal of motorized usage of these routes. COHVCO vigorously asserts the scope and scale of these conflicts has been greatly over stated by those opposing motorized usage of the area.

COHVCO is concerned that closures of routes have been proposed without undertaking a second step in the analysis that is critically necessary to insure effectiveness of management decisions. This second level of analysis is needed to determine the basis of the conflict, as only a small portion of user conflict can be resolved with closure of the route and improperly based closures of routes can significantly increase conflicts.

COHVCO believes that after a brief summary of best available science into user conflict, the difference in the Proposal management and best available science on the issue will be clear. Researchers have specifically identified that properly determining the basis for or type of user conflict is critical to determining the proper method for managing this conflict. Scientific analysis defines the division of conflicts as follows:

“For interpersonal conflict to occur, the physical presence or behavior of an individual or a group of recreationists must interfere with the goals of another individual or group….Social values conflict, on the other hand, can occur between groups who do not share the same norms (Ruddell&Gramann, 1994) and/or values (Saremba& Gill, 1991), independent of the physical presence or actual contact between the groups……When the conflict stems from interpersonal conflict, zoning incompatible users into different locations of the resource is an effective strategy. When the source of conflict is differences in values, however, zoning is not likely to be very effective. In the Mt. Evans study (Vaske et al., 1995), for example, physically separating hunters from nonhunters did not resolve the conflict in social values expressed by the nonhunting group. Just knowing that people hunt in the area resulted in the perception of conflict. For these types of situations, efforts designed to educate and inform the different visiting publics about the reasons underlying management actions may be more effective in reducing conflict.” ¹⁴

Other researchers have distinguished types of user conflicts based on a goals interference distinction, described as follows:

The travel management planning process did not directly assess the prevalence of on-site conflict between non-motorized groups accessing and using the yurts and adjacent motorized users…The common definition of recreation conflict for an individual assumes that people recreate in order to achieve certain goals, and defines conflict as goal interference attributed to another’s behavior” (Jacob & Schreyer, 1980, p. 369). Therefore, conflict as goal interference is not an objective state, but is an individual’s appraisal of past and future social contacts that influences either direct or indirect conflict. It is important to note that the absence of recreational goal attainment alone is insufficient to denote the presence of conflict. The perceived source of this goal interference must be identified as other individuals.”¹⁵

It is significant to note that Mr. Norling’s study, cited above, was specifically created to determine why travel management closures had not resolved user conflicts for winter users of a group of yurts on the Wasache-Cache National forest. As noted in Mr. Norling’s study, the travel management decisions addressing areas surrounding the yurts failed to distinguish why the conflict was occurring and this failure prevented the land managers from effectively resolving the conflict. It is COHVCO’s position that previous travel management decisions, such as the Forest Order from in 2007 did not reduce user conflicts, but rather resulted in the USFS being drawn into a court battle when the anti-access Organizations believed the closure Order did not go far enough. These issues can only be resolved with a high quality decisions and effective education of all users, which can be easily defended in the court action that will surely follow any decision relative to the management of the Proposal area.

COHVCO believes that understanding why the travel management plan was unable to resolve socially based user conflicts on the Wasache-Cache National Forest is critical in the Proposal area. Properly understanding the issue to be resolved will ensure that the same errors that occurred on the Wasache-Cache are not implemented again to address problems they simply cannot resolve. COHVCO believes that the RWD managers must learn from this failure and move forward with effective management rather than fall victim to the same mistakes again.

Similar sentiments to the studies cited above were recently again clearly identified as best available science in the Get Out West Report from the Western Governors Association. The Get Out West report specifically found:

“Good planning not only results in better recreation opportunities, it also helps address and avoid major management challenges – such as limited funding, changing recreation types, user conflicts, and degradation of the assets. Managers with the most successfully managed recreation assets emphasized that they planned early and often. They assessed their opportunities and constraints, prioritized their assets, and defined visions.”¹⁶

COHVCO believes our concerns regarding the Proposal and those expressed in the Western Governor’s Get Out West report virtually mirror each other. This concern must be addressed prior to finalization of the Proposal in order to avoid increases to many other management issues that were sought to be minimized with the creation of the Proposal.

At no point in the Proposal is there any mention of programs or resources to be developed that might be available to address socially based user conflicts. While COHVCO is aware that such a discussion is technically outside the scope of the Proposal, COHVCO believes that if a distinction between the different bases for user conflicts had been made in the planning process, this distinction would have warranted a brief discussion of methods for resolution of socially based conflicts through educational programs. The lack of an educational component in planning as a tool to be utilized in conjunction with travel management issues and trail closures, leads COHVCO to conclude that there was a finding at some point in the planning process to the effect that all user conflicts are personal in nature. This type of finding would be highly inconsistent with both COHVCO experiences with this issue and the related science.

COHVCO believes the proposed management, and associated levels of multiple use route closures, will result in increased user conflicts as recreational opportunities in the Proposal area will be lost and not replaced to address an issue that the closure simply cannot remedy. Contrary to the intent of the Proposal, mainly to minimize user conflicts, COHVCO believes the Proposal will result in greater conflict not less. As noted above, personal user conflicts only account for a small portion of total user conflicts. While these personal conflicts would be resolved, the overwhelming portion of user conflict results from a lack of social acceptance by certain users and these conflicts would only be resolved with education. COHVCO believes the distinct between personal and social user conflict must be addressed in the Proposal and the levels of closures reviewed to insure that the levels of closures are not going to result in increased user conflicts.

5. Motorized access has been specifically identified as a critical component of the hunting experience.

COHVCO has many members who are actively licensed hunters or fisherman and utilize a wide range of areas in these pursuits and fully utilize OHVs as part of their hunting experience, and often these visitors to the planning area are overlooked by groups allegedly advocating for hunting interests. COHVCO is also aware that many hunters are difficult to engage in the travel management process for a variety of reasons and often to not become aware of travel management proposals until access to areas is lost. This often results in high degrees of frustration to these users when they are informed that additional NEPA must be undertaken to alter any decisions that were recently implemented in compliance with NEPA. Throughout the

Proposal there are general allegations made that closures of motorized routes is being undertaken to improve hunting opportunities in the Proposal areas. The basis for these closures often is non-specific concerns from hunters, which is an insufficient basis for closure of multiple use routes, as this is a violation of relevant NEPA requirements and requirements that best available science be relied on in the planning process.

Recently, the National Shooting Sports Foundation in partnership with the USFWS and 20 different state wildlife agencies performed a national review of the issues that are impacting the hunting community and declining hunter participation rates in the US and what agencies can do to maintain hunter involvement in the wildlife management process. The NSSF research specifically concluded:

“Difficulty with access to lands for hunting has become not just a point of frustration, but a very real barrier to recruiting and retaining sportsmen. Indeed, access is the most important factor associated with hunting participation that is not a time-related or demographic factors in other words, the most important factor over which agencies and organizations can have an important influence….”¹⁷

The importance of hunting usage and access for funding of wildlife management activities, a significant issue that is directly related to hunting usage is overwhelming. This funding impact is summarized as follows:

“Hunters are avid conservationists who donate more money to wildlife conservation, per capita, than do non-hunters or the general population as a whole in the United States (Responsive Management/NSSF, 2008a). Hunting license fees and the excise taxes paid on sporting goods and ammunition fund state fish and wildlife agency activities and provide Federal Aid monies…. In fact, sportsmen, as a collective group, remain the single most important funding source for wildlife conservation efforts. Consequently, decreased interest and participation in hunting activities may have the unintended effect of reduced funding for important wildlife and habitat conservation efforts.”¹⁸

The importance of motorized access to the retention of hunters is immediately evident when the means of access for hunting activity are identified. Hunters overwhelmingly use motorized tools for accessing hunting areas as cars and trucks are used by 70% of hunters, and ATVs are used by 16% of hunters. By comparison, only 50% of hunters identified walking as their access method of choice. 19 The significance of closures on public lands is also specifically identified in this research, which identified that 56% of hunters specifically cited restrictions on motorized access and 54% identified closures of public lands by government agencies as significant issues for hunters. ²⁰

The funding streams secondarily impacted by hunters and suitability decisions are specifically of concern as hunting participation has been declining significantly over the recent few years and removing factors that were contributing to the declining participation was the basis of the entire NSSF report. This report specifically concluded that a lack of access to hunting opportunity was the largest addressable issue for land managers to address and improve hunter retention. Significant closures to multiple use routes in the Proposal area in the manner proposed will not improve access for hunters, and will over the long term reduce funding available for wildlife management. Reducing access to areas which are suitable for multiple use will only compound the changes and impacts to these secondary management issues.

6. There is a long history of user conflicts in planning area, and the specific assertions of these concerns have consistently been found unwarranted upon further review.

COHVCO feels compelled to address the long history of alleged user conflicts that appear to be a major factor in the development of the Proposal. COHVCO believes this history is highly relevant to the underlying merit of any valid claims of conflict made and the possibility that any closures could resolve these concerns or avoid the Proposal being legally challenged by those opposed to multiple use access. It is COHVCOs position that site specific closures will never resolve many of these asserted conflicts and that any management efforts in the Proposal area have always found the USFS in court defending challenges to decisions. COHVCO vigorously assert this litigation is not the basis for additional closures, as such efforts will never be found sufficient to those opposed to multiple use. To effectively defend this litigation will require a well reasoned and defendable decision for the management of this area that both is legally defendable and works toward long term resolution of conflicts. It is COHVCOs position that much of this opposition is from a small, well financed group who is simply opposed to all motorized activity on public lands and does not reflect the true cross section of users of public lands in the planning area. COHVCO has consistently sought to partner with the USFS to develop reasonable decisions that reflect all users interests in the climate that has resulted from on going legal challenges.

COHVCO respectfully submits that the USFS must conduct basic review and confirmation of input from asserted groups to insure the basis and viability of the input as there appears to be basic flaws in the legal basis for this input. Many of our members attended the public meeting in Rico in January to address this proposal and were surprised to see a small vocal group from the Rico Alpine Society present at the meeting. The presence of the Rico Alpine Society (“RAS”) was surprising as RAS was disbanded by the Colorado Secretary of State in 2012 and then voluntarily disbanded in 2014.21 COHVCO believes the disbanding of RAS indicates several factors relevant to the Proposal, such as there not being a significant degree of user conflict in the area. COHVCO respectfully submits that if there was anything near the user conflict asserted by those opposed to multiple use access, this user conflict would be sufficient to support the continued existence of a volunteer non-profit organization to address these issues and would have weighed heavily against disbanding the RAS. COHVCO submits that if there were conflicts at the level asserted by those opposing multiple use recreation, disbanding an organization would have been completely unacceptable to its members. It is COHVCO position that any comments from RAS must be viewed with this Organizational history in mind.

COHVCO is also aware of questions from our members regarding possible input from the Town of Rico seeking a non-motorized buffer around the Town of Rico. Several local businesses and members in the Town of Rico are concerned regarding the lack of public input in such a position. COHVCO is aware that the town maintains a non-binding consulting agreement/MOU with the USFS. COHVCO is concerned that a non-motorized buffer on USFS lands directly conflicts with the newly adopted RMP for the area. COHVCO would note that such a non- motorized buffer area would conflict with the Rico Regional management plan which was developed with significant public input, which provides as follows:

“Trails Goal C: Establish and Maintain a Regional Trail system for a broad range of outdoor recreational activities…. The Rico Regional Master Plan depicts four separate general trail designations, including: (1) motorized recreation on existing mining roads and Forest Service jeep roads, (2) non-motorized wide trails on existing historic mining roads, (3) narrow single track trails that exist and/or are recognized by the U.S. Forest Service as part of their trail system, and (4) future planned narrow single track trails.”²²

The Rico regional development plan specifically states that Town lands should be relied on for the development of any buffer areas from usages on USFS lands that might be necessary on a site specific basis.

COHVCO is aware that there has been years of opposition to any USFS actions that might maintain or improve multiple use access of all types or mitigate site specific issues that may exist in the Proposal area. The Organizations do not believe the Proposal can effectively mitigate these issues, as all previous USFS efforts have been found insufficient and the basis of further opposition. This longstanding opposition has resulted in a significant number of onsite reviews, analysis and alteration of funding proposals and management plans. This onsite analysis has almost unanimously concluded that the input from those philosophically opposed to multiple use was without any merit. While there is a long history of this occurring, we do not believe a complete review of each issue is warranted. Rather a brief summary of the most recent review of the Calico Trail reconstruction grant exemplifies our concerns. The Calico trail reconstruction grant that was submitted to the Colorado Parks and Wildlife OHV grant committee in 2013. Opposition submitted to the Commission made many strong accusations of impacts from reconstruction of the Calico Trail and resulted in an onsite inspection of the area. Much of the opposition was based on the term of turnpike in relation to trail reconstruction, which was incorrectly asserted to be an attempt by the USFS to develop a freeway through public lands. Turnpiking of routes has a long history of effectively mitigating resource issues such as water runoff by hardening of trails and strengthening of trail shoulders. This onsite review found that these allegations were completely without merit and opposition to this project continued despite attempts to mitigate concerns raised in comments through the education of the non-motorized community.

COHVCO must also address the Rico Delores lawsuit brought by the Backcountry Hunters and Anglers even though this lawsuit is more extensively discussed in the TPA comments that are being submitted in conjunction with these comments. This lawsuit again uses broad and non- specific assertions of impacts to challenge most multiple use routes in any area possibly classified as a wildlife habitat areas, in a manner that is strikingly similar to the input received on many other proposals. This lawsuit was dismissed by the court on the merits when BCHA moved for an injunction as part of preliminary motions. COHVCO is aware that any court dismissing a lawsuit on the merits when a party is seeking an injunction is somewhat unusual, and always speaks volumes to the merit of the underlying claims in the action. In a somewhat frustrating turn of events many of the same routes that were unsuccessfully challenged in that lawsuit are now proposed to be closed in this travel plan. COHVCO doubt any efforts in the Proposal to mitigate user conflicts will speed any final resolution of opposition to multiple use access, however such a course of action fails to properly weigh the actions of COHVCO and TPA in intervening in the action in support and defense of the previous decisions made by the USFS.

7a. Winter/Fall Creek Trail

COHVCO is submitting this portion of the comments as a supplement to the site specific comments that are being submitted by the San Juan Trail Riders and PAPA. These comments are not submitted in a manner to provide an exhaustive catalog of all concerns regarding closures. The closure of the Winter/Fall Creek trail is based on it being difficult to maintain and possible conflicts of multiple use with an easement crossing an old mining claim that was allegedly provided for quiet use. This route provides a long and high quality single track riding experience in the planning area that is significantly valued by multiple use users. COHVCO completely understands that some routes are difficult and expensive to maintain. Often rerouting these trails can effectively reduce long term maintenance costs and funding for such actions can be obtained through grants provided by the CPW OHV grant program.

A review of Proposal also notes concerns regarding possible violation of an easement across a mining claim by the Winter Trail The Organizations have significant experience with easements granted to or purchased by the USFS, as often these rights are questioned by subsequent purchasers of lands the easements are crossing. It has been COHVCO’s experience that the USFS simply will not purchase or accept easements that require significant limitations on possible USFS usage of easements for the benefit of the public. Most easements obtained by the USFS are exceptionally deferential to USFS management and often the USFS pays a premium to the landowner for the broad scope of the easement provided. Given this general policy of the USFS, COHVCO must question any asserted limitations on the scope of the easement relied on for the Winter Trail as this interpretation directly conflicts with all other USFS actions regarding easements. COHVCO believes this easement must be specifically provided in the proposed EA to allow for public review of this document. COHVCO is opposed to any self-serving assertions from landowners regarding an implied limitation on access in an easement after the USFS has paid a premium for the broad management scope and public access that is normally obtained.

7b. Wildcat Canyon Trail

COHVCO is very concerned that the asserted basis for the closure of the Wildcat Canyon trail is a perceived conflict between motorized trail use and a grazing permitee. The Proposal reflects this issue as follows:

“Wildcat Trail currently allows motorcycle use on the upper half of the trail. This situation is confusing to riders and trail conditions along portions of this trail are not conducive to safe riding. In addition, successful distribution of cattle across the Tenderfoot Allotment depends on the grazing permittee’s ability to herd cattle to desired locations and hold them until ready to move to the next pasture. Motorcycle noise can affect the herds movements. Thus, the trails are a key part of the herding requirement in this allotment.”²³

While there is limited research available specifically addressing the comparative impacts of a motorized trail vs a nonmotorized trail on grazing animals existing research on wildlife provides:

“The most common interactions reported in the literature that we reviewed between nonmotorized trails and focal wildlife species were displacement and avoidance, which altered habitat use, and disturbance at a specific site during a critical period. The interactions of the focal species and motorized or nonmotorized trails were quite similar.”²⁴

COHVCO will note that recreational impacts to wildlife are an issue that has been heavily researched in the Yellowstone National Park for an extended period of time. This research has uniformly concluded:

“Based on these population-level results, we suggest that the debate regarding effects of human winter recreation on wildlife in Yellowstone is largely a social issue as opposed to a wildlife management issue. Effects of winter disturbances on ungulates from motorized and non-motorized uses more likely accrue at the individual animal level (e.g., temporary displacements and acute increases in heart rate or energy expenditures) than at the population scale. A general tolerance of wildlife to human activities is suggested because of the association between locations of large wintering ungulate herds and winter recreation. Habituation to human activities likely reduces the chance for chronic stress or abandonment of critical wintering habitats that could have significant effects at the population level, especially when these activities are relatively predictable.”²⁵

Given that grazing animals are FAR more acclimated to human activity than wildlife, COHVCO submits that closures to minimize grazing animal activity would simply be ineffective and not based on best available science. COHVCO vigorously asserts that any other issues surrounding the Wildcat Canyon Trail can be resolved with educational materials.

7c. Ryman Creek

COHVCO respectfully asserts that alternatives for reroute of this important trail must be explored.

7d. Burnett Creek Trailhead

COHVCO would like the preferred alternative for the Proposal area to include possible development of the Burnett Creek Trailhead In the preferred Alternative of 2009 EA should be included in new proposal as intent was to avoid user conflicts.

8. Trail widths should permit all users to have high quality recreational experience.

COHVCO is concerned that the Proposal seeks to expand all OHV routes in the Proposal area to a width of 62 inches. The Proposal summarizes this change as follows:

“In the Rico-West Dolores area, all OHV trails are being proposed to be 62 inches wide to allow for use by side-by-side UTVs. This will apply to all OHV trails in this analysis area, including the Willow Divide OHV Trail.”²⁶

COHVCO believes there is sufficient ATV usage in the Proposal areas to warrant a dedicated trail for ATV usage to be maintained. An ATV width trail provides a different and often better recreational experience to ATV users, which is often highly valued by ATV users as any ATV width routes are somewhat difficult to locate. While this standard does accommodate ATV usage, COHVCO believes there are sufficient routes in the Proposal area to provide quality recreational experiences to both ATV and UTV users.

Conclusion

COHVCO vigorously support any new trails that are to be opened in the Proposal, such as the loop adjacent to FR533. It is COHVCO’s position that the public lands within the Proposal area provide recreational opportunities that highly valued by the single track motorized community due to large scale closures of single track trails in areas outside the planning area.

COHVCO is concerned that after a review of the management history of the Proposal area that the area has been repeatedly analyzed for a variety of management changes, and these management analysis have repeatedly declined to expand quiet usage of the area. These recent management reviews include determinations that the area was not suitable for upper tier roadless area designation, was not eligible for management for Wilderness Characteristics and was suitable for motorized recreation. COHVCO is very concerned that even with the clarity of recent landscape management analysis that the Proposal provides for a significant decline in motorized recreational opportunities. While COHVCO appreciates new routes in the Proposal, these are simply not sufficient to offset lost routes. COHVCO is vigorously opposed to the closure of any trails as part of the Proposal. It is COHVCO’s position that many of the closures are not based on best available science.

Please feel free to contact Scott Jones, Esq. at 518-281-5810 if you should wish to discuss these matters further or if you should wish to have further information regarding these concerns.

Sincerely,

Scott Jones, Esq.
Authorized Representative of COHVCO

1 See, USFS National Visitor Use Monitoring data; Round 3 at pg 9.

2 See, San Juan NF RMP (September 2013) Appendix V at map 21.

3 See, SJNF RMP FEIS (September 2013) at pg 382.

4 Proposal at

5 See, 2013 SJNF RMP FEIS Appendix V maps 65 & 66

6 See, Colorado Roadless Rule §294.41 – Federal Register Vol. 76, No. 73 / Friday, April 15, 2011

7 A complete version of the Colorado Roadless Rule Alternative 2/final map is available here. A comparison of Alternative 2 and Alternative 4 for possible upper tier designations is available here.

8 See, CPW Groundhog Mule Deer Herd Management plan D-24; March 2014 pg 10.

9 See, Hughes River Watershed Conservancy v. Glickman; (4th Circ 1996) 81 f3d 437 at pg 442; 42 ERC 1594, 26 Envtl. L. Rep 21276

10 See Western Governors Association report; A snapshot of the Economic Impact of Outdoor Recreation; prepared

by Southwick and Associates; July 2012 at pg 1.

11 See, Western Governors Association; Get out West Report; Managing the Regions Recreational Assets; June 2012 at pg 3.

12 See; White and Stynes; Updated Spending Profiles for National Forest Recreation Visitors by Activity; Nov 2010 at pg 6. A complete copy of this document has also been provided for your reference with these comments.

13 See, USDA Forest Service, Rocky Mountain Research Station; The Southern Nevada Agency Partnership Science and Research Synthesis; Science to Support Land Management in Southern Nevada; Executive Summary; August 2013 at pg 38.

14 See, Carothers, P., Vaske, J. J., & Donnelly, M. P. (2001). Social values versus interpersonal conflict among hikers and mountain biker; Journal of Leisure Sciences, 23(1) at pg 58.

15 Norling et al; Conflict attributed to snowmobiles in a sample of backcountry, non-motorized yurt users in the Wasatch –Cache National Forest; Utah State University; 2009 at pg 3.

16 See, Western Governor’s Association Get Out West Report 2012 at pg 5.

17 See, National Shooting Sports Foundation; 2011; Issues relate to hunting access in the United States: Final Report; Accessed December 4, 2013; www.nssf.org at pg 7. (hereinafter referred to as “NSSF report”)

18 See, NSSF Report at pg 3-4.

19 See, NSSF report at pg 56.

20 See, NSSF report at pg 113.

21 COHVCO has attached a copy of the Colorado Secretary of State’s website report regarding the history of the RAS.

22 See, Town of Rico Regional Master Plan adopted August 18, 2004 at pg 28.

23 See, Proposed action at pg 19.

24 See, Gaines, Singleton, and Ross; Assessing the Cumulative Effects of Linear Recreation Routes on Wildlife Habitats on the Okanogan and Wenatchee National Forests ; pg iv.

25 See, US Park Service; White and Davis; Wildlife response to motorized recreation in the Yellowstone Park; 2005 Annual report; at pg 15.

26 See, Proposal at pg 6.

Can OHV tourism save our trails from closure?…

YOU BET IT CAN!

TPA funded OHV Tourism education as an experiment in 2010. As we approach the end of 2014, it is now a critical strategic weapon used by the TPA in the ongoing battle to save OHV trails from closure.

OHV Tourism has a simple 3 part strategy:

• OHV tourism is a proven money maker. (A minimum of $100 spent per day per OHV.)
• Rural Colorado communities are in a recession but there are excellent OHV trails nearby.
• TPA encourages rural Colorado to embrace OHV tourism to save their towns and our trails.

Rio Blanco was the first county to fully embrace the notion of OHV tourism and has been the role model for other communities across the state.

TPA consulted directly with Rio Blanco County and together developed this three part strategy:

• Passed an ordinance allowing OHVs to use county roads for access to towns and trails.
• Developed partnerships with city, county and federal agencies to endorse OHV tourism.
• Attained funding to design, develop and market an extensive OHV trail system.

The Wagon Wheel Trail System is now fully operational in Rio Blanco County.  OHV enthusiasts can unload their off road vehicles anywhere in the county, ride the extensive trail network, ride into towns for gas,  groceries and lodging and never load their vehicle back on a trailer.  Rio Blanco has felt the positive economic impact and is now a strong advocate to keep OHV trails open in order to keep those OHV driven $100 bills flowing into their county.

As of 2014, TPA has consulted with multiple communities across Colorado who have “seen the light” and are developing OHV tourism strategies to help save their communities from economic collapse.  This is a list of other communities working with TPA to build their own OHV tourism strategies.

Clear Creek County – TPA is consulting with the county regarding development of a master plan including an OHV park and connector trails in the I70 corridor between Idaho Springs and Georgetown.
Teller County – Cripple Creek is engaged with TPA to determine how to best develop an OHV park and connect nearby communities to leverage OHV tourism.

Lake County – Passed an ordinance allowing OHV usage of county roads.  Designed developed and implemented an OHV park near Leadville.

San Juan County – Silverton has passed an ordinance allowing OHVs to travel county roads to the adjacent USFS trail system. TPA continues to consult with town officials on OHV tourism.

Hinsdale County – Lake City attained a temporary permit allowing unlicensed OHVs to access county roads.  Results were very successful and they are now working with TPA to develop an official OHV tourism strategy.

Mesa County – Passed an ordinace allowing OHV usage on county roads.  Collbran is now working with TPA  to develop an OHV tourism strategy.

Rio Grande County – Passed an ordinance allowing OHV usage on county roads in the town of South Fork.  Discussions continue with TPA to determine how to best deploy an OHV tourism strategy throughout the county.

All of these counties now clearly understand the positive economic impact of OHV tourism and they have become strong advocates to keep public lands open to save our trails…and their communities.

Rather than depend solely on OHV enthusiasts to fight to keep trails open, TPA is rallying rural Colorado as a “force multiplier” in the battle to keep public lands open for OHV travel.

Thanks to the many other organizations and individuals who donated their time and money, 2014 was a very productive year for Ride with Respect.

While most of our resources went to trail work, we also focused on a few education and advocacy projects to promote responsible recreation. This scope of work was made possible by the generosity of OHV riders as well as continued support from Grand County, Utah State Parks, the Colorado Trails Preservation Alliance, and the Yamaha Outdoor Access Initiative. (I know, the attached picture has an orange bike, but the rider has since traded it in for one of those new, blue 250F’s.) If you have yet to contribute, there’s still time to send a tax-deductible check to Ride with Respect at 395 McGill Avenue in Moab, Utah 84532.

WHITE WASH – In the “Dubinky” riding area, RwR’s trail crew began with some finishing touches on last year’s projects. First, although vandals knocked down many fences that had kept riders on the designated route through Dead Cow and The Tubes, we were quick to build stronger fences with better explanations for restoring riparian areas. Second we opened the reroutes of three steep hills along Enduro Loop, and followed up to ensure that the new routes properly settle in. These projects were featured in a recent edition of Discover Moab.

Then we moved on to three more reroutes of Enduro Loop (see bottom picture in PDF), including one section that’s shared with ATV riders south of White Wash. In each case, the new routes are loose, but will develop into flowing trails that riders are likely to prefer. More so, they’ll make it a lot easier to defend access in future. In planning the reroutes, BLM did all the environmental clearances, and provided all the necessary supplies. This partnership creates a joint buy-in that ought to support Enduro Loop for generations.

LA SAL’S – In the mountains above Moab, we maintained the trail system at Upper Twomile, and installed a couple more cattle guards that were provided by SITLA. On USFS land, we installed several rolling dips to properly drain an ATV trail near Black Ridge (see top picture in PDF). This is one of three areas where RwR was able to borrow a mini dozer from Utah State Parks. The agency’s OHV program loaned the machine, transported it, and trained Dale Parriott and me to operate it. This is a good example of where your money goes when registering an OHV in Utah.

SOVEREIGN TRAIL – Our work on Sovereign Trail consisted mostly of maintenance (see middle picture in PDF) and planning for trail use and nearby camping with the Utah division of Forestry, Fire, and State Lands. In December, a large boulder blocked the north end of Sovereign Singletrack. It could’ve been broken up and cleared out of the way, but above it are more boulders that could roll into the same spot. Fortunately several more contributors stepped up to route the trail away from the unstable area for good.

EDUCATION – One cost of Moab’s strong tourism industry is more traffic on the trails. On top of that, some machines have gotten larger, faster, and more user-friendly for people who are new to the backcountry. To foster safe and courteous use of trails, Tread Lightly produced customized posters of its Ride On Utah campaign. So far RwR has distributed a dozen of these posters to OHV-related businesses in Moab. In addition to riding on designated routes, they encourage reducing your speed, sound, and dust when passing fellow trail users to leave a good impression.

To guide the land managers in providing diverse recreation opportunities while conserving natural resources, a new book is being produced by the National OHV Conservation Council (NOHVCC). As one of several reviewers, I volunteered forty hours to provide feedback for the author. The final draft should establish a practical framework for land managers all over the world. In the meantime, NOHVCC helped produce a great educational video for OHV riders. Contact the Montana Trail Vehicle Riders Association if you’d like to utilize this video in your state.

ADVOCACY – From 2012 you may recall that U.S. Congressman Rob Bishop turned to county governments for his Eastern Utah Public Lands Initiative (EUPLI). The local input would help craft a bill that could benefit all stakeholders. It has the potential to provide stability for various industries and conservation interests. Since RwR has invested over ten-thousand hours toward trail infrastructure on public lands, we have participated through Grand County in EUPLI. We began the year with trips including one to the state capital at the invitation of BlueRibbon Coalition.

Soon our attention returned to Grand County, where public meetings allowed residents to vent their frustrations about the current state of public lands: Moab Times article.

Fortunately the county followed up with more constructive meetings, and RwR participated in a working group on the Big Flat and Labyrinth Rims area, which includes White Wash. Ultimately the county council incorporated many interests into a win-win proposal. We hope that the new county council will honor this work when making recommendations to Rep. Bishop.

MOAB RENDEZVOUS – Next year there will be a new way to support RwR. From April 16th through the 19th, the Rocky Mountain Adventure Riders will host its first Moab Rendezvous event for any kind of motorcyclist who likes to get dirty: www.rmariders.org
The group is permitted to lead rides on trails from the wide-open Lockhart Basin to the tight and twisty Sovereign Singletrack. I will be there to assist the event hosts, as most of the proceeds will go directly to RwR. Fifty riders have already signed up, but there’s room for more. The Moab Rendezvous will surely be the most fun way to support trails and their surroundings.

Although there’s a lot to prepare for, winter forces us to slow down and reflect. I am grateful for the widespread support of RwR, which is a tremendous team effort. Here’s to health and happiness this holiday season.

Clif Koontz
Executive Director

Ride with Respect
395 McGill Avenue
Moab, UT 84532
435-259-8334
501(c)(3)

From DirtRider:
What better way to promote and discuss trail preservation than on a week long trail ride? The Colorado 600 is just that. Unfortunately, it is an invite-only event. Fortunately, we brought along a camera to capture some of the action…

Check out the video here: www.dirtrider.com