Sand Hollow Land Swap Comments

Our friends in Utah need your help. Comments on the Sand Hollow BLM Land Swap are open until April 19th. If you have not commented on the proposal yet, follow our information below to make your voice heard.

1. - Watch the Video

2. - Copy this email address into your email generator, blm_ut_sgfo_comments@blm.gov

3. Type your personal info, ask questions of the BLM, and give them specific recommendations for this project.

4. Hit SEND to help everyone fighting in Utah!

The Gulches Litigation Has Been Filed

Motorized Recreationists Challenge Pike San Isabel NF Travel Plan

By Patrick McKay

Patrick McKay is a board member of Colorado Offroad Enterprise (CORE) and Colorado Offroad Trail Defenders.

In September 2022, the Pike San Isabel National Forest (PSICC) in Colorado published the long awaited final decision for its controversial new travel management plan. The final decision closed approximately 123 miles of currently open motorized routes, plus multiple other routes that were temporarily closed under previous actions that will now be permanently closed. While this amounted to only a 4% net reduction in total open route mileage, these closures were disproportionately concentrated in the three ranger districts closest to the front range cities of Denver and Colorado Springs and affected several of the most popular four-wheel-drive trails in the forest. Some of the closed routes had been featured in published guidebooks and regarded as destination trails for decades, yet the Forest Service deemed them to have no recreational value and closed them. As a result, the quality of motorized recreation opportunities in the region has been severely diminished.

The motorized recreation community in Colorado is extremely disappointed with this outcome and feels that our interests were almost completely ignored throughout the entire travel management process, which was driven from the start by extremist environmental groups and anti-motorized activists within the Forest Service itself. The Forest Service based its route designation decisions solely on inaccurate data that was gathered without public input in the 2015 Travel Analysis Process and on secretive ranger district input that was never disclosed to the public. All public comments that challenged the factual assumptions underpinning the forest’s analysis were ignored. While motorized advocates managed to save a handful of minor trails through the objection process, the Forest Service dismissed the majority of our objections regarding the most popular trails subject to closure. We were left with no choice but to challenge this flawed decision in court.

On February 14, 2023, Colorado Offroad Enterprise (CORE), of which I am a board member, filed a lawsuit challenging the forest’s decision to close 12 specific road segments. The complaint primarily focuses on five roads in Wildcat Canyon along the South Platte River, as well as seven other roads in the Kenosha Pass, Fairplay, and Rampart Range areas. You can download the complaint here and all exhibits filed with it here.

Our lawsuit is only the latest chapter in the long running controversy over the roads in Wildcat Canyon, the history of which I have described in a past blog post here. It is sad it has even come to this, as this situation was supposed to have been resolved back in 2004, when the Forest Service issued a decision allowing these roads (which had been temporarily closed since the Hayman Fire in 2002) to be reopened under county jurisdiction.

That decision was intended to be a compromise that would allow motorized users to continue using these popular trails while ensuring that they would be maintained to avoid negative impacts to the South Platte River. While easements were quickly granted for the roads in Teller County, the ink on the decision was barely dry before a group of activist staff within the South Park Ranger district (including the current district ranger) began working to undermine the deal. They delayed and ultimately thwarted its full implementation by convincing the Park County government to withdraw its application for an easement in 2015, after the South Park Ranger District had stonewalled it for seven years.

The result was that only half of the Wildcat Canyon trail network was reopened, while the other half in Park County remained closed, with its two major loops severed. While the roads in Teller County were well-maintained by motorized groups, the roads in Park County deteriorated because the Forest Service refused to allow any maintenance on them while their status was in limbo, even though they continued to be regularly driven by members of the public who were unaware they were closed at the county line. Those negative impacts were then cited as reasons to decommission the routes in the travel management process.

As documented in our lawsuit, the same activist Forest Service employees worked to keep the forest from conducting any NEPA analysis on reopening the roads in the travel management process, ensuring that the ultimate decision to decommission them was predetermined. They also made multiple attempts to illegally decommission and obliterate the roads while the travel management process was still pending, being stopped only when other Forest Service employees pointed out their plans were unlawful. In the words of one such employee, “If our leadership wants to know why the motorized community does not want to cooperate with the forest service, this is a great example of why they don’t trust us. I don’t blame them for their outrage.”

One of the central themes of our lawsuit is the way the Forest Service abused the Travel Analysis Process (TAP) to generate unsupported and blatantly false route data which was then used to determine route designations in the travel management process with no public input allowed. According to both Forest Service policy, the Travel Analysis Process is supposed to be a separate process from travel management. It is intended to generate baseline data that can be used to inform future travel management processes, not dictate their outcomes. Forest Service policy requires rigorous public involvement in both stages of the process, and specifically requires that the public be allowed to be given input in actual route designation decisions.

In the case of the Pike San Isabel National Forest, each ranger district produced its own travel analysis report around 2015, in which they assigned a range of risk and benefit scores to each route segment evaluated. These scores, which included things like recreational use benefit and wildlife risk, were based largely off of GIS data and the personal knowledge of district staff. These scores were later run through a formula to determine the ultimate designation of each route in the travel management process, with high value routes being retained as part of the “minimum road system” and low value routes being closed.

Each travel analysis report was subject to a 30 day public comment period which was not widely publicized and received only a handful of comments, in contrast to the thousands of comments received during each of the comment periods for the travel management process. Because of the forest’s failure to seek the input of motorized recreationists who actually use the trails, the many inaccuracies in the travel analysis reports were only discovered during the travel management process. Yet the forest chose to ignore all public comments challenging route designations based on inaccurate travel analysis scores, stating that decisions based on the TAP scores were not open to revision. Moreover, any route-specific recommendations included in the TAP reports by ranger district staff were automatically adopted in the preferred alternative regardless of their merit, and all public comments calling for different outcomes were ignored.

As argued in our lawsuit, the PSICC essentially treated the TAP reports as a dispositive travel management decision rather than a preliminary information gathering step, and then attempted to unlawfully “tier to” those documents to avoid having to conduct any real NEPA analysis of the impacts of individual routes in the travel management process. District staff were able to use the TAP scores and recommendations to largely predetermine the outcome of the travel management process, in blatant violation of NEPA and Forest Service policy. In the case of the roads in Wildcat Canyon, activist district staff manipulated the process by giving the roads blatantly false recreational benefit scores, ranking them as low benefit despite explicit findings in two prior NEPA processes that these roads had extremely high recreational value. Most of the other roads cited in our lawsuit were likewise given absurdly low recreational benefit scores, dooming them to unjustified closure.

The proper way for forests to determine their “minimum road system” (MRS) as required by the Travel Management Rule has always been a murky question with no clear answer. The PSICC claimed in its decision that the MRS was essentially determined by the TAP, even though Forest Service policy states that it is determined by the travel management process. Should our case go to trial, it will be (to the best of my knowledge) the first time the extent to which the travel analysis process can be relied upon for travel management has ever been litigated.

We believe it is clear that the PSICC violated NEPA and NFMA in multiple significant ways, not the least of which involved road closures in Wildcat Canyon that the forest itself had previously determined would violate the forest plan. As we know from internal emails we received, even some Forest Service employees considered the shenanigans the forest was trying to pull regarding some of these roads shameful.

I’m interested to hear the thoughts of people in this community on the forest’s actions here. The underhanded way in which certain activist employees were able to rig the process to close a number of highly prized motorized trails should be concerning to all. Legalities aside, the forest’s actions have caused a total loss of trust within the motorized community that will make it considerably more difficult for them to obtain our cooperation in the future.

Land Use Comments

Public Land Projects with public comment periods have been numerous this year, and we have tried to submit comments to represent our members and sponsors in the Western States. You can view many of the comments we were part of this past summer by clicking the button at the bottom of this post.

We submitted comments for Black Canyon Corridor, Johnson Hill, Moab Camping Plan, Chaffee County Camping Plan, USFS Wolf Management 110J, Labyrinth Rims/Gemini Bridges, and the Wildfire Response and Drought Resiliency Act. #keeptrailsopen

Help Save Moab Trails!

What’s going on?

Ride with Respect, Trails Preservation Alliance, and Colorado Off Road Enterprise urge you to weigh in so we don't lose out!

Read the following alert and watch the video below!

The Bureau of Land Management (BLM) Moab Field Office has released a Draft Environmental Assessment (The Proposal) for its Travel Management Plan (TMP) covering all motorized routes between Moab and Green River, Utah that could close 40% of what is currently open to motorized use. Proposed closures include all of Dead Cow Loop (The Tubes), parts of Enduro Loop, Brian's Trail (top of White Wash), Gold Bar Rim, Golden Spike, Rusty Nail, Tenmile Canyon, Hey Joe Canyon, Hell Roaring Canyon, Mineral Canyon, Tusher Wash, and the route between Monitor and Merrimac buttes to name a few!

The Labyrinth Rims/Gemini Bridges planning area is surrounded by national parks, wilderness study areas, and the new Labyrinth Canyon Wilderness just across the Green River. Within the planning area, the 2008 TMP inventoried ~1,900 miles of routes and closed ~800 miles of them, leaving ~1,100 miles open today, which the Draft TMP calls Alternative A. Volunteers (including local groups Ride with Respect, Moab Friends For Wheelin’, and Red Rock 4-Wheelers) have spent tens-of-thousands of hours implementing and refining the 2008 TMP in this area. A 2017 settlement agreement requires the BLM to revisit the 2008 TMP in this area, and expressly allows the BLM to add routes, but the agency has chosen not to consider adding even a single mile of route in The Proposal despite that motorized use of the area has roughly doubled since 2008. 

It is widely agreed that the BLM should extend the comment deadline because some of its maps were inaccurate at the outset of The Proposal, but the following figures are accurate within a few miles:

  • Alternative A would leave open 1,057 miles to all uses and 71 miles to ATVs and/or motorcycles. 

  • Alternative B would close 438 miles and place new restrictions on another 13 miles.

  • Alternative C would close 168 miles and place new restrictions on another 50 miles.

  • Alternative D would close 53 miles and place new restrictions on another 30 miles.

It’s worth noting some closures proposed in Alternative D are reasonable, but others have current and future value to leave open despite the appearance of low use. Southern Utah Wilderness Alliance (SUWA), which seeks to vastly expand wilderness designation that prohibits all mechanized travel, proclaims “It is vital that the BLM hear overwhelming public support for Alternative B,” an alternative developed at the request of all Grand County commissioners. Therefore it’s vital that the BLM hear our overwhelming OPPOSITION to Alternative B as it (and even parts of Alternative C) would devastate motorized recreation and offer no significant benefit to non-motorized recreation or natural resources.

How to comment effectively.

To comment substantively on The Proposal, include these points in your own words.

Tell the BLM about yourself:

  • Who you are, where you’re from, what activities you enjoy in the Labyrinth Rims/Gemini Bridges planning area, and how much money you spend locally when visiting (dining, recreational equipment, hotels, fuel, etc).

  • Emphasize if you are a multi-use recreationist. Include all the activities you enjoy in the area, and what characteristics you look for in a route. 

Examples: floating Labyrinth Canyon by raft or canoe, riding your dirt bike on Dead Cow, 4WD on Hey Joe, mountain bike on the Magnificent Seven.

  • The variety of benefits that the area’s motorized routes provide to you. (exercise, thrill seeking, skill building, family time, connection with nature, etc.). 

  • That you support the comments submitted by local, state, and national groups (RwR, CORE, TPA etc).

Then ask the BLM to:

  • Support Alternative A.  In 2008 the TMP closed over 40% of inventoried routes plus around 200 miles of non-inventoried routes, thereby balancing motorized recreation with non-motorized recreation and natural resources. This is especially worth noting given the significant amount of non-motorized opportunities that surround this planning area.

  • Recognize that the State of Utah is increasing its support of trail work, education, and law enforcement in the planning area.  The new DNR Division of Outdoor Recreation is hiring staff to do more trail work and enforcement patrols specifically in southeast Utah. Further, Utah’s new Off-Road Vehicle Safety Education Act will require (a) all OHV operators to complete an education course, (b) all ATVs to display license plates for easier identification, and (c) vehicle operators who are convicted of going off-trail to repair their damage through community service. With these additional resources, the BLM will be able to effectively implement alternative A and resolve any issues with the status quo.

  • Take an educational approach to reduce recreation conflicts.  Separating trail uses is appropriate to some degree, but additional closures should be thoughtfully evaluated. The BLM should promote education and trail etiquette efforts before resorting to hundreds of miles of closures, especially considering the recent surge in users who are new to backcountry trails. In addition, the promotion of tolerance among diverse recreationists will help alleviate user conflicts.

  • Protect wildlife by gaining full compliance with the current TMP. Wildlife enhances all recreational experiences. To effectively improve wildlife habitat, the BLM should focus on the enforcement of existing closures rather than expanding closures and adding to the burden of implementing and enforcing them. 

  • Fully value the economic contribution of motorized trail use.  The Proposal lacks evidence for its assumption that all types of visitors spend similar amounts of money to recreate in the area. Research demonstrates that most motorized trail users spend far more than other recreationists. For example, rental OHVs average $300 per day plus a tax rate of over 18% in Moab while most non-motorized gear rental is under $100 per day, plus a tax rate of under 9%.

  • Recognize that closing motorized trails would decrease positive impacts to the local economy and increase negative impacts to natural resources.  The Proposal lacks a basis for its assertion that only 7,348 visitor days (20 people per day) would be lost annually if Alternative B were chosen. In fact Alternative B and even some routes in Alternative C would result in either (a) far more visitor days lost, (b) far more traffic on the remaining routes which would make them less sustainable, or (c) far more use off of designated routes which would disorganize travel patterns and increase negative impacts.

Finally, make route-specific comments on your favorite trails that are proposed to be closed.  You can see all the routes over aerial imagery or topographic base maps by going to the BLM’s ePlanning site, clicking on “Maps,” and going to the section “Interactive Map.” You can see if it would be closed permanently, closed seasonally, or left open year-round in each alternative by going to the section “Static Map.” Determine the route number (e.g. D1944) to state it in your comments, and use it to look at the BLM’s route report (although it’d require downloading all 650MB of route reports).

To comment online or get more information on The Proposal:

Comment Now!

If commenting online fails, email the comments with the subject line “Labyrinth/Gemini Bridges Travel Management” to:

blm_ut_mb_comments@blm.gov

To comment by postal mail:

Bureau of Land Management 

Attn: Labyrinth/Gemini Bridges Travel Management

82 East Dogwood

Moab, UT 84532

Comments are due on October 21, 2022 so speak up for motorized opportunities today!


Moab BLM is Seeking Input on Three Camping Plans

What's going on?

The BLM Moab Field Office (MFO) released Draft Environmental Assessments for dispersed camping in three areas; Labyrinth Rims/Gemini Bridges, Utah Rims/Sunshine Wall, and Two Rivers. Here is the BLM Press Release.

The MFO plans to limit camping to designated campsites, but they won't let the public review and comment on which sites will be designated open or closed unless you urge them to take this step. The "Labyrinth Rims / Gemini Bridges" planning area extends from Moab northwest through Dubinky Well to Tenmile Point Road, including many of the region's best motorized trails and campsites. The "Utah Rims" planning area extends from the Colorado border (edge of Rabbit Valley) to the Westwater Put-In Road, and contains a high concentration of trails (especially singletrack) and campsites. The "Two Rivers" planning area has several campsites accessible by vehicle, but most are accessed by boat along the Dolores and Colorado rivers upstream from Dewey Bridge. View the map of the planning areas.

Make your comments!

Points to include in your comments:

  • The plans should show the location of all existing campsites and whether they would be designated open or closed so that the public can comment on specific sites.

  • The plans should designate a wide range of high-quality campsites near motorized trail networks that is sufficient to support projected visitation.

  • Designating a high quality and quantity of sites will be critical to preventing the displacement of camping to the surrounding areas.

  • The planning areas should be expanded to cover the likely direction of camping proliferation. Specifically: 

    • Expand the Labyrinth Rims / Gemini Bridges area north to the outskirts of Green River (bounded by the Blue Hills to the east).

    • Expand the Utah Rims area southwest to the outskirts of Cisco (bounded by Interstate 70 to the north).

  • In the meantime, separately approve the other three proposed measures to reduce camping impacts (requiring a portable toilet, fire pan, and BYO firewood), plus more minimum-impact education could be done without delay.

Your perspective:
Sharing your personal experience in your comments will give substance to the content you share and support your perspective!

  • Who you are.

  • Where you live.

  • What you look for when selecting a dispersed campsite (e.g. views, proximity to motorized trails, or solitude from other campers).

  • What you get out of the experience (e.g. connection with family or natural surroundings).

  • What you contribute (e.g. spending on supplies in nearby towns).

Where to make comments

General Comments (all three)

To make general comments on all three planning areas, go here, and click on the “Participate Now” option. Be sure to state that your comments apply to all three.

Two Rivers
If your comments pertain only to Two Rivers, go to the site for Two Rivers.

Labyrinth Rims
If your comments pertain only to Labyrinth Rims, go to the site for Labyrinth Rims.

Utah Rims
If your comments pertain only to Utah Rims, go to the site for Utah Rims.

By Mail
Moab Field Office, Attention: Camping Proposals
82 East Dogwood
Moab, UT 84532.