Archive | March, 2015

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.