Archive | April, 2016

Planning 2.0 Comments

Bureau of Land Management, DOI
Director (630)
1849 C Street NW., Room 2134LM,
Washington, DC 20240, Attention: 1004–AE39.

RE: Planning 2.0 comments

Dear Sirs:
Please accept this correspondence as the comments of the above noted Organizations regarding the BLM Planning 2.0 proposal and related initiatives after attended most of the meetings on this Proposal. The Organizations would be remiss if the relationship of the current Proposed Rule and previous versions of the Rule was not addressed, as it is the Organizations position that none of the concerns that were raised in our 2014 comments have been addressed, most troubling of which is the exceptionally limited public input that is being obtained in the process and complete failure to address economic burdens that are being placed on partners as a result of the changes in the planning process.

Prior to addressing the specifics of these concerns, a brief summary of the Organizations is warranted. COHVCO is a grassroots advocacy organization of approximately 2,500 members seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of off-highway motorized recreation throughout Colorado. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations.

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. 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. 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. For purposes of these comments, Colorado Off-Highway Vehicle Coalition, the Trail Preservation Alliance and Colorado Snowmobile Association will be referred to as “the Organizations”.

1. Executive Summary.
The Organizations support many of the principals that are expressed in the Planning 2.0 documentation but after a complete review of the Planning 2.0 documents the Organizations must express some concerns about implementation of the principals to date. Much of the work does not exemplify the principals of the Planning 2.0 Proposal. The principals of the Proposal include: 1. Create a more dynamic and efficient planning process; 2. Enhance opportunities for collaborative planning; and 3: Plan across landscapes and at multiple scales. These are commendable goals, which the Organizations vigorously assert can only be achieved with the application of management on the ground based on an up to date and accurate review of all facets of problems contributing to the management issue sought to be planned for. It has been the Organizations experience that development of high quality balanced plans for any management concern has a long history of resolving management issues in a cost effective and rapid process. Truly resolving the management concerns on the ground must be a long term planning objective and simply must not be overlooked. Developing plans that are never implemented or that are out of date when adopted rarely resolves any management concerns, as limited resources will be diverted away from truly effective management.
The Organizations are very concerned that numerous examples of successful initial steps towards implementing the goals of the Planning 2.0 process provided in the public meetings have fallen well short of furthering the principals identified. More specifically:

1. There has been very limited public outreach on the Proposal despite a desired goal of increasing public participation in planning;
2. NEPA analysis for the Proposal is insufficient and must be expanded;
3. The funding source for the extensive new multi-level planning must be clearly identified as this is a major increase in costs for partners sought to be engaged;
4. Economic analysis of costs and burdens resulting from planning changes is entirely lacking;
5. Statutorily required partner involvement in the Planning 2.0 process appears very limited and has been totally non-existent in many of the examples relied upon;
6. Public comment periods are significantly shortened under the new Proposal despite desire to plan for more issues on larger scales;
7. Much of the landscape level planning to date does not address multiple use requirements and recreational usage; and
8. BLM is seeking to accept citizen science in planning without identifying how that relates to best available science and BLM often relies on badly out of date science instead of clearly identified management documents for the species at the landscape level.

The Organizations vigorously assert these concerns are foundational to achieving the objectives of the Proposal and must be resolved prior to the Proposal moving forward.

2a(1). There has been very limited public outreach for the Proposal and many of related documents have been developed without public input.

The Organizations are very concerned that while BLM is seeking to develop a new national strategy for land management planning, only a very limited number of public meetings have been held to date. This is very concerning by itself. The Organizations must also express concern over the limited public input in the development of the Rapid Ecological Assessments (“REA”) and Landscape Conservation Cooperatives (“LCC”) used as examples of the new planning process. This level of outreach is simply insufficient to meaningfully gain public input on a national level issues and landscape level plans that will be guiding field office resource plans. Often Field Office level plans have significantly more public meetings and opportunities to comment than have been provided on the Proposal to date. As more specifically addressed in subsequent portions of these comments, the complete lack of public and partner input has resulted in some serious foundational flaws in REA and LCC that have been developed to date.

The Organizations vigorously assert that significantly more public outreach must be done, and that these meetings must be held at various times and locations throughout the country. The Organizations do not believe that public meetings held on a Wednesday afternoon are viable for many of the public, especially those in the recreational community. Evening and weekend meetings at numerous geographically diverse locations throughout the country must be provided to allow for full public input to be obtained. Expanded public input will create a far superior and high quality planning process for the BLM to implement moving forward. Webinars may be cost effective but they are not a replacement for in person meetings and discussions.

The Organizations further submit that the planning process appears to be targeting expanded involvement of many partners, including state agencies, wildlife managers, local government representatives and numerous NGO. The Organizations suggest that in person meeting should be scheduled and then a detailed presentation be made with these groups in order to make sure their thoughts and input are obtained. While not all these parties could be met with, a representative sampling who receive a detailed discussion of the goals and objectives of the Proposal could provide great insight and experience into how these groups effectively participate and the challenges that are being faced by these groups currently.

2a(2). Statutorily required partner involvement in all phases of planning must be protected.
The Organizations must note that partner involvement at the Denver meeting was surprisingly limited, which compounds concerns about limited public/partner involvement in the new planning process and over reliance on contractors as a substitute for public input. The meeting was well attended by environmental organizations, but traditional partners who provide ongoing funding and support to BLM, such as State and local government agencies and user groups were almost non-existent. This was very concerning as many of these partners are either required to be involved in the BLM planning process by federal law or as the result of consulting agency agreements that have been signed with BLM. The Winning Challenges document that was the basis for the Planning 2.0 process simply has no partner quotes, and relies on quotes from unspecified DOI employees for a large part of the document. Again, engaging partners is often difficult as many partners and users have exceptionally busy schedules and symbolic gestures do have meaning to these organizations. The impacts of these largely symbolic gestures to partners must not be overlooked.

Expanding collaboration in Planning 2.0 process entails significantly more outreach and engagement of existing partners than is currently proposed and this level of engagement requires more than the limited number of meetings currently provided for and make meetings at times when the public/partners can attend. Experiences with the Sage Grouse planning process have shown that engaging partners will be a major key to success moving forward at the landscape level and often engaging partners was highly site and project specific. The Sage Grouse planning process revealed that there are a wide range of partners necessary for landscape level planning, including state and local government agencies, and private land owners. While DOI is a major land holder at landscape level planning, Sage Grouse planning efforts identified in some habitat areas private lands accounted for more than 50% of the habitat, making full utilization of collaboration of public and private landowners critical. This type of engagement is fluid and highly specific to the particular management issue, as exemplified in the Sage Grouse process where some private lands were highly developed residential subdivisions while other private habitat lands were large ranches which had already engaged in conservation easements for the benefit of the Sage Grouse. Insuring proper partner engagement for a particular project must be a priority and provides concrete examples of how site specific NEPA will not be able to address landscape level changes proposed.

A critical component of any revised planning process must be to repair partnerships that are currently strained as a result of poor engagement previously. It is the Organizations experience that there are many partnerships with BLM that are severely strained for this reason. An example of this strained relationship with historically strong partners would be from Colorado, where many of the BLM field offices have recently completed RMPs, sage grouse planning and a variety of other planning efforts. Many recreational groups are simply tired at this point and question the value of this planning as nothing has changed on the ground. Partnerships between local governments and BLM representatives have also been strained for a variety of reasons as well. An example of this type of issue would be the community development for the Hermosa Watershed legislation (HR 1839) which seeks to remedy significant changes to historical management of BLM lands resulting from “new” policy manuals. The Hermosa Watershed Legislation is sponsored by Rep. Tipton and Senator Bennett and has a long stakeholder process as the basis for the Legislation, including numerous local government representatives and user groups. Throughout this process there was significant frustration expressed regarding BLM failure to address credible community input on issues and often community representatives were relied on to provide historical documentation supporting prior management decisions. After partners provided requested documentation, meaningful discussion did not occur and often the reasoning underlying the need to change these historical management decisions was not provided. Relationships were further strained in the process as BLM representatives were involved in the stakeholder meetings but failed to mention significant management changes in a recently released final version of a resource management plan for the planning area that would have rendered the entire stakeholder process irrelevant. This is not the way to work collaboratively with stakeholders and will result in significantly strained relations with stakeholders moving forward. Attempting to expand future collaboration with these partners would be difficult without addressing these types of historical stressors.

These strained relationships simply must be repaired to insure that planning can be conducted at the landscape level and then carried through to application on the ground. Developing high quality planning that actively seeks to including all partner organizations would be a step in the right direction, and the Organizations are concerned this engagement is not occurring at this point with LCC and REA. Failing to actively engage these partners will only result in further fracturing of already strained relationships.

2b(1). NEPA analysis and fragmented method of plan development.
The Organizations vigorously assert that NEPA analysis of the Planning 2.0 efforts must be significantly expanded as proceeding under just a categorical exclusion violates both NEPA and internal guidance documents of the BLM. The Organizations submit that the experiences of the USFS with the development of their new planning rule are highly relevant to our concerns about the lack of analysis being undertaken by the BLM. The USFS sought to coordinate their efforts and undertake a complete EIS of the new rule and its impacts. Rather than consolidate all issues into a single location and coordinated efforts, BLM has chosen to divide their planning efforts into numerous initiatives, each of which are being treated as a separate unrelated proposal. The cumulative impact of these numerous isolated efforts must be reviewed and streamlined as most decisions will be made under multiple overlapping standards, making the relationships of these standards to each other critical in developing an effective decision making process. An efficient effective process will also foster better relationships with partners, as partners will not be forced to attend repetitive meetings or discussions to address similar issues.

The Organizations would note that any position that the Proposal may continue forward with just a Categorical Exclusion and comply with NEPA planning requirements is internally inconsistent with landscape target of the goals and objectives of the Proposal. Proposed rule provides these landscape level goals as follows:

“The proposed rule would enable the BLM to more readily address landscape-scale resource issues, such as wildfire, habitat connectivity, or the demand for renewable and nonrenewable energy sources and to respond more effectively to environmental and social changes.”¹

The Organizations believe the inherent conflict of the determination that the new Proposal may proceed with only a categorical exclusion is immediately apparent when the goals and objectives of the Proposal are compared to existing guidance documents from the BLM on the necessity to prepare an EIS. This internal guidance documents provide:

“11.8 Major Actions Requiring an EIS.

A. An EIS level analysis should be completed when an action meets either of the two following criteria.

(1) If the impacts of a proposed action are expected to be significant; or (2) In circumstances where a proposed action is directly related to another action(s), and cumulatively the effects of the actions taken together would be significant, even if the effects of the actions taken separately would not be significant,”²

The Organizations submit that these landscape level goals can only be achieved through a significant change in landscape level planning, and when the cumulative impacts of these landscape level changes, such as REA and LCC, the need for expanded NEPA analysis becomes immediately apparent. These levels of planning (REA and LCC) would basically be entirely new and would have a significant impact on a wide range of issues. The lack of factual basis in the BLM position that the Proposal can move forward without an EIS level of analysis is clear when the cumulative impacts of all the separate planning efforts (Renewable Energy, species, recreation) are consolidated.

The Organizations also submit that the position of the BLM that only a Categorical Exclusion under NEPA is necessary to undertake a complete review of their planning rule is simply insulting to partners of all types. It has been the Organizations experience that even small projects or permits, including club rides that occur on existing resources require at least an Environmental Assessment. Many of the partners now alleged to be sought to engaged are involved in multi-year EA type analysis on a wide range of issues and will be working though the EA process as BLM planning simply moves forward with a Categorical Exclusion. The Organizations submit these differences in NEPA application cannot be overlooked and will do little to foster support or partnership for planning efforts moving forward.

The conclusion that NEPA analysis the new BLM planning rule can be supported with only a categorical exclusion simply cannot be reconciled with USFS determinations regarding their new planning rule. USFS immediately recognized the cumulative and significant impacts of their rule and moved forward with a vigorous EIS process to insure public input and review. Given that the new USFS and BLM rule are each moving in the same direction in terms of landscape level planning there should be some level of consistency in the agencies NEPA analysis. Clearly that consistency is not present at this time which indicates a severe issue with one agency determination.

2b(2). The Organizations vigorously disagree with each of the conclusions of the preliminary documentation regarding the propriety of a Categorical Exclusion being sufficient.
The Organizations must specifically and clearly state that the conclusions made in response to the Preliminary Categorical Exclusion trigger questions³ are vigorously opposed, as they clearly lack any factual basis and completely twisting of the purpose and need for the planning efforts. The Organizations submit that the BLM position that subsequent issue or site specific NEPA will resolve possible landscape level concerns around the new Proposal simply lacks any factual basis. The landscape target of the planning efforts will have cumulative landscape level impacts that cannot be addressed in subsequent local or issue specific NEPA. Any localized planning will simply fail to have a large enough scope to address these new levels of planning and the burdens that result to partners.

Our concerns over the responses to various NEPA questions begins with the “NO” response to question #4 which provides:

“4) Does the proposed action have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks?”

The Organizations are entirely unable to understand the basis for this position and our concerns are based on our experiences with the Desert Renewable Energy Conservation Plan in Southern California. Clearly planning for energy development at this level has never been undertaken previously and widespread use of this type of large level planning could have impact on numerous issues, the least of which could be economic impacts to local communities. The DRECP process identified issues and concerns for a wide range of issues and developing a process to create consistency in how partners are engaged and issues are resolved would be exactly the unknown environmental risks that should have triggered a “YES” answer to that question. Application of the lessons from the DRECP process would find numerous uncertain landscape level issues for the Proposal and warrant significantly higher levels of NEPA analysis.

The Organizations believe the lack of meaningful analysis of issues is exemplified by the “NO” response to question #8 which provides:

“8) Does the proposed action have significant impacts on species listed, or proposed to be listed, on the List of Endangered or Threatened Species, or have significant impacts on designated Critical Habitat?”

Again the Organizations must oppose the conclusion reached based on our experiences with the Greater Sage Grouse LUPA process. This level of landscape planning to avoid a listing of a species has rarely, if ever, been undertaken previously. The Organizations have to question how effectively information submitted relative to one Sage Grouse LUPA was conveyed to other planning areas LUPA, and influenced many of the issue specific management concerns raised. These are the type of landscape level issues that could impact a species proposed to be listed that should have triggered a heightened level of NEPA to insure that processes necessary to convey best available science were in place.

The Organizations submit that the responses to each of the NEPA trigger questions provided in the BLM analysis document fail to exhibit a basic understanding of the impacts and changes to landscape level issues that are sought to be achieved in the Proposal. The Organizations submit that a meaningful review of these NEPA trigger questions would immediately result in a Categorical Exclusion being found completely insufficient to undertake a complete review of the BLM planning process.

3a. Specific funding for new multi-level planning must be identified.
There is a critical step in the Proposal that has not been clearly addressed to date, mainly how the expanded planning process, and associated NEPA analysis, is going to be funded from inception to completion of on-the-ground projects. This is a critical question that must be resolved. The identification of funding sources for expanded NEPA management/analysis will become more critical with the expansion of multi-level planning in the Proposal, as most of this planning is going to require NEPA analysis. NEPA analysis is often time consuming and expensive, and there appears to be the desire to undertake more of this type of analysis. Simply creating landscape level plans and coordinating these plans with ongoing scientific development will take significant funds, and this funding should not be obtained at the expense of on-the-ground projects. It has been the Organizations experience that identifying funding for any planning or management has been a significant issue for BLM field offices and one that BLM appears to continue to struggle with. Often at the field office level there is simply no funding for a wide variety of issues, and often OHV grant programs provide the overwhelming funding for all multiple use recreation management. While the new planning process may look great on paper, it still must be applied on-the-ground and consistent funding will be a critical component of any effective long term planning.

When questions regarding funding of the new process were posed in the Denver meeting, BLM representatives asserted that the new planning process would be so streamlined and efficient that there would be more planning and more money for implementation. This response appears overly optimistic and failed to incorporate the experiences of the USFS with their new planning rule and early adopter forests. The lessons of the USFS process should be highly relevant to the BLM, as both planning efforts seek to achieve similar goals in a similar timeframe. It is the Organizations understanding that early adopter USFS planning areas have found their new planning rule slower and more expensive to begin with expanded collaboration of partners being required. The identification of funding for the wide range of new planning must be determined, and without resolving this fundamental question the effectiveness of any new planning process will be directly at risk as funding will not be sufficient to support expanded planning and implementation of planning decisions on the ground.

3b. Economic analysis of impacts to partners is never meaningfully addressed.
The Organizations believe our concerns about the limited economic analysis surrounding the Planning Rule development are aptly highlighted when the report required under the Small Business Regulatory Enforcement Fairness Act is reviewed.⁴  The Organizations vigorously assert that this report fails to review many impacts to state and local partners in any way, is far too focused on the $100 million threshold of analysis rather than reviewing major cost increases to state and local agencies that could result from planning revisions. The Organizations can unequivocally state that our involvement in Sage Grouse planning was a major cost increase for our Organizations, and this type of new planning appears to more common place moving forward. It has been the Organizations experience that currently hard copies of any planning documents and maps are not provided to partners by the BLM and partners are already forced to print copies of these documents at their own expense. These are exactly the types of costs that must be addressed under the new planning rule.

Development of landscape level plans will clearly have a significant impact on state partners as exemplified by recent efforts involving the Sage Grouse and Desert Renewable Energy Conservation Plan. The impacts of the DRECP are discussed in depth later in these comments. The Organizations continue to work with numerous state partners on a variety of issues, including on-going sage grouse efforts. The Organizations vigorously assert that State partners consistently assert that the Sage Grouse efforts placed a huge burden on their Organizations and that such efforts cannot be undertaken on an ongoing basis. The Organizations submit that these are exactly the type of burdens on State Partners that are to be addressed in the SBREFA significance analysis and has not been. This is very concerning as Sage Grouse Planning efforts appear to be the model for BLM landscape level planning moving forward rather than an anomaly in planning. Again the Organizations must note that the expertise with the Sage Grouse efforts was not possessed by the BLM but rather was developed at significant cost to the state and local partners in the process.

These major economic impacts of landscape level Sage Grouse LUPA planning are exemplified by several local government efforts in Colorado, such as Garfield County in Colorado. Gunnison County Colorado has been forced to undertake similar efforts in order to avoid listing of the Gunnison Sage Grouse. The Organizations vigorously submit that Garfield Colorado has undertaken massive amounts of habitat mapping for the Greater Sage Grouse habitat areas. The County had serious concerns over the accuracy of BLM proposed maps simply based on the exceptionally large scale of the maps created by BLM. These maps were at best a coarse scale filter of habitat throughout the range of the Sage Grouse. Garfield County was forced to develop far more fine scale and specific maps of Sage Grouse habitat to avoid unintended economic impacts to the County and its residents. These efforts required additional full time employees and significant resources from the County. Again these are exactly the types of impacts that the SBREFA was designed to take into account and simply have not been addressed in the Proposal. The Organizations submit that BLM outreach must be significantly better with partners on these types of economic issues. The fact that the conclusions of these efforts were shared freely with BLM in the planning process does not alter the fact that these conclusions were only developed at a major cost to the state and local partners.

The Greater Sage Grouse LUPA process also highlighted the economic costs to State and local partners that result from these new levels of planning. In the Sage Grouse Planning process, many local partners in the habitat areas have effectively managed local sage grouse issues for years and have significant data to support the effectiveness of this management in a manner that has directly and clearly benefitted sage grouse populations. Simply reconciling the BLM landscape level planning with these highly effective local planning efforts has proven problematic, resulting in frustration of partners. Many local partners have expressed serious concerns about basic information relied on in the BLM landscape level Sage Grouse planning process, such as population of sage grouse and threats to the species identified in the National Technical Team (“NTT”) Report. The NTT report often relied on theoretical information that seriously conflicted with significant portions of high quality localized data available. Localized threats to the Sage Grouse is an issue where there appears to be significant conflict between the various BLM landscape plans and best available science from local partners. These conflicts were so severe that the BLM was forced to issue a 66 page supplement to the NTT report to address the issues that were raised by partners once the NTT report was released. This change would require at least a review of more localized Sage Grouse plans developed in the amendment process to insure the revised NTT has been properly addressed in these more localized plans. This type of process would indicate a serious concern about collaborating with partner organizations and that development of an effective and efficient plan will be the result of the Sage Grouse Planning

The Organizations would also note that at the public meetings on regarding the new Planning proposal there was a consistent statements from BLM staff that the planning process would remain on-going in terms of partner involvement. The Organizations again submit that these types of programmatic consultation efforts are often time consuming and require the full time staff and resources as exemplified by Garfield County to make such efforts work. Involvement in multiple Sage Grouse type planning efforts proceeding at the same time simply cannot be economically supported by state and local partners. These are exactly the type of major costs that are to be addressed in an expanded NEPA process and SBREFA analysis and simply have not been.

4. Landscape level planning will only be effective if it is meaningfully undertaken and properly analyzed under NEPA.

While the Organizations commend the DOI for their interest and lead in addressing global climate change in the planning process, the Organizations must note that there are many factors that are impacting DOI lands and specific species that are not related to climate change and must still be managed. The Organizations vigorously support the idea that certain management issues can be effectively addressed at the landscape level. The Organizations have been actively involved with the USFS and USFWS regional efforts on various species including the Canadian Lynx and Wolverine and the Desert Renewable Energy Conservation Plan and recognize that these landscape level plans have been reasonably effective in focusing resources on issues. These were extensive documents that were based on best available science for a wide range of multiple usages, which took years to develop. This level of analysis and review does not appear to be present in many of the REA and LCC that have been developed to date.

The Planning 2.0 proposal seeks to develop new landscape level plans on a variety of issues to guide the subsequent development of field office level plans, which the Organization support as an effective tool to deal with specific issues. In the Denver meeting, examples of landscape level plans and successful development processes under the revised Planning 2.0 process principals, included BLM Sage Grouse Planning, Rapid Ecological Response (“REA”) and Landscape Conservation Cooperatives (“LCC”). Rather than being examples of how the objectives of the new planning process principals have been successfully applied, it is the Organizations position these plans are examples of what can happen when the principals and objectives of the Planning 2.0 Proposal are not applied properly.

Many of our concerns regarding the Sage Grouse process have been addressed previously in these comments. The Organizations have been involved in the BLM Sage Grouse planning, and believe declaring that plan process a success and the model for a new planning process is somewhat premature as many of the LUPA changes have not been implemented at this time. The Sage Grouse planning process also highlights several failures to achieve the principals of the 2.0 Proposal, including increased collaborative planning with partners. The Western Governors Association aptly summarized state and local participation in the landscape Sage Grouse planning process as an “afterthought” in correspondence to the BLM and USFS⁵, as often stakeholders in the Sage Grouse process were not meaningfully engaged and input was not meaningfully incorporated in final versions of the RMP. Similar sentiments have been vigorously expressed from a large number of Congressman and Senators in response to the Sage Grouse planning process. It is difficult to reconcile these statements with agency assertions that the Sage Grouse planning process has successfully expanded collaborative planning. It is the Organizations position that there is significant room for improvement in the process relied on in the Sage Grouse initiatives relative to the principals relied on in the 2.0 Proposal.

REA were also identified as a second example of effective implementation of the Planning 2.0 principals and objectives. The Organizations’ are aware that the principal of an REA has been effectively applied to management of a wide range of parks and other issues, but this process is not a replacement for quality input. The Organizations are very concerned with the process that has been relied on by BLM in the development of the Rapid Ecological Assessment (REA) plans, as BLM appears to have chosen to merely hire a contractor to prepare the Colorado Plateau Rapid Ecological Assessment (“CPREA”) rather than involve the public and partners.⁶ The Organizations are not aware of any public/partner input being sought for the development of these documents, despite these documents now being relied on to guide the development of field office plans on a variety of issues. This is very troubling and fails to provide the basis for success in BLM achieving its goals of the Planning 2.0 process. More specific concerns with the management proposed in these REA regarding a particular species are discussed subsequently in these comments.

The third example of effective implementation of 2.0 proposal principals in the Denver meeting and supporting documentation was the development of LCC partnerships. The Organizations were not familiar with BLM efforts regarding the development of LCC at the time of the Denver meeting. Subsequent evaluation of this issue recognized that the LCC website identifies 22 of LCC plans currently in place in the country, and that several have been in place for multiple years. As a result, one would expect detailed examples of how these LCC are working with partners to be easily available for public discussion. That simply is not the case and providing meaningful comments on these initiatives is difficult as many of the links on the LCC website⁷ are dead or provide at best general information. Only two non-DOI partners are even identified in the national brochure on the program.

The national LCC guidance brochure for the public providing quality examples of how the LCC have been developed with expanded partner involvement, as often the national LCC brochure provides information is in the form of somewhat random comments of DOI agencies that often do not relate to the goals and objectives of the LCC process. Examples of these comments include:

“Glorious fall foliage provides a backdrop for foraging Sandhill cranes.” ⁸ or

“A majestic bull elk pauses for a drink in the southern Rockies.” ⁹

These types of random statements are often highly frustrating to many partners and more properly suited as a note to a picture in a travel brochure rather than part of a mission statement for meaningfully undertaken landscape planning that will result in effective and efficient management of issues on the ground. Frustrations are compounded when there is no picture to relate the note too, as is in the LCC brochure. The Organizations assert these efforts fall well short of seeking best available science and a more dynamic and streamlined planning process with expanded collaboration of the public and partners, even if the statements are largely symbolic.

Further numerous comments in the national LCC brochure attribute issue specific statements to agencies that are completely unrelated to that agency’s mission or expertise. An example of such a quote would be the following quote attributed to NOAA:

“Preserving cultural artifacts and traditions creates vibrant, healthy communities.”¹⁰

While NOAA is an impressive organization that does great work, NOAA’s expertise is not in cultural resources and the Organizations must question any decision that sought to rely on NOAA in such a capacity. There are a wide range of true partner organizations that have long histories of effective management of this issue, such as state historic preservation offices and the national register of historic places, and failing to rely on these organizations for their expertise may complicate partnerships with them in the future.

While these statements are largely symbolic, development of landscape plans and related coordination with partners will require significant efforts to develop high quality decisions that can be effectively applied. The implications of these types of statements to partners should not be overlooked as many partners operate with limited budgets and are highly interested in on the ground success in managing issues. These type of statements would not indicate a similar desire from BLM. rather partners could easily conclude high quality planning is not being developed in the new planning process, as much of this information provided to date appears to fall well short of high quality analysis necessary for more efficient and dynamic planning. This simply must be resolved in order to achieve the objectives of the Planning 2.0 Proposal.

4b. The Organizations concerns regarding impacts from inaccurate REA are not abstract.
The Organizations are very concerned regarding the failure to develop meaningful public/partner input in the development of the REA development process and the long term implications of these failures. This failure will result in limited funds for the management of issues being directed away from resolution of the true factors and towards other less important issues. These concerns have already manifested themselves in response to the REA and planning 2.0 proposal process, as the Wilderness Society has asserted that REA are now the proper basis for all management. ¹¹ Given the prima facie failures of the REA development process to address a wide range of issues, the Organizations are not optimistic that any management undertaken would be effective. Rather than streamlining the process, the application of inaccurate and out of date will be an additional barrier development of effective management on the ground at the field office level. Avoiding these types of issues are exactly what meaningful NEPA analysis is designed to avoid and costs associated with remedying these types of oversights are exactly the costs to be analyzed in SREFA analysis. Neither has occurred regarding the Proposal to date.

4c. S.M.A.R.T. goals
The Organizations welcome the development of SMART goals in the BLM planning process as for many issues and concerns this would be a significant step forward. However, the Organizations are concerned that SMART goals may not be practical or effective for objectives where the path forward on the issue is not clear or goals are not directly quantifiable. While the Organizations can clearly understand what the SMART goal of having identified population targets for a species on particular landscapes looks like, the Organizations are unable to identify a SMART goal for recreational usage on a landscape level. During the course of the public meetings on the Proposal, no one else was able to theorize a SMART goal for recreation. This is a serious concern for the Organizations as improving landscape level recreational opportunities will never be effectively be balanced with hard population goals for a species on the sane landscape. The ambiguity of the recreational goal will directly impact the ability to implement the goal. The poor ability of SMART type goals to achieve certain objectives are a major concern with recreational usage of public lands. History has proven that the recreational community encompasses a wide range of user groups and often these groups do not agree.

The Organizations are aware that SMART goals with clearly defined targets can lead to great success as everyone is working towards a single target. Goals with targets that are less clearly defined can result in efforts to reach the target going in many different directions, as some seeking the goal may not know how to begin and others may confidently work towards their perception of the goal, which may not be shared with the rest of the group. Such hurdles will result in lost opportunities, unattained goals and wasted resources and that parties seeking to obtain these goals will result in a long term loss of motivation to continue to work towards the goal. In 1968 Dr. Edwin Locke released a study titled “Toward a Theory of Task Motivation and Incentives”.¹² In his theory, Dr. Locke explains that setting goals that are too vague can lead to poor performance compared to specific and challenging goals. Goals that are not properly crafted can become demotivating. If the goal seems too easy or not specific enough, then the employee is not motivated to achieve it. The Organizations submit that Dr. Loche works represent a good summary of our concerns regarding the application of SMART goals to public lands planning and more particularly to recreationally based SMART goals.

5. Comparisons to the newly released DRECP provide stark differences plan developments between LCC and REA developed to date.
The Organizations would be remiss in not addressing the stark differences between the REA and LCC that have been developed and the recently released Draft Desert Renewable Energy Conservation Plan (“DRECP”). The Organizations believe these comparisons are highly relevant given the similarity in timing of development of the plans, even though the DRECP conclusions were changed significantly from what was discussed and can no longer be supported by the Organizations. The last second changes in basic direction and application of the DRECP are the type of changes that fracture relationships and must be addressed as the planning 2.0 proposal moves forward. The collaboration efforts involved in the DRECP plan were the result of more than 40 meetings and an extensive subsequent stakeholder process subsequent to these meetings. The Organizations are not aware of any public process for the REA or LCC development to date, despite plans on these issues being released in final version.

DRECP process convened nationally recognized experts with the stakeholder panel to address a variety of management issues as part of the DRECP process and insure that best available science was being applied in the DRECP. This process allowed for exceptionally meaningful resolution of concerns of stakeholders in the DRECP in a truly dynamic and efficient manner. Stakeholders were able to raise possible gaps in science with national experts and the experts were able to resolve if that perceived gap was truly a gap in research or was an issue that had not been more extensively researched as it had been clearly identified as a nonissue for the species. The Organizations submit that many of the shortfalls that are identified in the final REA and LCC would have been immediately addressed and resolved if a public process similar to the one developed for the DRECP had been used for the REA and LCC.

The DRECP addresses a wide range of multiple usage management concerns in relation to renewable energy development moving forward. As previously noted the LCC and REA developed are very targeted to particular issues and often fail to include the recreational/multiple use community in these plans. If landscape level multiple use management could be effectively targeted at only particular issues it would simplify the planning process, but experience has taught the Organizations that resolving any problem in a multiple use framework is difficult. Achieving any resolution of issues is even more difficult and complex when all multiple users are not at the table. The Organizations believe that the DRECP process provides a viable and effective framework for achieving many of the goals sought to be addressed in the 2.0 proposal and must be used as a benchmark for comparison.

The Organizations believe that the DRECP process also exemplifies how to disengage partners after a long and vigorous process, as the end recommendation for the DRECP was significantly different in direction and scope that any of the direction that was provided during the development process for the recreational community. Too often SRMA designations to benefit recreation were overlapped with ACEC designations to protect a species or issues. The conflict of these standards became troubling when the area was to be managed under the most restrictive standards for the area, which resulted in a significant net loss of opportunity for the recreational community even in areas where recreational usage was to be protected and preserved. This is unfortunate and another example where partnerships must be repaired before partners will even reengage with BLM moving forward. These are the types of issues that can only be avoided with application of a vigorous public process in the Planning 2.0 process.

6. Planning 2.0 expands both the scope and scale of issues to be addressed in planning but reduces the time period allowed for public input.
The Organizations are deeply concerned that the Proposal significantly reduces time allowed for public review of planning documents despite the greatly expanded scope of both geographic area to be addressed and number of issues to be addressed in new planning. Rather than giving less time, more time should be provided for public review as it will improve the quality of the final product. This is critically important to recreational input on rule proposals as the backbone of the recreational user groups is the local club. Most local clubs only meet once a month and under current regulations are barely able to obtain a copy of any proposal, review it and then discuss the proposal with the club in order to get meaningful site specific input from members. This type of input simply cannot be obtained in less time.

The Organizations are also concerned that there is no flexibility in the timeframes identified for the comment periods on a proposed plan. Often resource plans are thousands of pages in length with dozens of large maps attached and hard copies are difficult if not impossible to obtain from land managers. As a result local clubs are forced to print maps at their cost in order to try and participate in any proposal moving forward. The Organizations would again note that these are the types of economic costs that must be addressed in the planning process and simply are not. The public needs significant time to simply understand any changes proposed and that time will be shortened even further under the Planning 2.0 proposal. That is simply unacceptable to the Organizations.

7. Multiple usage and recreation must be specifically addressed in the Planning 2.0 process.
Obtaining the proper balance of statutorily required multiple usage partners and interests in the new landscape level planning process is a concern after reviewing the Planning 2.0 Proposal. These concerns are heightened after a review of the LCC and REA documents. Omitting partners or interests in these types of landscape level discussions will hamper on the ground implementation of these decisions as contradictory or insufficient planning may be provided at the landscape level. The Organizations submit that all multiple uses should be clearly addressed in the Proposal, rather than asserting each is a highly compartmentalized issue that can be addressed separately. Without the required balance of usages at the landscape level, planning would not be legally sufficient.

Our concern on the lack of specificity on multiple use issues is not abstract. When questions were posed at meeting such as how does recreational usage fit in the Planning 2.0 process the response was there are separate efforts in place on that issue, such as the new BLM recreational planning initiatives. The Organizations must question why these individual efforts would not be consolidated in the single initiative and public process available in the Planning 2.0 effort. This would insure that issues such as those seen in the DRECP end product were avoided, where often mutually exclusive plans were made for a single area and then the most restrictive standards were applied which often rendered management standards for recreation completely irrelevant . It has been the Organizations experience that the gray area of planning for multiple issues is where all issues come together to be resolved. Rather than reducing the gray area of planning by defining the rules as clearly as possible when conflicting standards could be possible, Planning 2.0 simply avoids the issue all together. This simply will not create plans that are legally sufficient and effective on the ground.

Again the Sage Grouse planning process provides us with good examples of why the Organizations are concerned about this compartmentalized approach to planning. An example of the conflict of landscape level plans with on the ground application is encountered when recreational usage of sage grouse habitat areas was identified as “not a threat” to habitat quality in landscape level plans but roads and trails in habitat areas were identified as a threat to the Grouse habitat quality in field office level plans. The Organizations must question how recreational usage can occur in habitat areas without roads and trails to access these areas. These are the type of multiple use issues that must be clearly resolved and failure to do so will make implementation difficult at best and minimize any long term savings.

8. Citizen science is not a replacement for best available science.
In the Denver public meeting, BLM representatives repeatedly stated that expanded incorporation of citizen science in planning would be a benefit of the new planning process. The Organizations believe that a complete review of all science available on particular management issues must be undertaken to identify possible gaps in research prior to determining any next steps in management. This review would be highly effective in developing targeted research on particular issues. The Organizations believe that asserting there is a gap in research and new science is need, when there is valid peer reviewed science on the issue is a problem and would result in significant diverting of limited resources to issues that will never benefit the species.

As more extensively discussed in subsequent portions of these comments, the Organizations are deeply concerned that this review of existing science has not occurred in the REA and LCC development process. Often existing landscape level resources for a variety of management issues that already provide clear and concise summaries of threats and management issues for a species are simply not been incorporated in the REA and LCC process, including existing Landscape Conservation Assessments and Strategies for a large number of threatened or Endangered species that have been signed by BLM representatives. Too often CAS are not addressed or management provided by the REA and LCC directly conflict with the threats and management priorities of the CAS, despite the long history of partner development of the CAS and peer review. This is simply unacceptable.

Adopting citizen science is admirable but at no point was the relationship between statutory requirements for best available science application in all federal planning and the new citizen science now to be adopted explained. In a troubling development, citizen science was not even defined in the Denver meeting. Incorporating legally insufficient research into the planning process will simply result in more litigation and bad plans being developed that attempt to manage concerns in a manner that will simply never address the problems to be managed.

While integration of best available science will streamline planning, this process is very different than accepting citizen science in an attempt to fill possible gaps in research. After reviewing the research that is relied on for much of the CPREA that have been finalized at this time, the Organizations must express concern regarding the application of this citizen science. Asserting citizen science is necessary to fill non-existent research gaps will not streamline the management process. As more completely addressed subsequently, the science relied on in the CPREA and SRLCC falls well short of best available science and simply provides the basis for on-going litigation, which must be avoided as it will result in significant additional expense in planning and delay in implementation of any management changes on the ground.

9. The Organizations welcome statements that BLM travel management decisions will be made at a more local level moving forward.
The Organizations welcomed the repeated assertions in the Denver meeting that the BLM was moving away from field office level travel planning in favor of more localized management decisions. After participating in numerous field office level travel plans, the Organizations believe moving to a more localized analysis level makes a lot of sense. Too often important areas or routes are lost at the Field Office level analysis as users are asked to review decisions impacting hundreds of thousands of acres. This type of request simply overwhelms most users and often users are not able to identify omissions from maps of routes provided in decisions in field office level proposals in the short public comment period. Identifying omissions in the travel process is as important to the final decision as addressing particular routes, as any route that is not identified as open in the decision document is closed.

10. Numerous key terms are heavily relied on in the Proposal but are never defined.
The Organizations are also very concerned that numerous terms critical to the Planning 2.0 are not defined and are highly subjective in nature. This type of ambiguity will hinder the effectiveness of any finalized planning rule in the future and will hamper the ability of the public to work with land managers. This should be avoided at all costs as the planning rule should be clear in its application and avoid ambiguity rather than create ambiguity. The Proposal relies heavily on the term “social change” but never explains what this is or why there is such a prominent position for this term in the planning process. These are the basic challenges that simply must be resolved in order to move forward in an effective manner.

11. Conclusion.
The Organizations support many of the principals that are expressed in the Planning 2.0 documentation but after a complete review of the Planning 2.0 documents the Organizations must express some concerns about implementation of the principals to date. Much of the work does not exemplify the principals of the Planning 2.0 Proposal. The principals of the Proposal include: 1. Create a more dynamic and efficient planning process; 2. Enhance opportunities for collaborative planning; and 3: Plan across landscapes and at multiple scales. These are commendable goals, which the Organizations vigorously assert can only be achieved with the application of management on the ground based on an up to date and accurate review of all facets of problems contributing to the management issue sought to be planned for. It has been the Organizations experience that development of high quality balanced plans for any management concern has a long history of resolving management issues in a cost effective and rapid process. Truly resolving the management concerns on the ground must be a long term planning objective and simply must not be overlooked. Developing plans that are never implemented or that are out of date when adopted rarely resolves any management concerns, as limited resources will be diverted away from truly effective management.

The Organizations are very concerned that numerous examples of successful initial steps towards implementing the goals of the Planning 2.0 process provided in the public meetings have fallen well short of furthering the principals identified. More specifically:

1. There has been very limited public outreach on the Proposal despite a desired goal of increasing public participation in planning;
2. NEPA analysis for the Proposal is insufficient and must be expanded;
3. The funding source for the extensive new multi-level planning must be clearly identified as this is a major increase in costs for partners sought to be engaged;
4. Economic analysis of costs and burdens resulting from planning changes is entirely lacking;
5. Statutorily required partner involvement in the Planning 2.0 process appears very limited and has been totally non-existent in many of the examples relied upon;
6. Public comment periods are significantly shortened under the new Proposal despite desire to plan for more issues on larger scales;
7. Much of the landscape level planning to date does not address multiple use requirements and recreational usage; and
8. BLM is seeking to accept citizen science in planning without identifying how that relates to best available science and BLM often relies on badly out of date science instead of clearly identified management documents for the species at the landscape level.

The Organizations vigorously assert these concerns are foundational to achieving the objectives of the Proposal and must be resolved prior to the Proposal moving forward. If you have questions please feel free to contact Scott Jones, Esq. at 508 Ashford Drive, Longmont, CO 80504. His phone is (518)281-5810 and his email is scott.jones46@yahoo.com.

Sincerely,

Scott Jones, Esq.
TPA Authorized Representative
CSA/COHVCO President

D.E. Riggle,
Director of Operations
Trail Preservation Alliance

1 See, 9674 Federal Register / Vol. 81, No. 37 / Thursday, February 25, 2016 / Proposed Rules
2 http://www.blm.gov/wo/st/en/prog/planning/nepa/webguide/departmental_manual/516_dm_chapter_11.html#11-8
3 See, DOI BLM; Preliminary Categorical Exclusion Documentation; 2016 Proposed Rule 43 CFR Part 1600 (undated).

4 http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/planning_images.Par.22418.File.dat/Planning_Rule_Preliminary_Economic_Analysis_Final.pdf
5 See, http://www.westgov.org/news/298-news-2014/800-western-governors-concerned-federal-work-with-states-on-sage-grouse-conservation-an-afterthought-seek-clear-concise-input
6 See, http://consbio.org/products/projects/blm-rapid-ecological-assessment-rea-colorado-plateau
7 http://lccnetwork.org/ accessed 10/15/14
8 See, Department of Interior, Landscape Conservation Cooperatives Brochure – undated at page 3. available at http://lccnetwork.org/Media/Default/Misc/LCC_brochure_web.pdf
9 See, Department of Interior, Landscape Conservation Cooperatives Brochure – undated at page 1. available at http://lccnetwork.org/Media/Default/Misc/LCC_brochure_web.pdf
10 See, Department of Interior, Landscape Conservation Cooperatives Brochure – undated at page 2. available at http://lccnetwork.org/Media/Default/Misc/LCC_brochure_web.pdf

11 http://wilderness.org/sites/default/files/TWS%20–%20BLM%20report_0.pdf

12 See, Dr Edwin Locke; TOWARD A THEORY OF TASK MOTIVATION AND INCENTIVES. Journal of Organizational Behavior & Human Performance, Vol 3(2), 1968, 157-189. A copy of this article is available here: http://dx.doi.org/10.1016/0030-5073(68)90004-4

Timeline released for trail changes aimed at protecting rare fish near Pikes Peak | Colorado Springs Gazette, News

All,

A lot of thanks goes to a number of people and organizations that worked to help save a historic motorcycle trail. The out come was not the best, but under the circumstance it is the outcome we have to accept.

Rather interesting was the newspaper quote of the FS official, that defended the motorcycle use of the trail, vs the law suit by the CBD.

No need going over the false merits of the suit, we need to move on with other OHV issues that our sport is facing. Please pass on this newspaper article to all of your associates/members.

In light of the circumstance facing the FS, the PPRD did the best they could to accommodate the court order, and also help preserve our trail. If you get the opportunity to thank Ranger Martinez, please do it. There will be more issues we will have to work with the FS.

Don Riggle

Rio Grande National Forest Plan Revision Initial Comments

Rio Grande National Forest
Attn: Dan Dallas, Forest Supervisor
1803 W. Highway 160
Monte Vista Co 81144

RE: Rio Grande National Forest Plan Revision Initial Comments

Dear Supervisor Dallas:

Please accept these comments on the Rio Grande National Forest Plan Revision Project on behalf of the Trails Preservation Alliance (“TPA”), Colorado Snowmobile Association (“CSA”) and the Colorado Off-Highway Vehicle Coalition (“COHVCO”). Prior to addressing the specific concerns that have been raised to date in the development of the new Rio Grande National Forest’s Resource Management Plan (RMP), the Organizations would like to thank the Rio Grande National Forest staff for their efforts to date in the planning process. The Organizations are aware that the Rio Grande National Forest is one of the first forests to move forward under the new United States Forest Service (USFS) planning rule and at this time and USFS guidance regarding the application of the new planning rule to local forests or planning units remains under development. This lack of planning rule clarity compounds the inherent conflict that exists between current forest planning timeline and the rate at which species management and research are progressing. This lack of clarity has made any efforts on the Rio Grande difficult at best as there are many new concepts and principals developed under the planning rule that will heavily impact plan development. The Organizations believe that the efforts to date have done a commendable job in satisfying these new requirements and standards and the Organizations remain willing to assist in resolution of any issues that might arise on this front in any way that we can.

The TPA is a volunteer organization created to be a viable partner to public lands managers, working with the USFS and the Bureau of Land Management (BLM) to preserve the sport of trail riding and multi-use recreation. The TPA acts as an advocate for the sport and takes the necessary action to insure that the USFS and BLM allocate a fair and equitable percentage of public lands access to diverse multi-use recreational opportunities. COHVCO is a grassroots advocacy organization representing approximately 150,000 registered off-highway vehicle (“OHV”) users in Colorado seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of multi-use and 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. 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. 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. TPA, CSA and COHVCO are referred to collectively in this correspondence as “The Organizations.”

The Organizations offer the following comments, values and concerns regarding this plan update moving forward.

1. The Organizations believe that continued multi-use access and motorized recreation within the National Forest is vitally important to the preservation and conservation of our public lands and the well-being of our citizens. The Organizations acknowledge that as America becomes more urbanized and populations rise, our younger citizens are becoming less connected to and are less likely to identify with the outdoors in their daily lives. Our Organizations have worked diligently and continuously to help Coloradans and visitors to our State to be able to access and enjoy our public lands in a safe and responsible manner. We recognize that there is a bona fide correlation between an individual’s personal health and their participation in outdoor activities. We continually strive to get youth and families excited about visiting, seeing and experiencing all that our public lands have to offer. We have a history of partnering with the USFS to protect our forest resources while reducing and eliminating barriers that are continuing to make it difficult for Americans to get outside and travel on a multi-use trail or share a road as part of their outdoor recreational experience. The Organizations feel that this renewal of the Forest Plan must work diligently to ensure that a balanced spectrum of opportunities are provided in the Rio Grande National Forest to properly serve the diverse cross section of our population and meet their recreational needs. We contend that both “Conservation philosophies” and “Recreation activities” are compatible and can work in harmony for the betterment of the Forest. We request that this revision of the Forest Plan fairly and adequately provide an Environmentally, Economically and Socially sustainable end state.
2. The USFS has been a recognized supporter of the California Children’s Outdoor Bill of Rights. Nationwide there are concerns about the youth of our country’s lack of exercise, detachment from outdoor activities and limited access to public parks and land. The Rio Grande National Forest along with its associated network of roads and trails provides the necessary access and recreational opportunity for the surrounding region’s youth to explore nature, play in safe places, follow a trail, go fishing, camp under the stars, connect with the past and many of the other activities inspired by Richard Louv’s book “Last Child Left in the Woods.” Loss or closure of the multi-use and motorized system of trails with the Rio Grande National Forest would certainly be a tragedy and lost opportunity for the region’s youth to be able to connect to and be exposed to nature.
3. It is well recognized that the average age of our country’s population is increasing and the number of persons aged 50 and older is steadily increasing. As the average age grows, so is the number of people still choosing to recreate outdoors but more and more will be less able to use non-motorized methods of travel or participate in high-energy, high-skill sports. As this demographic group grows, so will their needs for access to the Forest by motorized or other assisted methods. If we collectively fail to recognize and plan for this changing demographic, we will be deliberately excluding a significant and growing segment of the population from the opportunities to experience and enjoy the Rio Grande National Forest. Many of us hope to retain our individual mobility into the “Golden Years,” but many will not, and they will need to rely upon some sort of motorized assistance to access the places we all enjoy and cherish. The Rio Grande National Forest’s Assessment #9, Recreation even states that “For seniors, inaccessible infrastructure and lack of opportunities that enable senior adults to continue in outdoor recreation constrains recreation participation”.
4. The economic impacts of multi-use and motorized recreation within the Rio Grande National Forest must not be overlooked or underestimated. Even though the Rio Grande National Forest receives somewhat lower visitation than other national forests in Colorado, there are still significant economic benefits being realized by all of the communities and Counties encompassed by and in proximity to the Forest. As an example, motorized recreational enthusiasts were responsible for $990 million in direct expenditures relating to motorized recreation in Colorado during the 2012-2013 season alone.[1]
5. Our Organizations contend that the previous Forest Plan and subsequent Travel Management Plan (TMP) substantially reduced recreational opportunities, reduced access, eliminated multi-use/motorized recreational opportunities and was too restrictive. This new plan must seek a more balanced and fair allocation of resources to recreation and especially multi-use/motorized recreational opportunities. Similarly, the restrictions of the former plan have contributed to the current poor health of the forest and unnecessarily hampered the efforts of the agency to be able to properly and effectively mitigate fuels and manage the density of the forest biomass.
6. With few if any exceptions, the roads and trails within the Rio Grande National Forest have been in existence and providing public benefits for decades. History has shown that these routes provides a level of tangible recreational, economic and/or forest access value. Continuing to have an adequate network of forest roads and trails will be truly beneficial and necessary in providing sufficient access for future timber management, continuing forest visits, recreation, emergency access/egress and wildland firefighting efforts. This minimal threat is accurately reflected in the aquatic assessments on the Rio Grande National Forest which clearly conclude that these routes pose an exceptionally low level threat to water quality.
7. We feel it is important to spotlight the following general principles regarding multi-use recreation and are important considerations when evaluating any modifications to the Forest Plan[2]:
   1. Generally forest visitors participating in multi-use activities will use routes that exist and adequately satisfy their needs and desires.
   2. Non-system trails and roads should be reviewed during this review process to determine if any of these non-system routes will fulfill a valid multi-use need and can be altered to meet recreation and resource management considerations.
   3. Route networks and multi-use trail systems should meet local needs, provide the desired recreational opportunities and offer a quality experience. We are not asking that this be done at the expense of other important concerns, but a system of routes that does not meet user needs will not be used properly and will not be supported by the users. Occurrences of off-route use, other management issues and enforcement problems will likely increase when the routes and trails do not provide an appropriate and enjoyable opportunity.
   4. Recreational enthusiasts look for variety in their various pursuits. For multi-use, to include motorized/OHV users, this means looped routes. An in-and-out route may be satisfactory if the destination is so desirable that it overshadows the fact that forest visitors must use the same route in both directions (e.g., access to dispersed camping sites, overlooks, historic sites, the Wheeler Geologic Area, etc.). However, even in these cases, loop systems will always provide better experiences.
8. “Desired Recreational Experiences” is subjective and will vary from individual to individual. Calls to decommission roads or to return areas to more natural states and enhance recreational experiences is purely subjective and a personal opinion. No one will be able to enjoy the forest and all of the resources the forest has to offer if adequate access is not provided. Multi-use and motorized recreation is indeed a bona fide form of recreation and not one to be reduced, banned or eliminated on public lands.
9. An adequate network of forest roads and trails is necessary to provide access for proper forest management and especially in times of emergency. The USFS is a world renowned expert on wildland firefighting and knows firsthand the importance of good access, redundant routes and routes in key places and the impact of those routes on the safety of the firefighters, the public and successful wildland firefighting. The demands for reduced road inventory, for reduced route density and increased decommissioning of roads is not collectively and universally in the best interest of the forest nor the public. The demand for more and more closure of multi-use and motorized access is often based upon self-serving desires and an unwillingness to share our natural resources with others, intolerance of mixed forest uses and an unwillingness to coexist in our individual pursuits of recreation. Likewise the premise that decommissioning roads will reduce human caused fires is absolutely unfounded and unsubstantiated and should not be utilized as a criteria for any decisions regarding the elimination or closure of any multi-use or motorized route.
10. Not all dead roads are necessarily of low value and in need of closure. Many dead end spurs and “low value” routes provide access to picnic areas, dispersed camping sites, overlooks, etc. Although the values of these roads is less than that of main roads, connectors and loops, (i.e. “higher value” routes) their individual, overall benefit and value must be individually considered. We acknowledge that these roads will likely not generate much positive public interest and comment, however these routes can still have substantial importance to the public. We would encourage the Rio Grande National Forest to listen to your own recreational and field staff when assessing any low value or dead end spur roads.
11. Duplicative roads and trails may on the surface appear redundant and not needed. This is often the cry from those unfamiliar with multi-use and motorized recreation or simply seeking to eliminate or reduce public use of these roads. However, we would challenge that some duplicative routes may in fact offer unique benefits for distributing the use rather than concentrating use to a single route or may offer looping and other recreational opportunities. It is our position that every route has recreational value as each route provides a unique experience to those using the route for recreational activity.
12. The Organizations in general oppose the conversion of routes to “Administrative Roads”. This designation in and of itself suggest an elitism attitude that Agency staff or other special designated personnel are the only ones capable of properly using a route. If a route is important for USFS and agency staff to access a location, it is very probable that that same route is equally important or desirable for the public to access the same or similar location. If the route is properly constructed and receives the requisite level of maintenance, there should be few reasons the public should not be allowed similar access and privileges. The designation that only “special” personnel are allowed to use a route does little to foster any sense of community and partnership users and agency staff should have for each other. Discrimination of the public users and the fostering of elitism should not be perpetuated, encouraged or allowed to proliferate. The designation of routes for Administrative Use should only be utilized in the rarest of instances where the exclusion of the public can be justified for very site specific, meaningful and justifiable conditions (e.g. mandated security of critical infrastructure, etc.).
13. In the past there have been unfounded concerns for American elk and mule deer as a reason to close and limit multi-use and motorized recreation on public lands. The premise that “large animals, especially deer and elk, are sensitive to traffic and activity along roads” is not supported by published scientific research. Extensive studies completed as recently as 2005 by the National Park Service (NPS) in Yellowstone Park stated that “Effects of winter disturbances on ungulates from motorized and non-motorized uses more likely accrue at the individual animal level than at the population scale.” Even the biologist performing the research stated that the debate regarding effects on human recreation on wildlife is largely a “social issue” as opposed to a wildlife management issue. This NPS research would certainly seem relevant to wildlife in the Rio Grande National Forest and does not support a premise for closures and reductions in multi-use recreational opportunities. Additional research published by Mark Rumble, Lahkdar Benkobi and Scott Gamo in 2005 has also found that hunting invokes a more significant response in elk than other factors in the same habitat area (e.g. roads or trails). Likewise research by Connor, White and Freddy in 2001 has even demonstrated that elk population increases on private land in response to hunting activities. This research again brings into question why multi-use trail recreation (specifically motorized recreation) might be cited and used as the justification for any closures or modification to public access.
14. The Organizations are aware of demands regarding a perceived inadequacy of the USFS to provide enforcement of regulations pertaining to multi-use and motorized recreation in particular. We would challenge that based upon several studies, pilot projects, etc. by the Colorado Parks and Wildlife Division, the USFS and the BLM to analyze if indeed an enforcement issue exists, and without exception, those projects have shown there are no problems due to a lack of enforcement. The State of Colorado’s OHV funds have been used to subsidize law enforcement programs and the detailing of law enforcement officers to OHV areas only to come back with consistent results that this cry for the need for enforcement is unfounded, unsubstantiated and just plain inaccurate. In 2011, the Colorado Parks and Wildlife Division initiated an OHV Law Enforcement Pilot program to address the accusations, questions and concerns raised by critics of OHV recreation on public lands in Colorado. The data and observations gathered from this Pilot program in 2011, 2012, and 2103 repeatedly demonstrated excellent compliance with OHV rules and regulations throughout Colorado by OHV users. It was estimated that over 10,000 individual OHV users were stopped and inspected during the Pilot Program and 94% of those users were found to be fully compliant with Colorado OHV laws and regulations.[3]
15. Sound. Motorized and non-motorized uses are equally legitimate uses of public lands and especially on USFS roads and multi-use/motorized trails. Sound from motorized use is to be expected in areas open to motorized use. The Organizations would offer that the State of Colorado already has strict standards for any and all sound emanating from OHV’s. This very detailed standard has proven to be effective since 2006 and governs vehicles produced as far back as 1971. OHV users themselves have funded efforts to educate, test and “police” themselves for sound level compliance. We feel that complaints of noise and demands for sound reduction are once again unfounded and will often be used as a selfish excuse to try and reduce or eliminate motorized access and use of public lands.
    The Organizations would be willing to partner with the USFS to address any site specific sound issues that may be asserted to be present on the Rio Grande National Forest. The Organizations have undertaken sound testing with independent third parties at numerous other areas asserted to have sound issues and have almost uniformly found that site specific sound issues are unrelated to OHV activity and are more commonly related to trains, air travel and high speed arterial roads in the area.
    The Organizations further submit that those seeking a quiet recreational experience have a wide range of opportunities available on the Rio Grande National Forest given the high levels of Wilderness already in place. The Organizations submit that these opportunities must be utilized before additional closures are undertaken, as the inability to access a “quiet area” is a different issue than the lack of quiet areas on the Rio Grande National Forest.
16. We acknowledge that the Rio Grande National Forest may have struggled somewhat with the proliferation of non-system trails by ALL users throughout the Forest. However, we feel much of this stems from an increasing need and demand for multi-use recreational opportunities on public lands in general. As the State of Colorado’s population has grown, so have the sales of Off Highway Vehicles (OHV’s), bicycles, hiking equipment, camping units and other forms of outdoor recreation increasing the demand for recreation sites within the Rio Grande National Forest. We would offer that much of the increase in illegal user-created routes, braided routes & trails and unauthorized group campsites are a result and reflection of inadequately meeting the needs and demands of the public and the recreational users who choose these areas. An adequate and varied inventory of routes and trails that fulfills the user’s spectrum of needs for variety, difficulty, destinations, challenge, terrain and scenic opportunity will lead to improved compliance and less off route travel. Closure and reduction of recreational opportunities and the resulting concentration of the ever increasing number of users, has shown again and again that the desired results are not obtained.
17. As future Proactive and Adaptive Management Plans are considered to try and achieve a particular desired condition or end state, these Plans should include thresholds and triggering mechanisms that allow for the expansion and adding of recreational opportunities, not just curtailment, restrictions and eliminations of opportunities. If desired conditions are not being achieved or monitoring protocols are not rendering the preferred results, consideration should be given that perhaps the needs and demands of the users are not being adequately provided for. One example might be off trail use or use of closed routes. Rather than assuming this is merely caused by a minority of users ignoring the rules, this may indeed be an indicator that the existing network does not adequately meet the user group’s spectrum of needs for a route to a particular destination, level or degree of challenge, route length, etc. The Organizations believe the motorized game retrieval standards currently allowed on the Rio Grande National Forest provide a concrete example of the need for flexibility in management to achieve management objectives.
18. The motorized community has proudly partnered with land managers to help offset budget limitations, which has resulted in grant funding exceeding $100k per year now being provided to the Rio Grande National Forest, even in light of the most recent round of budget cuts to the USFS. Lack of fiscal capacity by the USFS should not be a criteria for, or lead to closures and reductions in public recreational opportunities, closure of routes or elimination of public access to the Rio Grande National Forest. We fully realize the stark realities of ever diminishing budgets, but it would be a travesty that the public citizenry should be locked out of any public lands and denied access because of a lack of funding. Maintenance and staffing may suffer, but the public must not be shut out. Public access must be preserved and the ongoing grant funding that has been provided on a project and Good Management Crew basis for the Rio Grande National Forest the Organizations hope has played an integral part in efforts to maintain access to public lands for all user groups. This grant program has become more important every year as federal budgets continue to decline at a somewhat alarming rate and creates a situation where leaving a trail open to motorized usage significantly expands funding available for the route to be maintained with.
19. The Organizations encourage the individual Ranger Districts within the Rio Grande National Forest to carry on their efforts and continue to make submissions for grants through the Colorado Parks and Wildlife OHV Grant program to support OHV trail related projects on the Forest. OHV project grants can address the full spectrum of OHV recreation support needs. Examples of eligible OHV grant funded activities includes[4]:​
    • Construction, reconstruction or maintenance of OHV routes or multi-use trails that allow for motorized use​
    • Crossing structures, bridges, railings, ramps, and fencing
    • Bank stabilization and retaining structures
    • OHV trail corridor re-vegetation and erosion control​
    • Trailhead development and/or support facilities related to OHV or multi-use trails including parking areas, restrooms, and related facilities
    • Equipment needed to build or maintain OHV trails
    • Signs – directional, regulatory, and interpretive signage for OHV routes
    • Printing – maps/guides, safety and educational materials programs, publications and videos on safety and OHV recreation
    • OHV trail or system planning, engineering, or design
    • ​Land acquisition or easement projects. NEPA review and environmental compliance work required under NEPA or other statutes​
    • Restoration of closed trails or damaged areas where a nexus exists between OHV misuse and needed repairs
    • Salary, compensation and benefits for crew members or project employees​
    • OHV Education and safety programs
    • Wildlife habitat restoration
20. In general, the Organizations do not support the segregation of users and the exclusive use of one user group at the exclusion of others. We feel it is both socially beneficial and desirable for all users to learn to coexist and to show tolerance and respect for other users and groups of users. Just as we all learn to live together in our daily lives away from the forest, we should also extend that willingness to coexist when in the forest. Segregated user groups only fosters arrogance, elitism, intolerance and eventually leads to unjustified stereotyping and discrimination which results in greater user conflict. The Organizations are intimately familiar with the situation where user conflict is used as a strawman for the desire to create exclusive use areas on the Rio Grande. The Organizations are not aware of any major user conflict areas or issues currently existing on the Rio Grande and creating user conflict in an attempt to create exclusive use areas on the forest would be unfortunate.
21. We feel it will be necessary for this revision of the Forest Plan to provide opportunities and future opportunities that will not restrict the changes and development of new technologies such as hybrid bikes, electric bikes/motorcycles, personal mobility devices just to name a few.
22. Together our Organizations do not support or endorse the expansion of Wilderness areas within the Rio Grande National Forest or management that seeks to provide expanded Wilderness like experiences. In Colorado alone, there are approximately 3.7 million acres of Congressionally designated Wilderness in our National Forests or approximately 15% of all USFS lands. Another 210,984 acres of Wilderness are located within Colorado’s Bureau of Land Management (BLM) boundaries and 306,081 acres are located in Colorado’s National Parks. In total, there are 2 million acres of designated Wilderness already in Colorado. This is an area larger than the states of Rhode Island and Delaware combined. Many of the remaining lands within the State that might be considered for “Wilderness” designation have been specifically “released” by Congress from future consideration as Wilderness, or have been studied by the agency and deemed unsuitable for Wilderness designation.
    Finally, visitor use statistics do not suggest that we need additional Wilderness areas. Nationally, only about 5 percent of user visits to the Forest System are in Wilderness areas. The visitation figure for the Rocky Mountain region is even lower, about 4 %, despite over 15% of USFS lands in Colorado being Congressionally designated Wilderness[5]. Congress has amply addressed both the need and demand for Wilderness in Colorado. Wilderness advocates frequently claim new Congressional designations of Wilderness areas will drive economic growth, which claims are supported by generalized assertions by the Outdoor Industry Association (OIA) research findings that outdoor recreation is $646 Billion dollar a year industry. The relationship of this research and Congressionally designated Wilderness is unclear at best, as the OIA research specifically includes valuations of activities such as motorized recreation, Bicycling, RV camping, and Snowmobiling. In reality, most Americans, for various reasons, are unable or unwilling to enlist in the physical and rigorous effort required of the adventures in Wilderness areas. The Rio Grande National Forest and other forests face broad-scale ecological threats that require well designed management responses that do not stop at a Wilderness boundary. In Colorado, we only need to look outside to see the devastation tied to catastrophic wildfires and the spruce beetle outbreaks. An ecological imbalance has developed over time because widespread treatments in the Engleman and Blue Spruce stands that would have created age class diversity, enhanced the vigor of remaining trees, and improved stand resiliency to drought or insect attack—such as timber harvest and thinning — lacked public acceptance in the past.
23. Four large Wilderness areas on Rio Grande already provide exceptional recreational opportunity for those seeking to user experience (i.e., La Garita, Sangre de Cristo, Weminuche, and South San Juan). Even with these exceptional resources, these areas only received 4% of visitor days to the Rio Grande.[6] A lot of local frustration with complex fires and impacts that lack of management had with these fires scope and intensity. Requirements for Wilderness management have also greatly increased basic operation costs for land managers as even basic maintenance may only be done without mechanical assistance.
24. Colorado Roadless Rule. The Organizations are also concerned that the Roadless Rule is often used as a lever for the expansion of Wilderness areas. This is a misapplication of the Roadless Rule, as Colorado as developed its own rule that specifically identifies motorized trails as a characteristic of a Colorado Roadless area.[7] While Roadless areas have limitations on road construction and heavy maintenance, trails are entirely outside the scope of the Colorado Roadless Rule [8] as trail networks may be constructed and expanded in a Colorado Roadless Area.
    In the development of the Colorado Roadless Rule, an extensive inventory of characteristics of each area of a forest proposed to be managed either as a CRA or Upper Tier areas was undertaken. A significant portion of the Rio Grande National Forest was proposed to be managed as upper tier Roadless Areas under Alternative 4 in the NEPA analysis. After the inventory was completed most of these areas were identified to remain Colorado Roadless areas due to existing levels of human activity in the areas. Given the proximity in time of this inventory, the Organizations believe this inventory is highly relevant to discussions seeking the expansion of any wilderness like management as these areas were recently inventoried for these characteristics and found not to be eligible. The Organizations are not aware of any management in these areas where Wilderness characteristics were possibly expanded.
25. National Monument Designations. The Organizations would not support the designation of any new or existing historic sites, geologic sites or other areas being designated as National Monuments (with their inherent and corresponding restrictions and limits on public access). We offer that the Rio Grande National Forest has done an adequate job throughout its history in recognizing and preserving the many special and unique sites, locations and landscapes contained within the current Forest boundaries. Any designations as National Monuments are unnecessary and would be detrimental to ensuring unfettered public access. The Organizations support the status quo access to such locations as the town site of Bonanza, the Wheeler Geologic Area, Cumbres and Toltec National Historic Landmark, Mount Blanca, the Natural Arch, the Fremont Special Interest Area, etc.
26. We would ask that any future access easements allow “full public access” and that no “conditional easements” or easements restricting travel to a specified mode or modes of travel be exchanged or conveyed. The Organizations are also aware of extensive efforts in other national forests to create buffers around any non-motorized route or route that might have been provided a specific designation by Congress. Each of these specific designations are managed under the National Trails System Act, which clearly addresses the relationship of any designated routes and adjacent management standards as follows:
    “Development and management of each segment of the National Trails System shall be designed to harmonize with and complement any established multiple use plans for that specific area in order to insure continued maximum benefits from the land.”[9]
    Given this clarity of management, the Organizations would find it difficult to establish a fact pattern where the existence of a trail in an area could be used to close multiple use recreation in areas adjacent to the trail.
27. Cultural sites – The Organizations were pleased to note that The Need for Change document[10] states the desire to expand several cultural areas while maintaining motorized access. Maintaining multiple use access is critical to the public support for these areas in the future, as the public should understand why an area is important and without this type of hands on understanding resentment will grow for closure of these areas. The Organizations also vigorously assert that cultural sites have been specifically identified as a multiple use management concern and when multiple uses of cultural areas are balanced, closures to the areas are difficult to justify.
28. Best available science must be relied on in the development of the RMP for all species. Often identifying best available science can be difficult as this is an issue that is now rapidly evolving for many species, such as the Gunnison Sage Grouse, Mexican Wolf, Wolverine and Canadian Lynx. The rapid evolution of best available science in comparison to RMPs has resulted in conflict between these two issues, and as recently exemplified by the Pike & San Isabel National Forest Plan Challenge can result in lawsuits being brought against land managers when forest plans conflict with best available science. Overreliance on outdated management principals and standards should be avoided in the development of the Rio Grande National Forest RMP as this will be an area which will be ripe for legal challenge in the future.The Organizations submit that the new adaptive management and monitoring standards further support the requirement that best available science be relied on both in the development of forest plans and over the life of the forest plan. The Organizations would also note that the on-going requirement to manage to best available science and avoid application of outdated management standards in the development of new forest or resource plans was specifically addressed in the new Lynx Conservation Assessment and Strategy (“LCAS”). While the LCAS is highlighted here similar provisions are found in almost all species specific management documents that have been created. The LCAS specifically provides as follows:
    

    “This edition of the LCAS provides a full revision, incorporating all prior amendments and clarifications, substantial new scientific information that has emerged since 2000…… Guidance provided in the revised LCAS is no longer written in the framework of objectives, standards, and guide-lines as used in land management planning, but rather as conservation measures. This change was made to more clearly distinguish between the management direction that has been established through the public planning and decision-making process, versus conservation measures that are meant to synthesize and interpret evolving scientific information.” [11]
    

    LCAS continues by addressing the relationship of best available science and existing forest plans as follows:

    “Forest plans are prepared and implemented in accordance with the National Forest Management Act of 1976…..The updated information and understandings in the revised LCAS may be useful for project planning and implementation, as well as helping to inform future amendments or revisions of forest plans.”[12]
    

    Many wildlife or quiet use advocates are uncomfortable in reducing the strictness of management standards when best available science moves away from one low risk threat to a species to address newly discovered or understood threats. Given the clarity of these various positions and the legal exposure that could result from failing to implement these requirements the Organizations vigorously assert that best available science must be applied in the Rio Grande National Forest RMP moving forward.

29. Motorized game retrieval. The Organizations submit that motorized game retrieval is an important component of the hunting experience on the Rio Grande National Forest. While the Organizations are aware this is a site specific travel management decision, the continuation of these regulations should be provided for as the RMP moves forward.
30. Wildlife habitat connectivity- The Organizations are aware that nationally the concept of management of Wildlife Habitat area connectivity is a new concept but CPW has been at the forefront of this issue and has been critical in application of these types of principals on public lands throughout Colorado. As a result the Organizations submit that wildlife connectivity is an issue that has basically been resolved on the Rio Grande National Forest through the on-going site specific planning on the Forest and as a result do not see the need for significant changes in current management to address these issues.
31. The number of categories in the new Rio Grande RMP must be reduced. The Organizations are aware there has been significant concern voiced over the proposed reduction in the number of management standards that are currently in the Rio Grande National Forest RMP. The Organizations vigorously support a significant reduction in the number of categories simply to comply with the landscape nature of an RMP. Even with the size of the Rio Grande National Forest the number of categories currently in place reflects several local plans being combined rather than a true landscape level plan that is developed to facilitate local planning moving forward.

The Organizations would welcome a discussion of these opportunities and any other challenges that might be facing the Rio Grande National Forest moving forward at your convenience.

Sincerely,

D.E. Riggle,
Director of Operations
Trail Preservation Alliance

Scott Jones, Esq.
TPA Authorized Representative
CSA/COHVCO President

/signed/

Pat Steenburg & Clive Heller
Boot Hill Enduro Club
5511 Ridgetop Court
Alamosa, Colorado 81101
pmsteenburg@gmail.com

[1] See, COHVCO- Economic Contribution of Off-Highway Vehicle use in Colorado, prepared by the Lewis Burger Group – August 2013. A copy of this report has been enclosed for your convenience.

[2] See, National Off-Highway Vehicle Conservation Council- Management Guidelines for OHV Recreation, 2006.

[3] See, Colorado Parks and Wildlife – The 2014 Off-Highway Vehicle Law Enforcement & Field Presence Program, Colorado Parks and Wildlife Division, March 2014

[4] http://cpw.state.co.us/aboutus/Pages/TrailsGrantsOHV.aspx

[5] See, USFS National Visitor Use Monitoring Results, USDA Forest Service, National Summary Report, Updated 20 May 2013.

[6] See, USFS National Visitor Use Monitoring report for the Rio Grande National Forest- Round 3

[7] See, Colorado Roadless Rule § 294.41 Definitions; see also 294.46 Other activities (e)

[8] See, Proposed Colorado Roadless Rule; 77 Federal Register No. 128 (Tuesday, July 3, 2012) Rules and Regulations at pg 39580.

[9] See, 16 USC 1246(a)(2) emphasis added

[10]See, Rio Grande National Forest “Need for Change document” pg. 6 – item D7. A complete version of this document is available here: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd493976.pdf

[11] See, Interagency Lynx Biology Team. 2013. Canada lynx conservation assessment and strategy. 3rd edition. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication R1-13-19, Missoula, MT. 128 pp. at pg. 2. (Hereinafter referred to as “LCAS”).

[12] See, LCAS at pg. 4

Why wasn’t motorized recreation included in a major report?
Ask the publisher!

Take Action!

On March 31, the Pew Charitable Trusts released a report titled, “Quiet Recreation on BLM-Managed Lands: Economic Contribution 2014.”

The report found “quiet recreation visitors to these BLM lands spent approximately $1.8 billion … in 2014. These expenditures resulted in overall contribution … of approximately $800 million in personal income, $1.54 billion in value-added, economic output of over $2.8 billion, and nearly 25,000 jobs.”

However, the report does not include the economic benefits of responsible motorized recreation for reference. The Outdoor Industry Association concluded direct spending for “Off Roading” in the Western Governors Association region was more than $27.1 billion. Moreover, the Pew report cited a combined OHV category (i.e., cars, trucks, SUVs and ATVs) as No. 2 in total visitor days in western states and Alaska.

With motorized recreation contributing greatly to the economic engine of the United States, the American Motorcyclist Association believes the significant economic activity of motorized recreation should have been properly referenced in this report or in a separately commissioned motorized-only recreation study.

Ask the Pew Charitable Trusts research center why motorized recreation was not referenced in the report.

Now more than ever, it is crucial that you and your riding friends become members of the AMA to help protect our riding freedoms. More members mean more clout against the opponents of motorcycling. That support will help fight for your rights – on the road, trail and racetrack and in the halls of government. If you are a motorcycle rider, join the AMA at americanmotorcyclist.com/membership/join.

Take Action!