Archive | September, 2017

Scoping Report release announcement – Trails Preservation Alliance & COHVCO
 Scoping Report Pike and San Isabel National Forests, Public Motor Vehicle Use Environmental Impact Statement – USDA Forest Service

1. Background: The Pike and San Isabel National Forest (PSI) is working to complete an environmental impact statement (EIS) for travel management on the PSI as the result of a 2015 court settlement agreement. Analysis in the EIS will determine and decide which roads and trails will be open for public motorized use and included in future Motor Vehicle Use Maps (MVUMs).
2. The project Scoping Report is now complete: The formal public scoping comment period began on July 25, 2016 with the publication of the Notice of Intent (NOI), and was slated to run 45 days and end on September 8, 2016. However, the PSI extended the scoping comment period by 15 days until September 23, 2016, thereby giving the public more time to submit comments on the proposed project. The final scoping report analyzing these comments was approved by the PSI in September 2017 and is now available for public review at http://www.psitravelmanagement.org/scoping-results.
3. Next Steps: The TPA and COHVCO recommend that our constituents consider the following in response to the release of the PSI Scoping Report:
   • This Scoping Report is the first “official document” coming out of the PSI EIS process.
   • In general there appears to be a lot of support for continued multiple-use/OHV recreation and access. Several local governments and utilities are supporting Alternatives C or D.
   • The process is moving forward and we cannot afford to be complacent, all interested parties should remain vigilant, engaged and interested. Regularly check the TPA’s website, “News Page” (https://www.coloradotpa.org/news/) for updates and information.
   • All routes, roads and trails that were initially at risk are still all at risk.
   • The full scoping report can be downloaded at: https://static1.squarespace.com/static/57754b452994ca3f91e9085e/t/59c92c3bcd0f687a8b327861/1506356314788/FinalPSItravelMgtScopingReport.pdf
   • A copy of the scoping report, highlighted by the TPA for easier reading, is available at the top of this page.
   • The TPA and COHVCO recommend that our constituents review the report, if individual comments were provided, we recommend individuals review the report to see if their comments were indeed received and included, and if the comments were considered “substantive” or “non-substantive”. (Excerpt from the NEPA Handbook 6.9.2.1)
     • Substantive comments do one or more of the following:
       • Question, with reasonable basis, the accuracy of information in the EIS or EA.
       • Question, with reasonable basis, the adequacy of, methodology for, or assumptions used for the environmental analysis.
       • Present new information relevant to the analysis.
       • Present reasonable alternatives other than those analyzed in the EIS or EA.
       • Cause changes or revisions in one or more of the alternatives.
     • Comments that are not considered substantive include the following:
       • Comments in favor of or against the proposed action or alternatives without reasoning that meet the criteria listed above (such as “we disagree with Alternative Two and believe the USFS should select Alternative Three”).
       • Comments that only agree or disagree with USFS policy or resource decisions without justification or supporting data that meet the criteria listed above (such as “more grazing should be permitted”).
       • Comments that don’t pertain to the project area or the project (such as “the government should eliminate all dams,” when the project is about a grazing permit).
         • Comments that take the form of vague, open-ended questions.
   • It is important to see and understand the conflicting goals and aspirations of the pro multiple-use/OHV citizens and the anti-access groups and understand the level of effort and amount of resources the anti-access groups are willing to expend to reduce and drastically close access to multiple-use/OHV recreation on the PSI (the Wilderness Society alone had 58 pages of comments listed in Appendix D).
   • We suggest that our constituents review and read the comments that the TPA/COHVCO has submitted for the project scoping phase (TPA comments begin at Submittal Comment No. 1062, pg. D-226)
   • This is just the beginning of the process and will continue for about another year, and it will be very important for folks to remain engaged, go to future meetings and once again prepare and provide at least one more round of meaningful and substantive public comments. Public comments are not required at this time. Form letters do little, each of us must continue to be specific about what is important to us, which routes are important to us and why. A good example of scoping comments was prepared and submitted by the Central Colorado Mountain Riders (Submittal Comment No. 935, pg. D-47).

4. What can you do now?: Maintaining periodic dialogs with your local PSI, USFS, District Ranger staff will continue to be important to better understand all of the issues and challenges. Also, helping to inform and educate your local elected officials, local leaders and business owners on the positive economic impacts of OHV recreation and the potential for substantial and extensive loss of routes, roads and trails on USFS lands in the PSI.  When speaking to elected officials, be sure to have a plan, an organized list of discussion topics and make sure to do your homework regarding the discussion topics that are important to your respective local officials and business owners.
5. The PSI Public Motor Vehicle Use EIS project and the resulting decision will likely have long-term implications for multiple-use/OHV recreation nationwide on all USFS lands, and the importance of this decision cannot be understated.

Palisade Plunge Trail

Katie Stevens
Field Manager
Grand Junction Field Office
2815 H. Road
Grand Junction, CO 81506

Dear Katie:

Thank you for your quick and detailed response to our request for an update on the Palisade Plunge Project. It is unfortunate that the BLM did not receive any comments from the motorized community on the Palisade Plunge Trail (Perhaps the future public outreach process can better identify and notify a broader cross section of potential users and affected citizens). The Trails Preservation Alliance (TPA) along with Colorado Off-Highway Vehicle Coalition (COHVCO) did indeed submit comments to Great Outdoors Colorado on April 21, 2017 and a copy of those comments are provided with this letter.

We believe that the TPA understands and appreciates the political climate and emphasis associated with the Palisade Plunge Trail Project along with the prominence placed on the Colorado the Beautiful “16 in 2016”. However, we strongly feel that the idea of a single user group recreation trail, with limited accessibility and projected use and a relatively high cost (e.g., NEPA cost, actual construction costs, ongoing maintenance costs) is not the best use of funds from any source. Our concern expands on this issue when the more than $3million project cost is recognizing as exceeding the amount that the trails program has available for all other non-motorized projects in the state. This project, as currently planned, lacks any consideration for multiple-use recreation and users of motorized means. Proceeding with this project with a single, primary use by one particular user group is discriminatory and will certainly foster resentment and poor relationships with other user groups.

Nationally, years ago land managers and the motorized community collectively resolved that segregation and discrimination was a policy that was iniquitous and should no longer be tolerated and fostered, yet the Palisade Plunge Project, as currently planned, seeks to do just that. The Grand Junction Field Office has a unique opportunity to set an example to shift from an attitude and policy of segregating users and providing infrastructure for select user groups at the cost of others, to providing a true multiple-use trail for a diverse spectrum of users. We would offer that the landscape is just no longer big enough to offer trails and associated infrastructure dedicated to unique, distinct or small user groups (i.e. hikers, mountain bikes, equestrians, motorized users, etc.).

The concept of a trail that offers financial and economic assistance to area towns and a private ski area is certainly admirable and honorable. However, this same project, with some relatively minor modifications to construct a true multiple-use trail, could be an exceptional opportunity to expand and compound those same positive economic impacts by embracing a broader and more diversified set of users. A recently completed study commissioned by the COHVCO and the TPA has shown an annual contribution of $2.3 billion to Colorado’s economy from tourism and sales activity directly associated with off-highway vehicle recreation (https://www.coloradotpa.org/2017/01/25/economic-contribution-of-off-highway-vehicle-recreation-in-colorado/).

The TPA would also like to offer that the non-motorized users of the Grand Junction Field Office’s area, most notably the mountain bike community, has benefited significantly from the expenditure of State of Colorado OHV grant dollars on true multiple-use trails throughout the Field Office’s areas. To move forward with this Palisade Plunge Project, with a primary use of mountain bikes and other non-motorized users would be prejudicial and discriminatory to the motorized users in your community and those served by your Field Office. Many of those same motorized users have worked diligently over the past several years with the Grand Junction Field Office to obtain and expend hundreds of thousands of dollars within the Field Office’s area, all the time sharing those trails with all non-motorized users. If the Palisade Plunge Project were designed to be a multiple-use trail, Colorado OHV grant dollars could possibly be used for construction and future maintenance.

We also feel compelled to point out that trails and infrastructure for bicycles, especially mountain bikes have been escalating throughout the State despite somewhat flat, and in some instance declining per capita sales and use. Non-motorized trails, primarily used by mountain bikes, have proliferated both officially and unofficially on public lands, as you are very much aware of. Similarly, many if not most commercial ski areas are also adding trails for mountain bikes to their footprints without those trails and opportunities ever being captured by the Federal Land Manger’s inventory, maps or Recreation Opportunity Spectrum (ROS) analysis. Therefore we challenge that the Palisade Plunge Project is just one more addition to an already burgeoning inventory of trails for a small, select and declining demographic, a trail without a dedicated source to fund its construction or maintenance; all the while at the expense and exclusion of countless other users of public lands. We would also offer that the expected growth in e-bike sales will soon be a major recreational activity that must be recognized, positioned on and apportioned some ration of the landscape in addition to the myriad of existing activities. Will e-bikes simply be relegated to historic motorized trails (e.g., Moab), a prescription we believe is inappropriate, undesirable, and inappropriate or will e-bikes be allowed on trails like the Plunge?

The TPA appreciates the motorized recreation that the Grand Junction Field Office’s has helped develop to date. However, we feel a couple of issues deserve our perspective. Many of the, multiple-use/motorized examples you mentioned have been in the works for years, and are just now being approved and funded. We sincerely appreciate these projects and all of the efforts by your staff to bring these projects to fruition. However, we feel compelled to point out that all of these projects are multiple–use trails and projects and will be available to all user groups. While projects like the Palisade Plunge Project are for a very small, exclusive user group. The TPA staff and volunteers have ridden most of the areas you mentioned, and also most of the new areas east of Gateway in the former uranium mining areas. In fact we rode and inventoried this area in detail with the BLM staff as they were mapping and gathering data for the Resource Management Plan

Once again, we emphasize that the Grand Junction Field Office has the opportunity to establish a new paradigm for the coexistence of trail users and promoting tolerance and diversity of users. Instead of excluding users, a broader spectrum of trail users will benefit if the Grand Junction Field Office will work with vigor and diligence to encourage an attitude of cooperation and tolerance among all user groups. The planning for the Palisades Plunge Project needs to step back in order to be more inclusive and provide an opportunity for all user groups to include motorized use. The most expedient path forward in our judgment would be to develop this new trail in a way that it is truly “multiple purpose” and will provide shared opportunities for all users, non-motorized and motorized alike.

We thank you for considering our comments.

Sincerely,
Don Riggle
Director of Operations
Trails Preservation Alliance