Archive | September, 2022

Extensive closures are proposed to world-class trails in the Labyrinth Rims and Gemini Bridges area.
The BLM needs your input to protect them!

– Comments are due Friday, October 7th –

– Comments are due Friday, October 21st –

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

What’s going on?

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

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

Dead Cow/Tubes – a route that is proposed to be closed

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

• Alternative A would leave open 1,057 miles to all uses and 71 miles to ATVs and/or motorcycles.
• Alternative B would close 438 miles and place new restrictions on another 13 miles.
• Alternative C would close 168 miles and place new restrictions on another 50 miles.
• Alternative D would close 53 miles and place new restrictions on another 30 miles.

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

Check out this informative video from CORE!

How to Comment Effectively

Check out this new video from Chad of TPA and Marcus of CORE sharing how to make your comments most effective.

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

Tell the BLM about yourself:

• Who you are, where you’re from, what activities you enjoy in the Labyrinth Rims/Gemini Bridges planning area, and how much money you spend locally when visiting (dining, recreational equipment, hotels, fuel, etc).
• Emphasize if you are a multi-use recreationist. Include all the activities you enjoy in the area, and what characteristics you look for in a route.
  Examples: floating Labyrinth Canyon by raft or canoe, riding your dirt bike on Dead Cow, 4WD on Hey Joe, mountain bike on the Magnificent Seven.
• The variety of benefits that the area’s motorized routes provide to you (exercise, thrill-seeking, skill building, family time, connection with nature, etc.).
• That you support the comments submitted by local, state, and national groups (RwR, CORE, TPA, etc).

Taylor Canyon – a route that is proposed to be closed

Then ask the BLM to:

• Support Alternative A. In 2008 the TMP closed over 40% of inventoried routes plus around 200 miles of non-inventoried routes, thereby balancing motorized recreation with non-motorized recreation and natural resources. This is especially worth noting given the significant amount of non-motorized opportunities that surround this planning area.
• Recognize that the State of Utah is increasing its support of trail work, education, and law enforcement in the planning area. The new DNR Division of Outdoor Recreation is hiring staff to do more trail work and enforcement patrols specifically in southeast Utah. Further, Utah’s new Off-Road Vehicle Safety Education Act will require (a) all OHV operators to complete an education course, (b) all ATVs to display license plates for easier identification, and (c) vehicle operators who are convicted of going off-trail to repair their damage through community service. With these additional resources, the BLM will be able to effectively implement alternative A and resolve any issues with the status quo.
• Take an educational approach to reduce recreation conflicts. Separating trail uses is appropriate to some degree, but additional closures should be thoughtfully evaluated. The BLM should promote education and trail etiquette efforts before resorting to hundreds of miles of closures, especially considering the recent surge in users who are new to backcountry trails. In addition, the promotion of tolerance among diverse recreationists will help alleviate user conflicts.
• Protect wildlife by gaining full compliance with the current TMP. Wildlife enhances all recreational experiences. To effectively improve wildlife habitat, the BLM should focus on the enforcement of existing closures rather than expanding closures and adding to the burden of implementing and enforcing them.
• Fully value the economic contribution of motorized trail use. The Proposal lacks evidence for its assumption that all types of visitors spend similar amounts of money to recreate in the area. Research demonstrates that most motorized trail users spend far more than other recreationists. For example, rental OHVs average $300 per day plus a tax rate of over 18% in Moab while most non-motorized gear rental is under $100 per day, plus a tax rate of under 9%.
• Recognize that closing motorized trails would decrease positive impacts to the local economy and increase negative impacts to natural resources. The Proposal lacks a basis for its assertion that only 7,348 visitor days (20 people per day) would be lost annually if Alternative B were chosen. In fact Alternative B and even some routes in Alternative C would result in either (a) far more visitor days lost, (b) far more traffic on the remaining routes which would make them less sustainable, or (c) far more use off of designated routes which would disorganize travel patterns and increase negative impacts.

Monitor and Merrimac buttes – a route that is proposed to be closed

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

Make Comments

To comment online and get more information on The Proposal:

Email:
If commenting online fails, email the comments with the subject line “Labyrinth/Gemini Bridges Travel Management” to:
blm_ut_mb_comments@blm.gov

Postal mail:
Bureau of Land Management
Attn: Labyrinth/Gemini Bridges Travel Management
82 East Dogwood
Moab, UT 84532

Mashed Potatoes  – a route that is proposed to be closed

More Information

• Comments made by Colorado Trail Defenders (COTD) Extensive route-specific comments (large file)
• Final comments sent by the TPA and Ride with Respect on October 21, 2022: Labyrinth Rims/Gemini Bridges Travel Management Plan Comments

Deadline Next Friday!

Comments are due on Friday, October 7, 2022  Friday, October 21, 2022 so speak up for motorized opportunities today!

The Final Record of Decision (ROD) has finally been made for the long-awaited Pike and San Isabel National Forests (PSI) Motorized Travel Management (MVUM) Analysis project.  The Trails Preservation Alliance (TPA) has been involved in representing and preserving the sport of motorized single-track trail riding within the boundaries of the PSI and, specifically this project since the very beginning.

The area encompassed by this ROD includes approximately 2,206,400 acres and encompasses all US Forest Service (USFS) lands within the boundaries of the PSI in the six mountain Ranger Districts—Leadville, Pikes Peak, San Carlos, Salida, South Park, and South Platte.  The PSI is spread over 15 counties in Colorado: Chaffee, Clear Creek, Costilla, Custer, Douglas, El Paso, Fremont, Huerfano, Jefferson, Lake, Las Animas, Park, Pueblo, Saguache, and Teller.

The USFS started issuing Motor Vehicle Use Maps (MVUMs) for the Pike and San Isabel National Forests (PSI) in 2009, graphically depicting updated routes open to public motor vehicle use. The PSI was subsequently challenged in court by conservation and environmental centric citizen groups contending that the USFS did not meet its agency obligations under the National Environmental Policy Act (NEPA) and other federal legislation to analyze the impacts of designating routes on the PSI MVUMs. Parties to the lawsuit eventually reached a settlement agreement in 2015.  In response to this settlement agreement, the USFS conducted the NEPA analysis in the Pike and San Isabel National Forests Motorized Travel Management (MVUM) Analysis. This ROD finalizes the Decision on this analysis and selected Alternative C with some modifications.

From a global, overall sense, the TPA is pleased to report that the ROD maintains the majority of current routes, roads and trails open for recreation and forest access, especially motorcycles and the network of routes (roads and trails) remains much the same as it was when the project began back in 2015.  However, there is in fact a net loss of miles of routes open to recreational uses by approximately 4% when compared to the miles of routes that exist today or to the No Action Alternative (Alternative A).  Many of the routes that will be lost to public use provide access to private lands/in-holdings or to utilities, are dead ends or are redundant.  The TPA does not condone or support the closures, however, the ROD could have been much worse for motorcycle recreation that it is.  All of the significant and destination riding areas like North Rampart, Rainbow Falls, North Divide (i.e., 717 system), The Rainbow Trail, Greens Creek, Continental Divide Trail, Four Mile, Badger Flats remain accessible to motorcycle and OHV recreation and remain very much the same as they were before the project began.  There are however more significant losses to recreational uses by full size 4WD vehicles, UTV’s etc. such as the permanent closure of The Gulches (Longwater, Metberry and Hackett Gulches) beyond where the roads change from Teller County jurisdiction to USFS jurisdiction.  Probably the most significant change that supporters of the TPA will notice because of this ROD, is a considerable number of routes that will now be affected by Seasonal Closures. For example, over 575 miles of routes will now have Seasonal Closures added and almost 243 miles of routes that were subject to Temporary Seasonal Closures (e.g., Rampart Range Road, Mount Herman Road, etc.) will now have Permanent Seasonal Closures.

Some notable positive aspects of the ROD included the conversion of select “roads” to “trails open to vehicles” rather than being closed or decommissioned.  The recently relocated Captain Jacks’ trails (near the Bear Creek Watershed area) will remain open to motorcycle use, only 1.73 miles of motorized routes were lost/converted to non-motorized use and existing motorized uses on the Continental Divide National Scenic Trail (CDNST) will continue as is.

The TPA’s comprehensive and meticulous efforts and involvement since the project began (which included joining the original lawsuit as an Intervening Party on behalf of the USFS) coupled with our expansive local knowledge of the routes and PSI landscape by both the TPA and our affiliated clubs proved to be tremendously beneficial.  Likewise, the TPA’s forging new partnerships with other OHV user groups like Colorado Off Road Enterprise (CORE) and Colorado Off Road Trail Defenders amplified and improved our effectiveness in guiding and influencing the Decision and protecting our access to PSI lands for motorized recreation.  There should be no doubt the Decision would have been much different (i.e., worse) and the closure of routes much more prolific without the efforts of your TPA, our staff, our consultants, our clubs and our partners.

Record of Decision PSI MVUM Analysis – USFS Project 48214

Prepared by W. Alspach, Trails Preservation Alliance, October 2022

1. The Record of Decision (ROD) was issued on 26 Sep 2022.
2. The ROD covers 2,206,400 acres of USFS Pike and San Isabel National Forest lands, managed by six Ranger Districts – Leadville, Pikes Peak, San Carlos, Salida, South Park and South Platte.
3. Selected Alternative in the ROD: Alternative C with modifications.
4. Public involvement: Three meetings held in 2016. 3,870 discrete and unique comments received during the Scoping Phase.  3,148 individual comments received during the 45-day comment period for the Draft EIS (DEIS).  2,007 unique statements were considered to be “substantive”.
5. Summary of changes promulgated by the ROD to the current USFS Route System:

6. Summary of Modifications to Alternative C from Draft ROD:
   1. The Badger Flats area is omitted from this Decision and will be designated as per the separate Badger Flats Decision Notice, 14 Jun 2018.
   2. The Sheep Mountain Management Project (e., Sheep Mountain motorcycle single-track trails) has been removed from this Decision and will be managed per the Sheep Mountain Management Project Final Decision Notice, 29 Jun 2020.
   3. The majority of the changes are otherwise related to seasonal closures.
      1. Changes related to seasonal closures
         1. Add a seasonal closure to 9 miles of routes.
         2. Add a seasonal closure to 1 miles of a new NFS route.
         3. Define dates public motorized use is allowed on 7 miles of routes having seasonal closures.
         4. Define seasonal closures on 16 miles of routes previously selected for closures in the draft ROD.
      2. Changes related to the forest plan amendment
         1. Adjust the boundary of the Management Area 3A (MA-3A) outside of the NFSR 126 (aka Twin Cone) route to the end of the segment open to public motorized access. The last segment of NFSR 126, which will not be open to public motorized access, will remain in MA-3A. This will result in approx. 13 acres of MA-3A being converted to MA-7A.
         2. Reduce the buffer around NFSR 398 (aka Lost Canyon) and NFSR 398.B (aka Lennie’s Overlook) to 300 feet on either side of the road center line, resulting in approx. 173 acres of MA-3A being converted to MA-2B.
7. Summary of other considered Alternatives: Alternative A, the no action alternative, would have provided the most motorized recreation, as it includes the most miles of roads and trails open to public motorized access. Of the action alternatives, Alternative D would provide the greatest number of roads, trails, and areas open for public motorized access, but it would reduce the number of miles by about 3 percent, compared with Alternative A. In contrast, Alternative E would reduce the miles of routes available for public motorized access by 50 percent compared with Alternative A.
8. Alternative C will not close every route that was suggested by some public comments, nor does it expand the number of routes open to the public to the extent requested by other public comments. Modified Alternative C will reduce the miles of routes available for public motorized access by around 4 percent {4%} compared to Alternative
9. Per page 20 of this Decision, “the modified Alternative C will provide reasonable recreation opportunities while providing for resource protection, as is required under multiple use management”.
10. Regarding an aging population [per page 21]: “I recognize motorized recreation accessibility for an aging population may be affected by the increased restrictions on motorized use. Similarly, those with ambulatory difficulty may be affected by the reduction in motorized route access; however, while motorized access may be reduced in some areas, designating 85 parking locations under the modified Alternative C will support access and recreation opportunities for forest users”.
11. Regarding E-bikes [per page 21]: “In the years since the Notice of Intent to publish an EIS for this project was published in the Federal Register, electronic bikes (e-bikes) have gained in popularity and use on National Forest System lands. The US Forest Service recently released new directives for the management of e-bikes on roads and trails (FSM 7710). The directives confirm that the agency will manage e-bikes as motor vehicles under the Travel Management Rule (36 CFR 212, Subpart B) and Executive Order 11644 (as amended) and added definitions of e-bikes (including three different classes) to the agency policy (FSM7700). Consistent with the new directives, this decision recognizes e-bikes are included as motorized vehicles on routes identified as open for public motorized access. Also consistent with agency directives, future projects may identify routes open only to e-bikes or designate some non-motorized routes as open to e-bikes after additional environmental analysis. Given that the final directives regulating management of e-bikes on NFS lands were published in March 2022, after the draft Record of Decision was released, this Travel Management decision is not the appropriate time to consider the use of e-bikes on the PSI”.
12. National Trails System Act, Continental Divide National Scenic Trail (CDNST) [per page 32]: “This act established the Continental Divide National Scenic Trail, (CDNST) which passes through the PSI. Though the National Trails System Act intends that National Scenic Trails be established for hiking and horseback use, the 1978 amendment specifically provides for limited motorized use. According to policy, motor vehicle use by the general public is prohibited on the CDNST unless that use is consistent with applicable land management plan, is designated in accordance with 36 CFR Part 212, Subpart B, and the segment of the CDNST was constructed as a road prior to November 10, 1978. A detailed description of the number of miles of roads and trails intersecting or co-locating with CDNST segments is provided in Appendix B of this document. My decision to designate the modified Alternative C does not change any National Recreation Trail management and complies with the National Trails System Act”. 
Additional information is contained in Appendix A-1.
13. Implementation [per page 35]: “This decision will be implemented on the date of publication of the updated Motor Vehicle Use Maps [MVUM] for each ranger district. Although construction or other changes on the ground may begin immediately, the revision of the maps for all six districts is expected to take up to two years. Some changes may require additional time to be fully implemented”. 

14. Responses to select TPA submitted Objections:
    1. Wildcat Canyon [See Appendix A-1, page A-4]: No change from Alternative C, all routes remain closed.
    2. Continental Divide National Scenic Trail (CDNST) [See Appendix A-1, page A-7]: “I have determined that the draft ROD adequately discloses that establishing a management corridor for the CDNST is not within the scope of this analysis. ….. I am directing the Responsible Official to conduct site-specific analyses on routes open to motor vehicle use by the general public that cross the CDNST or co-align with the CDNST to disclose the impacts of the Selected Alternative on the CDNST”.
    3. Seasonal closures on Rampart Range Road (NFSR 300) and Mountain Herman Road (NFSR 320) [See Appendix A-2, page A-36]: “These segments of routes NFSRs 320, 300, and 307 [aka Schubarth] are not plowed or maintained during winter, and remain unpassable in places even when lower routes or south-facing slopes may be quite clear. As a result, public regularly venture onto routes in winter months, become stranded, and either damage the road or other resources or require assistance for extraction. The Forest has worked with the local Search and Rescue providers to determine these routes are not appropriate for year-round public motorized travel, and issued these winter seasonal closures for public safety and resource protection. When the road is used to access private lands, such as NFSR 307, the seasonal closures will be implemented past the private access points to insure landowners maintain access to private property”.
    4. Of the TPA’s 12 specific objections, not all received specific responses or acknowledgement in the Reviewing Officer’s Instructions. Notable exclusions were:
       1. The lack of new parking areas in the PPRD
       2. Adding new “Open Areas” open to motor vehicles
       3. Specific route closures (e.g., 336.A, 540, 322A, etc.)

15. Overall Generalities and Observations:
    1. Positives:
       1. The network of routes, roads and trails open to OHVs remains pretty much the same, with some routes receiving seasonal closures.
       2. Some roads will be converted to Trails instead of being closed or decommissioned.
       3. Many of the routes being decommissioned are dead end spurs.
       4. Many of the routes converted to Special Use or Admin Use Only are spurs or have a parallel route that does remain open.
       5. The North Divide (e.g., 717 system), Rainbow Falls and North Rampart riding areas remain essentially unchanged.
       6. The Bear Creek Watershed Restoration Project rerouted trails (i.e., 665, 667, 668) remain “as is” in their relocated locations and are not closed.
       7. NFSR 346 (aka Hotel Gulch) remains open despite being shown as closed in the Draft Alternatives.
       8. Some mapping errors/issues have that users identified with routes in the Salida and San Carlos Ranger Districts have been recognized, acknowledged and corrected (e.g., 348-Hope Gulch, 230C-Hoffman Park, 406-Hudson Ditch, etc.)
       9. Only 1.73 miles of motorized routes were lost/converted to nonmotorized use.
       10. Motorized uses on the CDNST will remain status quo.
       11. County Resolutions supporting OHV use on county roads (either on all county roads or select county roads) were likely to have been beneficial to OHV recreational uses on adjoining or connecting USFS routes.
       12. CORE’s comments and efforts were successful in causing some modification/adjustment to the 3A Management Areas for NFSR 398 (aka Lost Canyon), NFSR 398.B (aka Lennie’s Overlook) and NFSR 126 (aka Twin Cones).
       13. The scope and breadth of closures to motorized routes on the PSI sought by the plaintiffs in their original lawsuit was not achieved.
    2. Negatives:
       1. A number of routes, roads and trails will now have seasonal closures. The majority of changes in access to routes will be due to a plethora of new or permanent seasonal closures.
       2. What were temporary seasonal closures are now permanent. For example, Rampart Range Road, Mount Herman Road, the entire North Rampart Riding area.
       3. There were essentially no new or expanded recreational opportunities added.
       4. Hackett, Longwater and Metberry Gulches will all be permanently closed.
       5. Most comments and or objections submitted concerning the PPRD area were ignored, rejected or not accepted and reasons why have not been provided (e.g., parking areas, connector routes, new single-track, inclusion of SRTMP work, etc.),
       6. The miles of routes available for public motorized access will be reduced by 4% over the entire PSI area.
       7. The access for and restrictions on E-bike use on USFS trails is yet to be definitively resolved.