Reprinted with permission
Ride with Respect Year in Review 2022
www.ridewithrespect.org
In 2022, Ride with Respect’s work progressed in every direction, literally and figuratively. Our advocacy of access for responsible recreation stretched from the Arizona border to the Wyoming border, while our education and trail work is laying the ground work to match the scale of motorized use around Moab (see attached photos).
To do more than ever before, RwR has also had to spend more on things ranging from NEPA consultation to heavy equipment. We depend on all trail lovers to chip in, and you can make a tax-deductible donation by writing a check to Ride with Respect, 395 McGill Ave, Moab UT 84532. Please specify if you’d like the receipt to indicate a donation made in 2022.
On top of the many contributions amounting to tens or hundreds of dollars, so far this year has blessed RwR with ten people who contributed between one-thousand and ten-thousand dollars, some of whom have contributed for two decades and counting. We’re counting on new folks to recognize that, even as RwR grows, the organization remains a lean operation and highly-effective way to help save trails.
Finally we give thanks for other organizations’ support of RwR, including the State of Utah OHV Program’s support of OHV trail host volunteers, acquiring incredible tools like an excavator with an off-road trailer, and persevering participation in land management plans. Also in planning matters, RwR continues to enjoy the partnership of the Trails Preservation Alliance, which contributes more than its share. The Grand County Recreation Special Service District funded our maintenance of Sovereign Trail System. Rocky Mountain ATV/MC will provide perks for our OHV trail host volunteers on top of supporting our general operations. Last but not least is a generous grant from Right Rider Access Fund, which is made possible through contributions from MIC, SVIA, and ROHVA. The grant enables RwR to invest in upgraded safety gear for us to maintain trails, educate visitors, monitor conditions, and invite decision-makers to view trails on public lands firsthand.
Trail Work
RwR spent several hundred hours maintaining trails in 2022. On Sovereign Trail, our work included a couple small reroutes of the singletrack, and a couple field trips with managers of the new Utahraptor State Park. The park will eventually charge entrance fees (not just camping fees), but we trust that they’ll improve trails, as their staff has already begun pitching in on Sovereign Trail.
On the Dubinky trail system toward Green River, RwR worked with the BLM to repaint the slickrock blazes and define the designated width (singletrack, ATV, or 4WD) at trail entrances. For three days, we joined the trail crew from Utah’s new Division of Outdoor Recreation (UDOR), which came from Salt Lake City to delineate trails between Crystal Geyser and Tenmile Wash. For another three days, we joined UDOR’s mini-dozer operator to install rolling dips and other tread work on Camp Jackson and Wagon Wheel ATV trails in the Abajo Mountains. We’re pleased to see UDOR’s aim to establish multiple crews around the state, and RwR can continue to help make them as productive as possible.
A half-mile up Gemini Bridges Road, RwR assisted the Moab Friends For Wheelin’ to delineate the free parking area and post rules to respect the property. Property owners Intrepid Potash have generously accommodated public use thus far, so it’s key that we maintain access by refraining from camping or leaving any litter, especially human waste. If nature calls, you can use the vault toilet at the very bottom of Gemini Bridges Road by paying their parking fee. Alternatively, back in the Intrepid Potash parking area, you can use your own portable toilet. Even in more remote areas, you can carry a portable toilet in the form of a disposable sanitation kit (aka WAG bag). Grand County provides bins to dispose of your WAG bags for free. This toilet talk might sound like a load of crap, but when so many recreationists are digging shallow holes behind the same few trees every year, it becomes unsightly and unsanitary (especially if it’s near any kind of water source).
Education
RwR calls out OHV critics for exaggerating or even fabricating negative impacts of riding on other forms of recreation and on the land itself. By the same token, when problems exist, we face them and try to fix them. A small portion of riders absolutely are harming public resources, and they need to be brought into the fold or brought to justice. (To that end, UDOR is dedicating another law-enforcement officer in southeast Utah to join county and federal officers.) Many newer riders don’t know the finer points of a trail ethic, which can also add up, and fortunately Grand County produced a more detailed video about minimum-impact practices.
Also this year, the State of Utah upped its game with the passage of H.B 180, which requires (a) adult OHV operators to complete an online course, (b) all ATVs to have license plates even if they’re not street-legal, and (c) people convicted of driving off of designated routes to repair any damage through community service. You can find out the course requirements on the Utah OHV Program’s website but, since the course is free and takes just half an hour, we encourage everyone to take the course regardless of whether they’re required. RwR provided feedback on an early version of the course, and we’re optimistic that it’ll cover the points everyone should know before they hit the trail. This course along with the license plate and community service requirements should make rider compliance and our ability to advocate access even stronger.
Motorized Trails Committee
In the third year since Grand County established its Motorized Trails Committee (MTC), RwR continued to support it as I (Clif) continued to serve as the chair. RwR thanks all of the MTC members for attending monthly meetings, including county staff, the BLM, and especially the volunteer OHV enthusiasts. County leaders have differed with the MTC on some major issues, sometimes without considering the MTC’s input, but common interests have led to some wins for all parties.
After a couple years of building consensus with the Sand Flats Stewardship Committee and proposing refinements to Hells Revenge and Slickrock Trail, the BLM approved most of the MTC’s requests, which the MTC then implemented. One refinement shown in an episode of At Your Leisure TV was redesignating The Staircase from motorized singletrack to 4WD so that Hells Revenge users could directly return to the entrance after doing the whole slickrock part of the loop. Likewise we redesignated the Black Hole bypass from motorized singletrack to 4WD so that all users would have the option of avoiding exposure to the cliff edge. Also we rerouted the Spillway “dot route” (motorized singletrack alternate of Slickrock Trail) so that riders could park within 100 yards of Mountain View Cave. Finally we reopened the Updraft “dot route” that overlooks the spectacular corridor of Highway 128. Updraft was designated as part of the original Slickrock Trail network over a half-century ago, but it was technically closed by the BLM in 2008, so we appreciate the agency and Sand Flats staff for being open to reopen this inspiring route.
The MTC has faithfully continued to host “rake and ride” trail work each month. Additionally, on Steel Bender (aka Flat Pass) 4WD trail, the MTC made the legal (NE) bypass of Dragon Tail less difficult while blocking off the illegal (SW) bypass. Half the work came from Xtreme 4×4 Tours staff and tow equipment. All these resources were donated, as Grand County has budgeted no funding for the MTC, although the county has budgeted to expand its trail ambassador (education) staff so it can include motorized trails next year.
Moab Camping Management Plans (CMPs)
The BLM proposed Camping Management Plans (CMPs) for the Labyrinth Rims / Gemini Bridges area between Moab and Tenmile Canyon, the Utah Rims area from the Colorado state line to the Westwater put-in road, and the Two Rivers SRMA including several roads that drop down to the Dolores River and Colorado River near Cisco. RwR supports the proposal to limit camping to designated dispersed sites because these areas can’t sustain new levels of camping without defining the sites just as a Travel Management Plan (TMP) defines the routes. Campsites could remain plentiful, dispersed, and free except in specific areas where infrastructure like toilets are needed, which may warrant clustering sites and charging fees in those areas.
However the BLM didn’t pledge to thoroughly inventory the existing sites or indicate which specific sites it plans to designate open or closed. Second it didn’t pledge to provide public review of the inventory or designation of individual sites. Third, if many sites are closed, the proposal would likely displace camping use and impacts to adjacent areas such as north of Tenmile Canyon and west of the Westwater put-in road. Provided a more thorough process, the CMPs should actually encompass larger areas of comparable terrain. Fourth, how the dispersed camping interfaces with designated campgrounds (e.g. no-camping buffers around the campgrounds) or sets the stage to cluster / charge fees for camping in any specific areas should also be subject to public review just like the process of inventorying and designating individual sites. Adding to those four points, RwR partnered with the TPA, COHVCO, and CORE to comprehensively comment.
Grand County’s Motorized Trails Committee (MTC) agreed with the four points above, and recommended them to the county commission. The staff of groups seeking to vastly expand the designation of wilderness (which prohibits mechanized use including bicycling) opposed this request for public review of a thorough campsite inventory and a BLM proposal that actually identifies which sites would be designated open or closed. Fortunately, in this instance, the county commission sided with its MTC. Since then, the BLM has expressed appreciation for the constructive feedback, and pledged to provide more meaningful opportunities for public participation before limiting camping to designated sites in these three planning areas.
San Rafel Desert Travel Management Plan (TMP)
The San Rafael Desert between UT-24 and the Green River is the first Travel Management Plan (TMP) completed from the 2017 settlement agreement, thus setting the stage for the other eleven TMPs in the southeast half of the state. As you may recall from our previous Year In Review, the 2020 San Rafael Desert TMP closed a third of the existing routes. It‘s actually more like half of the existing routes when you exclude the graded roads and highways for which the BLM lacks jurisdiction. True to their “uncompromising” mission, wilderness-expansion groups sued the BLM while OHV groups, the State of Utah, and Emery County intervened in defense of the BLM. The BLM’s Price Field Office staff began to defend the 2020 TMP as reasonable by and large but, by 2022, it became clear that political appointees are directing local staff to essentially throw out much of the work they had performed from 2014 to 2020.
This January the BLM closed another 35 miles of route without doing an environmental assessment because the agency said closures would be temporary and followed by an environmental review that would determine whether each route is open or closed in the long term. OHV groups, the State of Utah, and Emery County appealed the “temporary” closures because this emergency authority is only authorized to prohibit use that will cause a significant adverse effect. In the case of these 35 miles, the BLM only claimed to protect the soil and plants growing on top of the routes themselves. RwR along with the TPA and COHVCO provided a biologist’s report finding only common plants on these old mining roads and motorcycle race courses. Yes, common plants have grown on the routes especially since 2008 when most San Rafael Desert routes were technically closed due to a complete lack of route inventory, and plants even grow on graded roads in the San Rafael Desert due to the nature of migrating sand dunes. Further, the BLM’s rationale could be applied to myriad doubletracks since plants grow in the center hump, yet temporarily closing those doubletracks would be an abuse of the emergency authority. We also pointed out that a closure is “temporary” in name only when it doesn’t even set a timeline goal for the subsequent environmental review. In this case, it appeared that the review would hinge upon the approval of a backroom deal to settle the wilderness-expansion groups’ appeal of the 2020 TMP, which is clearly putting the cart before the horse.
This February the BLM indeed released a settlement deal it had negotiated with the wilderness-expansion groups to the complete exclusion of OHV groups, the State of Utah, and Emery County despite that all of us had intervened on the BLM’s behalf ever since the wilderness-expansion groups sued in 2020. As with the temporary closures, we appealed this new settlement, which requires the BLM to reconsider 195 miles of the routes designated open by the 2020 TMP. In August the BLM finally showed the public the location of the 195 miles of routes, and indicated its preliminary decision to close most of them, but it didn’t indicate the rationale or any analysis that would be found in an environmental assessment as required by NEPA. RwR along with its Colorado partners provided photographs and descriptions of many routes’ recreational value and lack of potential impacts to other social or natural resources.
Without responding to our comments, this October the BLM made very few changes to its preliminary decision, and closed another 120 miles of routes in the San Rafael Desert. The agency’s only explanations were found in the cookie-cutter cells of a spreadsheet, claiming that routes lacked recreational value despite that RwR had painstakingly demonstrated the great value of many routes. The spreadsheet also claims that the routes are “reclaimed” even when the route consists of a wide, non-riparian wash bottom that’s composed of loose sediment. The BLM’s decision blatantly fails to meet NEPA’s requirement to invite public input on a thorough analysis of impacts (which includes the positive impacts of OHV recreation on lifestyles and livelihoods). Naturally OHV groups, the State of Utah, and Emery County appealed this decision which, along with our appeals of the temporary closure and 2022 settlement, ought to compel the BLM to provide proper process and sufficient evidence when closing additional trails. RwR has supported many route closures, sometimes even initiating the closure and implementing it on the ground, but we expect agencies to follow their own rules even when an administration wishes that the legislature had given the agency a different mission.
Labyrinth Rims / Gemini Bridges TMP
The BLM’s 2017 settlement also requires reconsideration of the TMP at Labyrinth Rims / Gemini Bridges, which covers many word-class OHV trails between Moab and Green River. For 22 years, RwR has been very engaged in travel planning there, spending several-thousand hours just in rerouting over a dozen trails away from sensitive resources. As you may recall from our previous Year In Review, the 2008 TMP closed roughly half of the existing routes in Labyrinth Rims / Gemini Bridges, and the most restrictive of the BLM’s preliminary alternatives in 2021 would’ve closed about half of the remaining half of OHV routes when you exclude the nearly 200 miles of graded roads that are outside of the BLM’s jurisdiction. Grand County urged the BLM to consider closing far more than that so, this September, the BLM made its most restrictive alternative more severe by sparing just 495 miles of non-graded routes across the 300,000-acre planning area despite that it’s the primary destination for OHV recreation in southeast Utah.
Grand County’s Motorized Trails Committee dutifully explained how the new more-severe alternative would be completely unnecessary and disastrous for diverse recreation (see the last four pages), but the county commission unanimously voted to send the BLM a letter that supports the new more-severe alternative. Adding insult to injury, the letter claims that “Alternative B still heavily favors motorized recreation.” In 2023, hopefully the couple of incoming commissioners can broaden the perspective of the commission as a whole. Also hopefully the BLM will honestly incorporate comments from RwR and the TPA, that convey the value and integrity of almost all routes in the 2008 TMP. Our comments include a route-specific letter. They also include a wildlife report.
Participating in the Labyrinth Rims / Gemini Bridges TMP alone has cost RwR and the TPA tens of thousands of dollars, which positions us to effectively appeal if the BLM decides to close hundreds of more miles of route. However we’d prefer to defend a BLM decision that more conservatively refines the 2008 TMP so we can focus on the trail work, education, and enforcement efforts that actually achieve conservation.
Ashley National Forest Land Management Plan (LMP)
In national forests, the revision of Land Management Plans (LMPs) or “forest plans” strongly set the direction that TMPs will go. The Ashley is a rather large national forest that already has the High Uintas Wilderness area that occupies over a quarter-million acres of the Ashley, yet this national forest contains few rugged routes that are connected for OHV loops. Clearly the current LMP for the Ashley has made modest trail development difficult, yet the draft LMP would make it even more difficult in most ways, as RwR and other OHV groups explained in our joint comments. For example the draft alternatives would zone even fewer acres in a motorized classification of the Recreation Opportunity Spectrum, which is a prerequisite to even considering the development of a motorized trail on any of those acres for decades to come. RwR identified a half-dozen areas that would be zoned as motorized in only one of the draft alternatives despite that each area has historic motorized use and would be needed for connectivity, such as a motorized corridor between the High Uintas Wilderness and the Uintah and Ouray Reservation to allow any east-west travel by OHV. RwR found motorized zoning to be totally suitable when we visited these corridors with the guidance of local OHV advocates. These historic and potential connections are in fact part of the trails master plans that Uintah, Daggett, and Duchesne counties have spent years developing with USFS input, yet all of the draft alternatives would preemptively block the master plans. The agency’s next draft ought to leave a path open for them to consider such development in the coming decades.
Bears Ears National Monument Management Plan (MMP)
Currently the Bears Ears National Monument (BENM) occupies 1.36 million acres of BLM and USFS land including a couple-dozen ATV trails developed by the local ATV club SPEAR, national-forest singletracks like Vega Creek / Shay Mountain / Indian Creek, and Lockhart Basin 4WD road up to and including Chicken Corners. As you may recall from our previous Year In Review, the State of Utah is challenging the unilateral designation of this monument, and BlueRibbon Coalition has joined this effort. Hopefully it can persuade presidents to reserve their Antiquities Act authority for areas that can’t be protected by some other means, as such areas are few and far between in the modern era.
In the meantime, RwR is faithfully participating in the development of a Monument Management Plan (MMP) for Bears Ears. The existing plans, including an MMP for the smaller version of BENM developed from 2018 to 2020, are already quite restrictive. We would still be open to further restrictions so long as a compelling case is made for the change, but in fact no case was made, as the new draft MMP acknowledges no change. Instead it portrays several of these further restrictions as already being in place despite that the existing plans clearly state otherwise. How can the public evaluate proposed rules when the agencies misrepresent current rules? This falsification of the baseline feels fitting for this monument that, to many longtime stewards of the area, was proclaimed under the false pretense that monument status is necessary to protect antiquities. As with the San Rafael Desert TMP, it seems like the BENM staff would know better, but they’re following marching orders from political appointees.
Whatever the explanation, here are four examples of this erroneous baseline. In terms of the Recreation Opportunity Spectrum (ROS), currently 90% of the USFS acreage is zoned as motorized, yet the draft MMP claims that it’s only 50%, plus it claims that motorized use can take place only in motorized zones when in fact the current definitions allow for exceptions of motorized use in non-motorized zones. If uncorrected, routes like Shay Mountain Singletrack would be summarily closed before travel planning has even begun.
Second, the draft MMP incorrectly claims that motorized use is currently prohibited in Inventoried Roadless Areas (IRAs), despite that the majority of motorized singletrack in the Abajo Mountains is in IRAs. After all, the 2001 roadless rule intended only to prevent road construction, not motorized trail construction (let alone to close existing motorized trails). While the USFS is free to propose that motorized travel be prohibited in IRAs, it can’t pretend that such a prohibition is already in place.
Third, the draft plan makes an oxymoronic claim about BLM Lands with Wilderness Characteristics (LWC) that the plans currently in place had found to be unsuitable in terms of managing for those wilderness characteristics. (Areas that the current plans had found suitable to manage wilderness characteristics are called MWC.) The draft plan claims that currently such areas are “managed to minimize impacts on wilderness characteristics while still allowing discretionary uses.” Actually neither the BLM’s 2008 RMP nor the 2020 MMP direct the BLM to minimize impacts to wilderness characteristics in LWC areas, only in MWC areas.
Fourth, the draft MMP incorrectly portrays the BLM’s San Juan Recreation Management Zone area to be currently designated as OHV closed when in fact most of that area is designated as OHV limited. Designating that area as OHV closed would eliminate several dirt roads that access the river, precluding any discussion during the subsequent TMP review. We look forward to the BENM planners’ recognition of the current rules that are in place, and that these rules are generally adequate for the goals that were claimed by those who advocated for a monument in the first place. What’s lacking more than rules and plans are the resources and teamwork to implement them, particularly as the monument proclamations have diverted resources away from truly caretaking the Bears Ears toward battling the Antiquities Act.
RwR’s comments outlined these and other concerns with the draft MMP as well as our concerns with the proposal from the Bears Ears Inter-Tribal Coalition (BEITC) on behalf of the Bears Ears Commission. The BEITC is funded by wilderness-expansion groups, and its proposal for the MMP aligns with the policy pursuits of those groups. Those groups have also greatly influenced the majority of San Juan County commissioners in recent years. Next year will bring two new commissioners, providing even more ethnic diversity, with indigenous, Latina, and Anglo commissioners. We are optimistic that the commission will also be even more independent-minded when representing the interests of their county community. Although the divisiveness of monument proclamations may understandably linger, there’s potential for improvements independent of monument status, as most people support more recreational infrastructure, education, and enforcement. RwR’s efforts lay a foundation for such management despite the Antiquities Act’s amplification of the political pendulum in the administrative branch.
Conclusion
Progress on public lands has been inconsistent, and it’s far from certain, but it’s still worth pursuing in a principled manner. We appreciate the support that so many trail riders have entrusted in us, as RwR couldn’t do it without you. Happy Trails and Happy New Year.
Clif Koontz
Executive Director
Ride with Respect
395 McGill Avenue
Moab, Utah 84532
435-259-8334 land