US Forest Service -Region 2
VIA Electronic portal submission only
Re: Proposed 20/21 project list under GAOA
Dear Sirs:
The above Organizations welcome the opportunity to voice our support for the proposed Region 2 list of projects for the 2020/2021 season under the Great American Outdoor Act (S 3422) (hereinafter referred to as “the Proposal”). The Organizations support the current list of projects as they are diverse in nature and badly needed. Our concern is that partners were not well engaged in the development of the list despite the huge amount of funding that these partners have provided for decades, which could be problematic moving forward. The Organizations vigorously assert that existing resources must be leveraged as a springboard for success rather than seen as a reason to allocate money away from partner efforts and resources in order to avoid the creation of a priority list of projects such as was compiled by Region 2 in response to the passage of the National Trail System Stewardship Act in 2016.
Prior to addressing the specific concerns, the Organizations have regarding the Proposal, we believe a brief summary of each Organization is needed. The Colorado Off-Highway Vehicle Coalition (“COHVCO”) is a grassroots advocacy organization of approximately 250,000 registered OHV users in Colorado 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. The Trail Preservation Alliance (“TPA”) is a 100 percent volunteer organization whose intention is to be a viable partner, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of trail riding. The TPA acts as an advocate of the sport and takes the necessary action to ensure 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 the more than 30,000 winter motorized recreationists across the state to enjoy their passion. CSA has also become the voice of organized snowmobiling seeking to advance, promote and preserve the sport of snowmobiling through work with Federal and state land management agencies and local, state and federal legislators telling the truth about our sport. For purposes of this correspondence TPA, COHVCO and CSA will be referred to as “The Organizations”.
The Organizations were heavily involved in the development of the GAOA and were able to spend days with Congressional staff on snowmobiles in Colorado. USFS staff so staff was able to directly understand the grim funding situation of land managers and the huge role that partners now play in funding basic management on public lands. Several of the pictures that were taken by Congressional staff on this ride were used on the Senate floor in speeches and support documentation for the GAOA passage. The Organizations have partnered with land managers through the CPW Trails program for decades to provide direct funding for management and maintenance of trails and related resources, which now exceeds $7 million annually.
The Organizations support the diverse nature and quality of the projects that are proposed in the 2020/2021 project list, as there is far better diversity of projects and interests in this list than previous priority project efforts compiled by the Region in 2018. The Organizations were not aware of many of the efforts that were addressed in the 2020/2021 project list, which is encouraging and troubling all at the same time. The Organizations have extensive involvement with the allocation of funding in the CPW trails program, which has been the primary source of project money for land managers over the last several years. The Organizations are aware that the current list of projects has been prepared at a hugely compressed timeline given the short timeframe provided for in the GAOA.
The Organizations would ask that moving forward with GAOA implementation that the partner involvement be GREATLY expanded on the project list. The Organizations can see a HUGE amount of benefit to land managers with better collaboration of these projects with partners working at the scale of the Organizations. Unlike every other user group, the motorized community has consistently provided land managers with direct funding available for capital and maintenance projects and would like to coordinate on these efforts moving forward. The Organizations would like to avoid project lists like the priority trail list that was created by the Region in 2018 in response to the passage of the National Forest System Trail Stewardship Act of 2016. This list lacked the diverse nature of the projects and was largely centered on Wilderness areas, which are some of the most expensive areas to maintain and are also some of the least used trails in the Region. This was insulting to partners and the public who were using other areas far more frequently.
A primary concern from the Organizations would be maintaining the diverse nature of projects on the list. The Organizations have worked hard to provide significant funding to land managers throughout the state and this funding has maintained opportunities for all user groups. As a result, we are concerned there could be a perception that interests that have not worked with the USFS in the manner the Organizations have could be more needy of funding to maintain or repair facilities. Unfortunately, this reallocation of funds has occurred in the past as exemplified by the list of priority trail list of projects created by Region 2 in 2018, where multiple-use access or partner resources clearly was not a priority for the development of the list. This was simply insulting to the partners who work so hard to support land managers and have been the only source of direct funding for management operations when budgets have almost totally evaporated previously.
The only reason this perception could be factually accurate is from the SUCCESS of the CPW Trails program in maintaining and protecting recreational opportunities and this success should never be seen as a negative. It is our position that the success of this program must be seen as a springboard for further success on the ground and not as a reason to direct money to projects that don’t have this infrastructure. No other user group has provided almost 400 seasonal hired employees, dozens of pieces of maintenance equipment such as dozers, skid steers and mini-excavators to land managers. This foundation for success must be used and not seen as a reason to allocate funding to other projects.
Please feel free to contact us at any time to discuss this support and how to collaborate on the development of future lists under GAOA. Our contact info is Scott Jones, Esq. at 508 Ashford Drive, Longmont, CO 80504. His phone is (518)281-5810 and his email is scott.jones46@yahoo.com or Don Riggle at 725 Palomar Lane, Colorado Springs, 80906, Cell (719) 338- 4106. We are also aware that the State Trails Committee and Program would openly welcome such a collaboration with land managers moving forward.
Respectfully Submitted,
Scott Jones, Esq.
CSA Executive Director
TPA & COHVCO Authorized Representative
Don Riggle
Director of Operations
Trails Preservation Alliance