July 22, 2026
Bureau of Land Management
Vernal Field Office
170 South 500 East
Vernal, Utah 84078
Re: Dinosaur North Travel Management Plan
DOI-BLM-UT-G010-2026-0122-EA
Dear BLM Planning Team:
Please accept this correspondence from the above organizations as our official comments regarding the BLM’s reassessment of its Travel Management Plan (TMP) in the Dinosaur North planning area.
1. Background of Our Organizations
In our comments, the “Organizations” will refer to the following four groups:
Colorado Off Road Enterprise (CORE) is a motorized action group based out of Buena Vista Colorado whose mission is to keep trails open for all users to enjoy. CORE achieves this through trail adoptions, trail maintenance projects, education, stewardship, outreach, and collaborative efforts.
The Colorado Off-Highway Vehicle Coalition (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.
Ride with Respect (RwR) was founded in 2002 to conserve shared-use trails and their surroundings. Since then, over 750 individuals have contributed money or volunteered time to the organization. RwR has educated visitors and performed over twenty-thousand hours of high-quality trail work on public lands.
The Trails Preservation Alliance (TPA) is an advocacy organization created to be a viable partner to public lands managers, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of motorized trail riding and multiple use recreation. The TPA acts as an advocate for the sport and takes necessary action to ensure that the USFS and BLM allocate a fair and equitable percentage of public lands to diverse multiple-use recreation opportunities.
2. Introduction
Along with the Ashley National Forest, the Dinosaur North planning area provides the primary OHV riding opportunities for Vernal and Dutch John by going up Brush Creek, over Diamond Mountain, and down into Browns Park. The emerging recreation economies and lifestyles of these towns includes non-motorized recreation, which can utilize places like the High Uintas Wilderness and Dinosaur National Monument, while motorized trail riding depends on less restricted public lands that still have compelling terrain. In northeast Utah, these criteria are primarily met in parts of Ashley National Forest and the Dinosaur North planning area.
3. Comments of the American Motorcyclist Association
The Organizations support the July 21, 2026 comments of the American Motorcyclist Association, including the BLM's responsibility to:
1. Provide an adequate system of roads and trails per the Multiple Use Sustained Yield Act of 1960 and Bipartisan Infrastructure Act of 2021,
2. Create additional opportunities for motorized and nonmotorized access per the Explore Act of 2025,
3. Expand access to public lands and waters for recreation, hunting, and fishing… while promoting a wide range of outdoor recreation opportunities like hunting, fishing, hiking, biking, skiing, climbing, boating, off-roading, and wildlife viewing per the "Make America Beautiful Again" executive order, and
4. Manage OHV riding like any other form of outdoor recreation per EO 14408 that relieves the BLM from outdated "minimization criteria" by rescinding EO 11644 and EO 11989.
The organizations incorporate the above listed points into these comments to be analyzed by the BLM.
4. Promoting wilderness characteristics outside of wilderness areas
The Organizations caution against promoting wilderness characteristics (WC) outside of wilderness areas for several reasons. Lands with WC shouldn't be managed for WC, and even Natural Areas shouldn't be managed solely for WC according to the BLM's past rationale for these "discretionary" designations.
Where the 2017 Settlement Agreement refers to minimizing damage to public lands with BLM-inventoried wilderness characteristics, it refers to minimizing damage to those public lands, not minimizing damage to the WC themselves. Furthermore where the 2017 Settlement Agreement refers to considering the potential damage to any constituent element of WC, it directs the BLM to consider such damage, but it doesn't direct the BLM to minimize such damage. If the 2017 Settlement Agreement were to direct the BLM to minimize impacts to WC, it probably wouldn't have been approved by the court, which cautioned against creating de facto wilderness in its 2018 dismissal of Utah's appeal.
Furthermore anti-buffer language is a prominent part of the Dingell Act and previous legislation designating wilderness in Utah. In the past couple of years, even more reasons emerged for the BLM to avoid promoting WC in the planning areas, specifically recent Supreme Court decisions such as Loper Bright Enterprises v. Raimondo, June 28, 2024 that reaffirmed the judicial review of an agency's legal interpretation. The BLM should be cognizant of the extent to which decisions like restricting OHV access to promote WC is actually grounded in legislation. When clear authorization is lacking, administrative actions are now more likely to be ruled a bypass of requirements such as the Section 603 release and Section 202 multiple-use mandate of FLPMA. The argument for restricting OHV access to promote WC could be unavailing if that exercise is wholly or partially beholden to administratively-created special designations that wind up no longer holding under the glaring Congressional authority of the Section 603 release and Section 202 multiple-use mandate of FLPMA.
The Organizations don't expect access everywhere, and there may be reasons to restrict it, but restrictions that promote WC outside of wilderness areas are subject to legal scrutiny now more than ever.
5. Sound
Section "AIB-9: NATURAL SOUNDSCAPES" on Page 19 of Appendix B claims that "OHVs generate, on average, between 75 and 97 dBA at a distance of 50 feet. Decibel output can vary widely between different types of OHVs depending on types of engines, size, and throttle position." The only way that these figures could be accurate is if they pertain to a full-throttle scenario such as the EPA vehicle testing procedure (SAE J331) that's done under full acceleration of the vehicle to determine maximum sound. OHVs are more typically operated at half-throttle on average, which yield sound levels that are something on the order of 20 dBA lower than the figures of 75-97 dBA, so they should be corrected to reflect realistic conditions.
6. Incompleteness of the current TMP
When analyzing the alternatives, it's critical to recognize the incompleteness of the current TMP. The 2008 Vernal RMP acknowledged that its route inventory needed revising and its TMP needed refining, as Page 22 states "The TMP will be further refined within one to five years from the approval of the ROD. The same interdisciplinary team process will be followed for revising the baseline inventory." This work wasn't completed, so the 2014 Vernal RMP Evaluation on Page 5 states "The Record of Decision (ROD) and Approved Resource Management Plan (RMP) (October 2008) directs the Bureau of Land Management (BLM) Vernal Field Office (VFO) to complete a Comprehensive Travel and Transportation Management Plan for all the BLM-managed public lands located in Daggett, Duchesne, and Uintah Counties, and a small portion of Grand County, Utah. The Vernal FO is in the process of developing a Comprehensive Travel and Transportation Management Plan." Likewise the 2026 Vernal RMP Evaluation on Page 14 states "The RMP’s TMP has not been fully implemented." Since the current TMP is incomplete and it hasn't been implemented on the ground let alone enforced, it doesn't represent current use of the area, which is far more extensive.
7. Alternatives
The new route inventory appears to capture virtually all of the high-value existing routes, but not every existing route, which should be noted when analyzing an alternative.
It's also important to incorporate the trails master plans that Uintah and Daggett counties extensively developed and incorporated into their general plans.
Alternative D is the only one that incorporates county planning and all the high-value routes, although some isolated elements of Alternative C are acceptable, which could be combined with the rest of Alternative D.
8. Specific routes
Given time constraints, the Organizations will just provide a couple examples of routes that have great recreational value.
Sears Canyon provides just one of three ways for motorized-trail enthusiasts to connect Diamond Mountain with Browns Park. The old road is primitive, yet its whole length is feasible for novice-intermediate riders to traverse and feasible for land managers or partners to maintain. The creek, rock formations, and views into Wyoming are remarkable.
Looking back through the 2007 Vernal DRMP, we see that the maps showing this area as OHV Closed have a light-gray line down Sears Canyon that actually refers to a drainage, but was likely confused with the dark-gray lines that indicated routes which could represent a corridor through the OHV Closed area. The Vernal RMP lacked written analysis of this and other OHV Closed area designations. Whatever the reason, it's worth amending the RMP to accommodate continued enjoyment of Sears Canyon.
Rye Grass Draw is another one of the three links from Diamond Mountain to Browns Park. As with Sears Canyon, it provides a more primitive opportunity than Crouse Canyon, plus it could be passable when Crouse Canyon floods. So long as the Rye Grass Draw road isn't improved to Class B, then it can utilize federal and state OHV funds to be reshaped or relocated if issues arise with the pipeline company or private land owner.
9. Conclusion
By considering the recreational value of each route and the visitors' preferred route characteristics (such as providing challenge, as sense of flow, intimacy with one's surroundings, and variety of terrain), land managers can develop a TMP of enough quality and quantity to ensure both visitor satisfaction and compliance, which in turn conserves the surrounding lands and resources.
Sincerely,
Clif Koontz
Executive Director
Ride with Respect
Chad Hixon
Executive Director
Trails Preservation Alliance
Scott Jones, Esq.
President/Founder
Colorado Off Road Enterprise
Marcus Trusty
Authorized Representative
Colorado Off-Highway Vehicle Coalition
Supporting Documents:
AMA comments dinosaur TMP