June 8, 2026
Bureau of Land Management
Price Field Office
125 South 600 West
Price, Utah 84501
Re: San Rafael Swell & San Rafael Desert Travel Management Plan
DOI-BLM-UT-G020-2019-0019-EA
DOI-BLM-UT-G020-2018-0004-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 Plans (TMPs) in the San Rafael Swell and San Rafael Desert planning areas.
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
The Organizations applaud the BLM for reassessing the motorized routes closed or limited in its San Rafael Swell and San Rafael Desert planning areas. Many of these routes have been quite beneficial for Off-Highway Vehicle (OHV) riding and other forms of recreation without significant adverse effects thanks to basic trail maintenance efforts, and more could be done. Reopening them would provide an adequate quantity, quality, and variety of routes to improve the manageability of trail systems from Chimney Rock to the San Rafael Desert.
3. Comments of the Sage Riders Motorcycle Club
The Organizations appreciate the Sage Riders Motorcycle Club (SRMC) for decades of stewardship across the planning areas. We agree with the May 20, 2026 comments of SRMC, which we have enclosed and incorporated into these comments to be analyzed by the BLM, not merely as a reference document.
4. Comments of One Voice et al.
The Organizations support the June 7, 2026 comments of One Voice et al., 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.
The One Voice et al. comments also correctly assert that the recent rescission of executive 11644 and 11989 relieve the BLM from outdated "minimization criteria" so that OHV riding can be managed like any other form of outdoor recreation. The organizations incorporate the above listed points into these comments to be analyzed by the BLM.
5. The current TMPs result from inaccurate baselines for analysis.
The current TMPs result from Environmental Assessments (EAs) with no-action alternatives that omitted many routes which had not been properly closed and had been continuously used by the public for decades. Specifically the San Rafael Swell EA's "total evaluated route network" missed many existing routes that warrant analysis through a route report and consideration in draft alternatives. Some of these routes are on motorized route maps produced by Emery County as well as the Emery County Trails Committee. Others are not county roads, but are nevertheless viable worth of due consideration. Here are just a couple examples:
A. Parallel route of UT-72 between SS6193 and SS6184 - This old constructed road, which is just west of Highway 72, is three miles long. It allows OHV riders to connect many routes without going on the highway, which benefits recreation as well as highway users.
B. Old Woman Wash from SS2533 to UT-24 - This major wash connects the Reef road to the San Rafael Desert on the other side of Highway 24. It goes under a highway bridge that's unobstructed, at which point it's less than a quarter-mile from a route designated open in the 2022 San Rafael Desert TMP. This route, Old Woman Wash, is what most OHV riders actually use to cross Highway 24 instead of Temple Wash. Also this route, Old Woman Wash on the west side of the highway, is part of BLM-permitted motorcycle race courses including the 1987 Mail Run.
Further the EAs didn't account for recent loss of access by implementation of the Dingell Act wilderness areas that permanently closed hundreds of miles of existing routes across the planning areas. Consequently the current TMPs closed too many additional routes, complicating implementation of the TMPs and even of the Dingell Act, so this reassessment is urgently needed.
6. The current TMPs result from socioeconomic analyses that failed to recognize major negative impacts of extensive closure.
The current TMPs result from EAs in which most of the action alternatives would greatly harm the livelihoods and lifestyles of surrounding communities. First, the analysis areas should've certainly included Wayne County, as Hanksville and Loa are the closest towns to the southern half of the planning areas. Both towns rely on dispersed recreation opportunities from the San Rafael Desert to Mussentuchit areas.
Second, the San Rafael Swell EA stated "On the basis of the above analysis, BLM believes there would be only minimal impacts to the planning area’s economy under any alternative, and detailed analysis is not required. There are no past, present or reasonably foreseeable actions that would alter this conclusion" (Section A.10 AIB-10 on Page 126). The idea that the action alternatives would have only minimal impacts to the planning area's economy is absurd. Motorized recreationists from all over the world visit this area for the network of trails that are generally uncrowded, extensive for exploration, and reaching remote areas with rugged terrain and exceptional views. All of those qualities would be scarcer in most of the alternatives, greatly reducing the effective carrying capacity of the route network, and greatly reducing its word-class nature.
For example, Temple Mountain provides one of the best motorized singletrack trail systems in Utah, the United States, and even the world. It's limited by route mileage and connectivity, making singletracks like the Pink Trail important to maintain variety and prevent crowding. Gems like the Pink Trail couldn't even be reproduced by constructing new trails, as the high-quality terrain has been designated wilderness or a recreation area that prohibits constructing new motorized routes. Thus blocking off routes like the Pink Trail could easily reduce the number of people who choose to stay in—or establish residency in—nearby towns such as Green River and Hanksville. Suffice it to say that the EAs underestimated the socioeconomic value of many motorized routes so, particularly as rural economies become less certain, reopening those routes would be timely.
7. The current TMPs baselessly promoted wilderness characteristics outside of wilderness areas.
The current TMPs minimized impacts to wilderness characteristics (WC) as much or more than it minimized impacts to other resources, suggesting that the BLM deliberately closed many routes for the purpose of promoting WC outside of the designated wilderness in these planning areas. This promotion is inappropriate for many reasons that go back many years, including the 2008 Price RMP, the 2017 settlement agreement, the 2019 Dingell Act, and recent Supreme Court rulings this section will outline.
A. 2008 Price RMP
The draft TMP in Section 3.3.2.1 "Affected Environment" on Page 34 states "LWC units are not solely managed for the protection of their wilderness character unless a BLM land use planning decision has been made to manage the unit as a BLM natural area." This statement inaccurate in multiple ways. First, NAs are not solely managed for the protection of WC either. The BLM insists that NA designations don't constitute a decision because they can manage for WC among other things at the agency's discretion. If—as the draft TMP assets–NAs are solely managed for the protection of WC, then they don't leave enough discretion to avoid recognizing NA designations as decisions. Second, LWC units are not even partly managed for the protection of WC, as the BLM insists that LWC classification is purely descriptive. Thus the SRS TMP should not prioritize route closures in LWC units because the Price RMP directs the BLM to not manage for WC in those LWC units, yet Alternative B does so expressly and Alternative C does so effectively.
B. 2017 settlement agreement
The draft TMP in Section 3.3.2.1 "Affected Environment" on Page 34 states:
Similarly, the 2017 Settlement Agreement stipulates that “For purposes of minimizing damage to public lands with BLM-inventoried wilderness characteristics, the BLM will consider the potential damage to any constituent element of wilderness characteristics, including naturalness, outstanding opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation, for each alternative route network.”
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 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.
C. 2019 Dingell Act
i. Preserving the Balance Inherent to this Compromise Legislation
The Dingell Act designated roughly half of the San Rafael Swell (and much of the San Rafael Desert) to be wilderness and the other half to be very accessible, which is what the Organizations reminded the Price Field Office of in our January 7, 2022 letter regarding scoping of the Price RMP Amendments. Specifically our letter stated:
Please remember that Emery County agreed to the massive wilderness designation so the remaining areas would continue to be managed more inclusively by the multiple-use form of conservation. Indeed, settling the wilderness debate was the spirit shared by all congressional sponsors of the Emery County bill... the packaged Emery County bill of 2019 proposed to designate over 650,000 acres of wilderness, with those additional acres encompassing 73 miles of Class D roads and at least that many other motorized routes that had not been marked "closed" on the ground, nor had they even been analyzed for closure (through a complete travel-planning process that would start with a complete inventory of existing routes). The point is that designating approximately 660,000 acres of wilderness permanently closed many well-established routes to motorized and mechanized travel.
The Organizations reiterated these points in our March 3, 2021 letter regarding scoping of the San Rafael Swell TMP. Our letter concluded that "Route inventories in all parts of the TMA should include a baseline of all roads and trails, if any, that are or will be proposed to be closed as a result of the Dingell Act wilderness designation."
ii. Accounting for the Permanent Closure of Existing Routes in New Wilderness Areas
Over three years later, the both of the TMP EAs failed to provide a baseline of all roads and trails that are in wilderness designated by the Dingell Act within the given planning areas. Combining both planning areas, the Organizations are aware of over a hundred miles of Class D roads and at least that many miles of other motorized routes that were in continuous use for decades up to 2018 or later. We are also aware that the BLM has an inventory of these routes, yet the TMP EAs didn't show the routes on planning maps, let alone analyze the impact of their permanent closure.
iii. Managing Displacement due to Closures by the Dingell Act and the most recent TMPs
Given that at least a few-hundred miles of route were permanently closed by wilderness designation in planning areas, displacement of that use to other parts of the planning areas is inevitable, yet the TMP EAs yet again denied the existence of such displacement from these routes or the hundreds of miles of route closed by the TMPs. The San Rafael Swell TMP in Section 3.3.4.1 "Affected Environment" on Page 51 states "Based on this prominent concentration of recreational use, even though the alternatives would change the route networks available for motorized recreation opportunities, they would not meaningfully change visitation to these popular areas nor would they result in visitor use being distributed differently across the TMA." In fact, displacement had already begun through blocking off the existing routes permanently closed by wilderness designation, and it would increase greatly by blocking off additional hundreds of miles closed by the current TMPs. This displacement must be scaled back in order to successfully manage recreation and conserve resources.
iv. Honoring the non-wilderness management for areas not designated as wilderness
The September 18th, 2019 Congressional Record from Senator Romney stated "The driving force for this compromise bill was the desire for countywide land use certainty." This certainty applies to non-wilderness areas just as it applies to wilderness areas. He elaborated:
For example, it was important to not close a road, trail, airstrip, or prohibit other existing use in the legislative text or corresponding map with a wilderness designation. Further, to avoid applying more restrictive designations, such as wilderness, to areas it would limit ongoing activity, such as grazing or recreation.
Clearly if Congress had intended other parts of the planning areas to be managed as wilderness, it would've designated them as wilderness. This is yet another reason not to promote WC beyond designated wilderness.
v. Honoring continued access of the routes that comprise wilderness boundaries
The September 18th, 2019 Congressional Record from Senator Romney also stated:
On the topic of roads, stakeholders worked closely with BLM to ensure all roads in the 2008 Resource Management Plan were “cherrystemmed,” meaning they were not included in a wilderness designation. Our intent was to maintain these roads and for those designated as “open” to stay open. These cherry-stems are of various sizes and were intended to ensure an adequate corridor exists to facilitate necessary maintenance.
The current TMPs' closure of route adjacent to wilderness violates the good-faith agreement that was shared among those that negotiated development of the Dingell Act.
D. Recent Supreme Court Rulings
In 2024 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 San Rafael Swell EA in Section 3.3.2.1 "Affected Environment" on Page 34 asserts "Distinct from any planning decisions, under 43 CFR § 8342.1 the BLM has the obligation to minimize impacts to resources, including wilderness character, when designating OHV routes." The BLM should be cognizant of the extent to which such agency guidance 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 that the BLM was merely conducting minimization pursuant to the 2017 Settlement Agreement 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.
For all these reasons, the current TMPs' promotion of WC outside of the many wilderness areas designated by the Dingell Act is legally unfounded, and should be rectified by this reassessment.
8. The current San Rafael Desert TMP baselessly buffered the Green River
While the Dingell Act designated most stretches of the Green River as some type of Wild And Scenic River, it did not make such a designation for the stretch south of Green River City, yet the current TMP disproportionately closed routes near the river. The routes don’t cause considerable adverse impacts upon river use, and they do provide glimpses of the river, so most of them should be reopened.
9. The current TMPs baselessly closed routes for the primary sake of preserving common plants within the routes.
The current TMPs result from EAs claiming that many routes "have fully reclaimed, are not apparent on the ground, or are otherwise inaccessible by routes authorized for public OHV use" and that use of the routes "will cause considerable adverse effects to resources including, but not limited to, soil and vegetation." The existence of vegetation on designated routes is not a sufficient reason to close the routes, nor does it prove that the routes are unused, nor does it prove that the routes are valueless (i.e. lack a purpose or need at present or in future). For example, many segments of routinely graded, Class B roads in the planning areas are currently covered in vegetation, such as SD211 and SD212. The mere existence of common plants on an old bull-dozed road or permitted motorcycle-race course doesn't justify closure. In fact the route may have current or future value as an alternative to a graded road by providing a more primitive experience, some degree of intimacy with the surroundings, and a sense of challenge or flow. A quality OHV ride depends on piecing these primitive routes together without graded roads while including enough points of interest and variety of terrain. It's simply not attainable in many parts of the planning areas, so the reassessment should identify routes needed to make quality loops, some of which are naturally overgrown. Improving the TMPs would increase compliance and decrease travel off the designated routes, thereby conserving vegetation across 99% of the planning areas.
10. The current TMPs incorporated none of the Organizations' route-specific comments.
Between the Organizations' August 25, 2022 letter regarding the San Rafael Desert TMP and the Organizations' July 22, 2024 letters regarding the San Rafael Swell TMP, we commented on over two dozen routes, in most cases providing photos and in all cases providing rationale to leave the route open. The resulting TMPs left none of these routes open, which makes it hard to believe that the BLM seriously considered our comments, so a reassessment is certainly in order.
11. Route-Specific Comments
The Organizations appreciate the BLM's proposal to reopen nearly 250 miles of route, but these are enormous planning areas, and at least twice that many routes warrant reopening. In total there are several-hundreds of miles of route with great recreational value that are quite feasible to manage without considerable adverse effects. Most of them have been continuously used for decades, and should not be blocked off without compelling reasons.
It appears that the scope of this reassessment excludes land recently traded from SITLA to BLM. That's fine so long as the agency plans to designate routes on former SITLA sections in future, and effectively adopts the SITLA policy in the meantime to maintain status quo. An example of a high-value route in a former SITLA section is the primitive road that climbs up to the strip mine on Flat Top.
Given the 30-day comment period, we don't have time to cover the rationale for reopening each BLM route, so we'll simply list several routes that each exemplify a characteristic of value, then we'll highlight valuable routes in a couple of focus areas (Temple Mountain and southeastern San Rafael Desert). These highlights are based on our decades of experience in all kinds of OHV riding and assisting the BLM's management. The organizations have photos of nearly all these routes we would be happy to provide it upon request.
A. Examples of Route Qualities
Bull Bottom aka Itchy and Scratchy Trail (SD1348A): Although it mostly traverses slickrock, this route is a singletrack exemplifying trail qualities like a sense of flow, some challenging obstacles, and greater connection to the natural surroundings than what a more developed route would provide. It has been enjoyed by motorcyclists and bicyclists for many years including permitted events. With a roughly 500' buffer, it forms the boundary of Labyrinth Canyon Wilderness, suggesting that Congress deliberately avoided the route when designating the wilderness area. The cliff of Three Canyon physically prevents mechanizes uses from entering the wilderness. In short, it's a high-value trail that's relatively easy to manage.
Primitive Roads below The Reef (SS2491 and SS2497-SS2498-SS2496): These routes exemplify connectivity, as they're critical to parallel The Reef while staying off of UT-24. While motorcyclists and other mechanized users can no longer go up into The Reef, they can still enjoy viewing the length of it from the desert below, but only if these links are reopened.
Farnswoth Tanks Loop (SS2540): This old bladed road exemplifies the importance of short loop options for campers, in this case campers of Temple Mountain and Goblin Valley State Park. The road has a sinuous alignment and modest grades for rider flow and route sustainability.
Road Draw (SS3071): This drainage exemplifies an alternative to graded roads, in this case the Buckskin Draw Road. The drainage is a non-riparian, wide wash that accommodates full-size vehicles. It provides a bit of adventure for OHV riders instead of going fast on the graded road. Reopening it is a relatively easy way to enhance motorized trail opportunities within the Swell Recreation Area.
Overlook of Blue Trail Canyon (SS66096): This old bladed road exemplifies the value of a spur to reach its point of interest, in this case a great view of Blue Trail Canyon. It has a flowing alignment through gentle hills of pinion and juniper that naturally encourage OHV riders to stay on the route. The view is just a half-mile from Interstate 70, thus the setting is already quite motorized.
B. Temple Mountain
The Temple Mountain area is surrounded by wilderness designations with the exception of northwest, where the McKay Flat Road crosses relatively featureless terrain. Thus Temple Mountain must accommodate many campers and trail users, which calls for a much higher density of routes, thus we appreciate the BLM proposal to reopen SS4272 that's surrounded by so many primitive campsites. To live up to the name "Recreation Area," the renowned Temple Mountain trail system should be improved. Given the restriction against route construction, reopening existing routes becomes the primary means of providing many recreational opportunities in a relatively small area.
Spur North of Ernie Canyon (SS2767): This short spur climbs to the base of a couple buttes for great views of the San Rafael Reef Wilderness.
Purple Trail (SS2745-SS2746): Although this motorized singletrack used to go down Iron Wash through The Reef, it would still be quite valuable as a spur to the new wilderness boundary. The singletrack trail system is small for modern motorcycle trail riders, so reopening the first three miles of Purple Trail would greatly help those seeking quantity. For those seeking quality, the spur does reach closer views of Iron Wash through The Reef. Motorcycling volunteers and state grant funds would certainly support the BLM to ensure that riders turn around before the wilderness boundary. At the beginning of the spur, a "dead end" sign would establish proper expectations and keep use levels relatively low.
Flanks of Temple Mountain (SS2595, SS2683, and SS2605): Scaling even halfway up each side of Temple Mountain by utilizing a few of the many old roads would provide lasting impressions of the natural and human history for all kinds of OHV riders. Being so close to Goblin Valley Road, it'd be quite feasible for heavy equipment to make any needed improvements to drainage.
Primitive Road southeast of Temple Mountain (SS2671): This old bladed road follows the contour of a hillside to naturally provide drainage and a sense of flow. It combines with S2666 to make a short but valuable loop.
Pink Trail (SS2641A): This route connects Waterfall Trail to the rest of the motorized singletracks so that motorcyclists don't have to ride the graded road. It makes management quite feasible by following the contour of a ridge at the top and following a drainage at the bottom. In the middle is a steep downhill that could erode with increased use, but the terrain is quite suitable for a reroute that would reduce the grade, and riders would stay on the designated route since the surrounding ground is so rugged. The route is particularly valuable for electric motorcycles and bicycles with limited range because it creates a more continuous trail experience.
C. Southeast San Rafael Desert
This part of the Price Field Office is sometimes overlooked because it's so far from Price and so flat compared to many other parts of the field office. However as those parts have become more restricted and crowded, the San Rafael Desert becomes more important for recreation, particularly more remote and long-distance pursuits such as overlanding and dualsport motorcycling. Plus, even outside of the Labyrinth Canyon Wilderness, there are points of interest and appealing qualities of the vast desert. It depends upon the TMP to provide loops that combine these points while avoiding graded roads.
SD051 and SD052: These routes provide a more primitive alternative to Hans Flat Road.
SD078: This route provides convenient access to Temple Wash. As with many areas adjacent to a highway corridor, it is denuded, although a singletrack is surrounded by some degree of vegetation. At its north end, the downed fence has a gate indicating where the route went through the gate. Recent scouring of Temple Wash below the highway bridge may impede larger vehicles, but smaller vehicles can already get through all of SD078, and larger vehicles could do so after basic tread work with support of local OHV clubs or the state's OHV program.
SD079: Temple Wash has been permitted by the BLM for motorcycle races, and provides a dynamic challenge and flow that has become scarce as most other washes have been closed. This stretch of wash generally lacks riparian resources that may otherwise cause concern. Recent scouring of Temple Wash below the highway bridge may impede larger vehicles, but smaller vehicles can already get through all of SD079, and larger vehicles could do so after basic tread work with support of local OHV clubs or the state's OHV program.
SD128 and SD319: Bypassing the highly-developed Hans Flat Road, these routes connect two highlights of the San Rafael Desert (at least of the part that hasn’t been permanently closed by wilderness designation), specifically Sweetwater Reef overlook and Jack's Knob. Most of the route is on SITLA property, which has no other motorized access under the BLM's preliminary proposal.
SD217: This route may seem redundant with SD309, but if you’re coming from SD326 (from Wayne County / Richfield FO) and you want to head north (to Moonshine Well), reaching SD309 via SD312 would seem circuitous to any group that’s hurrying for whatever reason.
SD218 to SD372: This pair of routes primarily consists of a single, straight seismic line that provides the only east-west travel across a north-south expanse of over ten miles (from SD543 into Wayne County / Richfield FO) covering most of Antelope Valley. Although parts of the route are much less apparent, route markers could be placed at regular intervals to organize travel. It accesses the corner of a SITLA section.
SD236: This route is an alternative to the graded road, going across the shallow-yet-interesting canyon of Dugout Wash as well as a slickrock expanse, both of which nicely contrast the predominantly flat and sandy planning area.
SD240: This route is an alternative to the graded road, providing over two miles of primitive road.
SD250: This route accesses SITLA property and the small-but-scenic Red Reef, which also makes the route itself more rolling and interesting.
SD715 and SD720: This route traverses the southeast rim of Gruvers Mesa, providing views that are different from the route on the northwest rim. The end the road, which accesses SITLA property, is particularly scenic.
SD740_S2: This route is part of a short-but-great loop partly due to the rolling terrain. Its southeast end offers views up to The Cone, while the northwest end offers views down to the San Rafael River (while generally staying back off of its rim). The route is entirely passable by motorcycle, and could be made more accessible to larger vehicles by doing basic tread work with support of local OHV clubs or the state's OHV program. The middle part could easily be realigned to reduce the grade for sustainability, but this shouldn’t be an immediate concern due to the low use levels associated with such a remote location. Note that SD741 is also a high-quality route but, given the SD740 already provides views of the San Rafael River in a loop, the SD741 spur is not as important.
SD762: This route creates a loop with SD210, which is a five-mile route that would otherwise be one-way. This loop is a more interesting way to reach the San Rafael River overlook of SD763. Although parts of the route are much less apparent, route markers could be placed at regular intervals to organize travel.
SD781: This route creates a loop to a view of the San Rafael River from the river's north side. It traverses rolling red-rock terrain off the flank of Horse Bench that makes for a high-quality route.
SD857 and SD858: This pair of routes makes a larger loop out of the same one as SD781 that reaches a view of the San Rafael River from the river's north side. It also reaches the corner of a SITLA section.
SD869 and SD870: This pair of routes reaches SITLA property and a point overlooking the San Rafael Valley as well as the geologic transitions from the sandstone formations southward and the shale formations northward.
SD1029: This route meanders through badlands of the Morrison Formation to reach SITLA property and a panoramic view of Dry Lake Wash and beyond. Since this area is nearly void of vegetation, the Organizations are wondering why the BLM would preliminarily propose to close it (even more than we're wondering why all the other closures are proposed). Perhaps it’s because the wash where the route begins is so broad that the route is less distinct. This shouldn’t be an immediate concern given that the area is naturally barren, but eventually you could reroute it to the existing primitive road that lies a quarter-mile northward. It's a more distinct route that stays even further away from Horse Bench Reservoir.
SD1303_S3: This route gradually winds up a hill and then down the other side to the Green River. If there are noise concerns along the river (despite that the river will continue to be used by motorboats), note that vehicle sounds from SD1303_3 are drowned out by the loud diesel of major irrigation-water pumps a couple-hundred yards upstream. If there are concerns about the route dropping down to river-bank level, the BLM could close the last hundred yards of the route so that OHV riders could still view the river from atop the small rim.
The above list is not comprehensive. For example, SD940 was permitted by the BLM for motorcycle races and provides singletrack character. For a primitive alternative to graded roads, there's SD221 to SD335 as well as SD345 to SD346.
12. Conclusion
Particularly given the Dingell Act's wilderness designations of 660,000 acres surrounding the planning area, the Organizations commend the BLM for accommodating non-wilderness uses on the remaining acres by further investigating the inventoried routes and input of recreationists who have enjoyed them for generations. On all sides of the Swell, the sustainable solution for most of these routes is to restore access, fostering stewardship of the routes and the landscape alike.
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:
Sage Riders Motorcycle Club Comments
One Voice et al Comments