TPA Rio Grand Over Snow Travel Management Plan Comments

August 8, 2026

Re: Draft Environmental Impact Statement - Rio Grande National Forest Over-Snow Travel Management Project

Dear Forest Supervisor and Planning Team:

The Trails Preservation Alliance (TPA) appreciates the opportunity to provide comments regarding the Rio Grande National Forest (RGNF) Over-Snow Travel Management Project and associated Draft Environmental Impact Statement (DEIS).

TPA is a Colorado-based nonprofit organization dedicated to preserving and expanding responsible motorized recreational opportunities on public lands while promoting sustainable management, stewardship, and cooperation among recreational users and land managers. TPA and our partners have extensive experience with motorized recreation, travel management planning, trail stewardship, and the practical implementation of Forest Service travel management decisions throughout Colorado.

After reviewing the alternatives presented in the DEIS, TPA supports Alternative 3 as the appropriate foundation for the final decision, with specific modifications discussed below. Alternative 3 provides the most reasonable balance between maintaining meaningful over-snow vehicle (OSV) recreation opportunities and addressing legitimate resource concerns. TPA also requests that the Forest incorporate appropriate route designations identified under Alternative 4 where those routes improve connectivity and recreational access without creating demonstrable resource impacts.

1. Alternative 3 Provides the Best Foundation for the Final Decision

TPA supports Alternative 3 because it retains a meaningful system of both designated routes and areas available for OSV recreation while providing specific management measures for identified resource concerns.

Alternative 3 would designate approximately 738 miles of routes and more than 1.2 million acres for cross-country OSV use. It also addresses mapped big-game winter range by directing OSV travel onto designated routes in affected areas rather than relying on unnecessarily broad prohibitions on motorized winter access.

This approach is preferable to alternatives that substantially reduce cross-country opportunities or create large nonmotorized areas without sufficiently demonstrating that those restrictions are necessary under applicable law, the regulations currently in effect, and the site-specific administrative record.

The final decision should therefore adopt Alternative 3 as its starting point and make additional adjustments only where supported by site-specific analysis and the administrative record.

2. Incorporate Beneficial Route Designations From Alternative 4

While TPA supports Alternative 3 overall, the Forest should not treat the alternatives as all-or-nothing packages. Certain routes identified under Alternative 4 appear capable of improving the Alternative 3 transportation system.

Alternative 4 contains approximately 1,169 miles of designated roads and trails, compared with approximately 738 miles under Alternative 3. Where Alternative 4 routes provide meaningful connectivity between existing riding areas, communities, trailheads, groomed systems, or other established recreational destinations, those routes should be incorporated into the final Alternative 3 network.

Connectivity is an essential component of a functional travel system. Simply measuring the total mileage or acreage available for OSV recreation does not adequately evaluate the quality of the recreational opportunity. A fragmented network can contain significant mileage while failing to provide practical access or meaningful recreational experiences.

TPA therefore requests that the Forest conduct a route-by-route comparison of Alternatives 3 and 4 and incorporate Alternative 4 routes into the final decision wherever those routes:

Where an Alternative 4 route is excluded from the final decision, the Forest should clearly identify the route and explain the site-specific resource concern supporting that exclusion.

• provide connections between otherwise isolated riding areas;
• maintain historically established access;
• provide loop opportunities;
• connect communities, parking areas, trailheads, or groomed systems;
• provide access around terrain or seasonal resource constraints; or
• otherwise improve the functionality of the designated OSV network without creating a demonstrated and site-specific unacceptable resource impact.

3. Snow-Depth Restrictions Must Be Supported by Site-Specific Evidence

TPA has significant concerns regarding rigid minimum snow-depth requirements, including the proposed 12-inch unpacked minimum snow depth for general OSV use and the 18-inch threshold associated with grooming.

The Forest Service's original proposed action described these thresholds as measures intended to reduce potential resource damage. However, a Forest-wide numerical threshold is not automatically necessary to provide sufficient protection, nor is it necessarily the most effective mechanism for accomplishing that objective.

Snow conditions vary tremendously across the Rio Grande National Forest based on elevation, aspect, vegetation, wind loading, substrate, existing road surfaces, and individual storm events. Twelve inches of unconsolidated snow over a paved or aggregate road presents an entirely different resource condition than the same depth over sensitive alpine vegetation.

Similarly, wind redistribution can make a single numerical measurement an unreliable indicator of whether OSV use would result in resource damage.

The purpose of a management restriction should be to provide sufficient protection against actual or reasonably foreseeable resource impacts - not merely to satisfy an arbitrary numerical threshold.

TPA therefore requests that the Forest replace rigid Forest-wide snow-depth requirements with a conditions-based management standard wherever practicable.

Such an approach could authorize OSV travel when sufficient snow is present to prevent contact with and damage to underlying soil and vegetation, with managers retaining authority to impose temporary restrictions when conditions warrant.

At minimum, designated roads and other hardened surfaces should be evaluated separately from cross-country travel areas. Applying identical snow-depth requirements to fundamentally different surfaces lacks a logical resource-management basis unless the Forest provides evidence demonstrating otherwise.

The Forest should identify the scientific or monitoring information supporting the selected numerical thresholds and explain why a more flexible, conditions-based standard would not provide sufficient protection for the resources at issue.

4. Wilderness Boundaries Should Not Become De Facto Wilderness Expansion Areas

TPA opposes unnecessary motorized closure buffers adjacent to designated Wilderness.

Congress establishes Wilderness boundaries. Those boundaries should not be administratively expanded through travel management unless the Forest identifies a specific resource or management problem requiring additional restrictions outside the congressionally designated boundary.

The mere proximity of lawful motorized recreation to Wilderness is not, standing alone, sufficient justification for prohibiting that recreation.

The Forest Service retains ample authority to address actual incursions into Wilderness through mapping, signing, education, enforcement, and appropriately designed travel routes.

Where the DEIS proposes nonmotorized buffers or closures adjacent to Wilderness, the final EIS should identify:

1. the specific management problem being addressed;
2. evidence demonstrating that the problem currently exists or is reasonably foreseeable;
3. the geographic extent necessary to address that problem;
4. why existing enforcement, education, signage, or boundary marking would be insufficient; and
5. why the selected closure is proportionate to the documented problem and necessary to provide sufficient protection.

Without such analysis, generalized buffers risk functioning as administrative expansions of Wilderness management beyond the boundaries established by Congress.

TPA requests removal of any Wilderness-adjacent OSV closure for which the Forest cannot demonstrate a site-specific management need.

5. Management Measures Should Be Sufficient, Evidence-Based, and Consistent With Current Law

On May 29, 2026, Executive Order 14408, Removing Unnecessary and Counterproductive Restrictions on Access to Federal Lands, rescinded Executive Orders 11644 and 11989 and directed relevant agencies, including the Department of Agriculture, to initiate rulemakings to rescind or revise regulations previously adopted to implement those Orders. Executive Order 14408 expressly identifies applicable statutory authorities and agency-specific land-management authorities as the appropriate framework for managing off-road vehicle use and emphasizes maintaining sufficient environmental protections while removing unnecessary restrictions.

See Exec. Order No. 14408, 91 Fed. Reg. 33577 (June 3, 2026).

TPA recognizes that the Travel Management Rule, including 36 C.F.R. Part 212, remains in effect unless and until it is amended through the required rulemaking process. The Rio Grande National Forest must therefore comply with the regulations currently in force when issuing its final decision. At the same time, the rescission of Executive Orders 11644 and 11989 is directly relevant policy context: the Forest should not treat the former Executive Order minimization framework as an independent policy objective or use it to justify restrictions beyond what the current regulations and underlying statutory authorities require.

For this decision, the better management question is whether a proposed measure is sufficient to protect an identified resource or address a documented conflict, based on site-specific evidence and the authorities that actually apply. Sufficiency does not mean the elimination of every conceivable impact. It means adopting measures reasonably related to the magnitude, location, and likelihood of the identified concern.

Motorized recreation is a legitimate and long-established use of National Forest System lands. Management decisions should therefore evaluate actual site conditions, resource concerns, existing uses, and the range of available tools. Restrictions should be proportionate to documented risks and should not exceed what is needed to provide sufficient resource protection.

Closures should not become the default management response when route designation, seasonal management, education, signage, enforcement, trail design, temporary restrictions, or other targeted measures would sufficiently address the identified concern while retaining public access.

TPA requests that the Final EIS clearly identify the statutory and regulatory basis for each significant restriction, the evidence supporting the need for that restriction, and why the selected management measure is necessary and sufficient for the particular resource or conflict at issue.

6. Historic OSV Access Should Receive Meaningful Consideration

Alternative 3 appropriately recognizes continued OSV access in certain Special Interest Areas and Research Natural Areas where such use has historically occurred.

TPA supports this approach.

A special management designation does not automatically establish that all motorized winter recreation is incompatible with the purposes of that designation. Compatibility should be determined based upon the specific values for which the area was designated and the actual effects of the recreational use.

The final decision should retain historic OSV opportunities in these areas unless the Forest demonstrates through site-specific analysis that continued use would materially impair the particular resource or value the designation is intended to protect.

7. User Conflict Must Be Evaluated Objectively

TPA recognizes that motorized and nonmotorized winter recreation sometimes occur in the same general landscapes. The existence of multiple recreational uses, however, does not itself establish an unacceptable conflict.

National Forest System lands are multiple-use public lands. Users should expect to encounter other lawful recreational activities.

Where user conflict is identified as a justification for restricting OSV access, the Forest should distinguish between documented physical or safety conflicts and individual preferences not to see or hear another lawful user group.

The Forest should also evaluate whether targeted measures are sufficient to address documented conflicts before resorting to large-scale closures. Strategic route placement, trailhead management, signing, education, and carefully defined nonmotorized zones can frequently provide sufficient management without unnecessarily eliminating established OSV opportunities.

8. The Final Decision Must Produce a Practical and Understandable OSV System

Regardless of the alternative ultimately selected, implementation must result in a system that users can reasonably understand and follow in the field.

The final OSV use map should clearly distinguish:

The Forest should also provide digital GIS data compatible with commonly used recreation mapping platforms.

Clear mapping and signing are particularly important where designated routes pass through areas otherwise closed to cross-country travel. Ambiguous boundaries increase the likelihood of accidental violations and unnecessarily complicate enforcement.

• designated OSV routes;
• areas open to cross-country OSV use;
• seasonal restrictions;
• nonmotorized areas;
• Wilderness boundaries;
• snow-depth or conditions-based restrictions; and
• connections between major riding areas.

9. TPA's Requested Decision

TPA requests that the Rio Grande National Forest:

Adopt Alternative 3 as the foundation for the Final EIS and Record of Decision.

TPA further requests that the Forest:

1. incorporate appropriate routes identified in Alternative 4 where they improve connectivity, loops, historical access, community access, or the overall functionality of the OSV system;
2. retain the broad cross-country riding opportunities provided by Alternative 3;
3. replace rigid Forest-wide snow-depth thresholds with conditions-based management standards where practicable and, at minimum, separately evaluate hardened routes from cross-country terrain;
4. remove unnecessary closure buffers surrounding Wilderness and other specially designated areas unless supported by documented, site-specific management needs;
5. retain historic OSV access within Special Interest Areas and Research Natural Areas where continued use is compatible with the specific values being protected;
6. apply the Travel Management Rule currently in effect while recognizing Executive Order 14408 and its direction to revise the regulatory framework, and evaluate proposed restrictions based on whether they are evidence-based, proportionate, and sufficient to protect the identified resource;
7. use targeted management measures when they provide sufficient protection without eliminating established recreational opportunities; and
8. provide clear maps, GIS information, signing, and implementation guidance so the resulting OSV system is understandable and enforceable.

Conclusion

The Rio Grande National Forest contains some of Colorado's most significant winter motorized recreation opportunities. The decisions resulting from this planning process will shape public access and winter recreation for many years.

TPA believes Alternative 3 provides the strongest foundation among the alternatives analyzed because it preserves a meaningful amount of both designated-route and cross-country OSV recreation while providing mechanisms to address legitimate wildlife and resource concerns.

The final decision can be improved further by incorporating beneficial route designations from Alternative 4, eliminating unsupported closure buffers, and replacing inflexible snow-depth requirements with management standards tied more directly to actual resource conditions.

Responsible motorized recreation and sufficient resource protection are not mutually exclusive objectives. A well-designed travel system can accomplish both.

TPA appreciates the Forest Service's consideration of these comments and the substantial effort involved in developing the Rio Grande National Forest Over-Snow Travel Management Plan.

Sincerely,

Trails Preservation Alliance