July 22, 2026
Bureau of Land Management
Kanab Field Office
669 S. Hwy 89A
Kanab, UT 84741
Re: Trail Canyon Travel Management Plan
DOI-BLM-UT-P020-2026-0003-EA
Dear BLM Planning Team:
Please accept this correspondence from the above organizations as our official comments regarding the BLM’s Travel Management Plan (TMP) in the Trail Canyon 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 Paunsaugunt area that includes Hog Canyon, the Trail Canyon planning area provides the primary OHV riding opportunities for Kanab by spanning Moquith Mountain, Elephant Cove, and Orderville Gulch. The emerging recreation economy and lifestyles of this town include non-motorized recreation, which can utilize places like the adjacent Canaan Mountain Wilderness and Zion National Park, while motorized trail riding depends on less restricted public lands that still have compelling terrain. Surrounding Kanab, these criteria are primarily met in the Paunsaugunt and Trail Canyon planning areas.
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 "B.9 AIB-9: Natural Soundscapes" on Page 95 claims that "OHVs generate 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. Alternatives
The 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 diligent planning of Kane County and input from locals like the UT/AZ ATV Club.
Alternative D is the only one that incorporates county planning and all the high-value routes, although some isolated elements of Alternative A are acceptable, which could be combined with the rest of Alternative D.
7. Specific routes
Given time constraints, the Organizations will just provide a couple examples of routes that have great recreational value.
The primitive road that traverses between Orderville Gulch and Walker Gulch (92X and 92XWSA) is shown on old USGS maps as a 4WD trail, and it continues to provide great views above and below the natural bench that it follows. It's a key part of a larger loop on BLM land and some private property via public roads. The WSA boundary that jaunts over this road is clearly a mapping error that could be addressed by amending the RMP if needed to accommodate continued enjoyment of the loop.
The Barracks Trail (20WSA) provides a unique opportunity to follow a primitive 4WD route along a beautiful river. If more education or trail work is needed, federal and state OHV grants are available. Even in this dynamic setting, the route can typically be confined to a couple braids that would work in different ground conditions. The Barracks Trail may require more work than most routes, but it offers an opportunity to educate visitors about riparian resources in addition to the thrill of a rugged route.
8. 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.
Authorized Representative
Colorado Off-Highway Vehicle Coalition
Marcus Trusty
President/Founder
Colorado Off Road Enterprise
Supporting Documents:
AMA comments trail canyon