The Bureau of Land Managements (BLM’s) Kremmling Field Office’s (KFO’s) proposed Resource Management Plan (RMP) needs your comments. The current proposed RMP calls for a significant decrease in the number of miles for off-highway vehicle use. The KFO, located in Kremmling, CO., has released its proposed RMP and is requesting public comment.
The KFO field office manages BLM lands located north of I-70 between the eastern boundaries of the Medicine Bow/Rout National Forest and western boundaries of the Arapahoe Roosevelt National Forest. The office has extended the comment deadline until January 17, 2012 and the American Motorcyclists Association (AMA) urges you to use the talking points provided below to send a letter to the KFO.
Comments should be addressed and mailed to:
Kremmling Field Office
Attn: Dennis Gale, RMP Project Manager
PO Box 68
Kremmling, CO 80459
The RMP, as proposed, would have the following effects:
- Decrease cross-country travel currently allowed on 307,300 acres to 200 acres
- Decrease designated route mileage for full-size vehicles from 1,739 miles to 872 miles
- Decrease designated route mileage for ATVs from 73 miles to 14 miles
- Decrease designated single-track route mileage for motorcycles from 53 miles to 21 miles
- Decrease mileage for mechanized/ non-motorized from 99 miles to 72 miles
- Decrease mileage for foot/horse traffic from 33 to 6 miles.
Alternative D has been identified as the best alternative for off-highway vehicle (OHV) recreation, but even this Alternative fails to address current usage trends and provide a viable plan for realistic management of the lands over the expected life of the RMP. In fact the RMP could be outdated by the time the final decision document is released.
Both the Colorado Off Highway Vehicle Coalition (COHVCO) and the Trails Preservation Alliance (TPA) are opposed to Alternative C as this option lacks a solid scientific basis and violates both state and federal planning guidelines.
Other talking points provided by the AMA, COHVCO and TPA to include in your letter are:
- The RMP provides a large amount of information regarding uses but is very disorganized and hard to review. This lack of basic organization limits the opportunity for the public to comment effectively.
- Combining travel management and resource management plans is simply not a viable planning process, and these issues should be addressed separately. There is simply too much information to be analyzed under a combined plan.
- There is no meaningful analysis of travel management issues in the RMP. The travel management portion of the RMP is covered in 51 pages addressing four alternatives for 378,884 acres.
- The economic impact of the proposed travel management closures in the RMP has been incorrectly calculated. The RMP asserts that closure of 50% of the motorized routes will have no negative economic impacts. This calculation is simply incorrect, as every mile of trail has value as a recreational resource.
- A lack of access has already been identified as a hunting management issue on the KFO, and closing 50% of routes will clearly impact many uses outside motorized recreation.
- The RMP proposed simply does not reflect current usage levels not accurately address future usage projections. The projections were developed in numerous state planning documents and must be reviewed and incorporated into federal public lands management plans. This failure to accurately address demands on the KFO going forward will result in a plan that rapidly loses value for on the ground management decisions.
- The RMP moves to a fully designated trail system for all users but any expected benefits of the change to a designated trail system are not addressed. The RMP does not analyze why the habitat protection of a designated trail system is not sufficient to achieve RMP objectives and why the RMP finds further closures are necessary. This despite that the fact that many habitat management plans identify designated OHV trail systems as the single factor in protecting habitat.
- While the initial closures proposed in the RMP are painful for the OHV community, many of the standards and guidelines proposed lay the groundwork for significantly more closures in the future, if area specific travel management plans are developed to address site specific issues.
- The issue specific travel management standards (e.g., big game habitat, lynx and sage grouse habitat) are often not supported by scientific research and often directly conflict with regional management guidelines for the species. The RMP standards almost always seek to exclude motorized access first, even if it is not identified as a concern in regional planning documents.
- The RMP proposes “optimize big game habitat”. This standard is of significant concern as most of the planning office is mule deer habitat and optimizing this habitat would require removal of any use that could impact the mule deer.
- This lack of analysis for travel management related issues is a violation of NEPA’s requirements for a detailed statement of high quality information of why decisions in the Plan have been made.
- The RMP proposes closure of all roads and trails on landlocked parcels to all motorized travel. No management issue is identified as the basis for this closure and this will only further restricted ability of users to enjoy the trails by creating dead ends and fragments throughout the system.
Since the comment period ends soon, time is of the essence. The AMA, COHVCO and TPA need your help. Riders, their friend and family are encouraged to submit comments before January 17. Please cut and paste the aforementioned talking points addressed to KFO. Do not forget to sign and date your letter before mailing it.
To be most influential, and to make sure everyone’s voice is heard, please take the time to personalize your letter. Any additional information you can provide regarding specific trails, recreational experiences, camping and other uses of this area you and your family enjoy will only strengthen the effectiveness of your letter.