Colorado BLM
Summary of Public Comment to the
Recommended Recreation Guideline

December 11,  2000

From August 8 to September 22, 2000, the Colorado Bureau of Land Management office accepted public comment (via phone, fax, e-mail, and letter) on it's Recommended Recreation Guidelines. Each comment that was received within the specified time frame, has been read and considered. Below are responses to comments that were specific to the guidelines, or were made by multiple respondents. Numerous comments were received that were personal viewpoints or opinions, which were also read and considered. Colorado BLM thanks each respondent for taking the time to help with this process.

  • Comment: BLM needs to complete an inventory of current roads and trails.

BLM Response: This concept is supported in G.1. of the Recreation Guidelines.



  • Comment: OHV activity has minimal impacts on wildlife.

BLM Response: OHV activity can have a negative impact on wildlife. One example is the effect OHVs have on the connectivity of wildlife habitat and corridors. Section B of the Recreation Guidelines provides guidance to help mitigate these situations.

 

  • Comment: Use science in decision making.

BLM Response: BLM relies heavily on the input of biologists, geologists, hydrologists, and other experts that provide scientific facts to aid BLM managers in making sound land management decisions. In addition, F.2. of the Recreation Guidelines incorporates the use of recreation science in decision making.


  • Comment: Shared use on trails will not always work because of differences in desired experiences and for safety reasons.

BLM Response: Guidance on how to deal with this issue is adequately captured in G.4.c. of the Recreation Guidelines. Furthermore, collaborative transportation planning will address use of roads and trails (see guideline G.2.).

 

  • Comment: Adopt a "closed unless posted open" policy.

BLM Response: This comment is beyond the scope of these guidelines; a policy of this scope would need to come from the BLM Director.


  • Comment: Opposes "closed unless posted open" policy.

BLM Response: This comment is beyond the scope of these guidelines; a policy of this scope would need to come from the BLM Director.



  • Comment: Gathering public input is fine, but to forego decision making authority is not acceptable; BLM should not be engaging in "partnerships".

 

BLM Response: BLM has found that using collaborative processes and partnerships (see guideline E.4.) produces better decisions. BLM is ultimately responsible for land management decisions for land it administers.

  • Comment: BLM needs additional enforcement and on the ground presence.

BLM Response: This concept is captured in the Recreation Guidelines, under #3 in the Implementation Issues.



  • Comment: Assess and monitor social and economic impacts from closing trails.

BLM Response: Economic and social impacts are analyzed through the National Environmental Policy Act (NEPA) process when preparing transportation plans.



  • Comment: Having all of the OHV use concentrated in one area is worse than dispersed use.

 

BLM Response: The concept of concentrated use may have merit when considering the overall health of a larger landscape area, and may be considered during the development of RMPs, Activity Plans, and Transportation plans. More information on this can be found in the Recreation Guidelines under #8 in the Implementation Issues section.



  • Comment: BLM should increase user fees and keep the money on site for maintenance.

 

BLM Response: At this time, most fees collected at BLM recreation sites in a given year go into the general fund. During the next fiscal year at least 85% of the monies collected at a specific site are redistributed to that site for maintenance, upkeep, improvements, etc. BLM is exploring ways to retain 100% of fees collected at from a specific site to remain there. Currently, there are 3 pilot studies underway in Colorado in which fees collected at a site, remain at that site.



  • Comment: Trails that have already been established, should be kept open.

 

BLM Response: Travel management planning will help determine the overall road system for an area, including roads that should be kept open and roads that should be closed and rehabilitated.



  • Comment: Require new engine design on OHVs for noise mitigation.

BLM Response: This recommendation is beyond the scope of these Recreation Guidelines. This recommendation would require a change in federal and/or state regulations.

  • Comment: Sustainable access is needed.

 

BLM Response: The majority of BLM land in Colorado will remain accessible to vehicles. The guidelines will help BLM meet the challenge of providing sustainable access while maintaining the health of the land.

 

  • Comment: Marketing should not be happening; this will only encourage more use and damage (see E.6).

 

BLM Response: The intent of E.6. in the Recreation Guidelines was not adequately conveyed with the term "marketing". Guideline E.6. will be modified to read:

In order to mitigate adverse impacts to the public lands, work with the private sector to integrate a responsible recreational use message with the goods or services they provide.

 

  • Comment: Include the public in the process.

BLM Response: Several of the Recreation Guidelines encourage public participation in managing recreation (see E.3., E.4., G.2., G.4.d., Implementation Issue #5)

 

  • Comment: BLM should not use categorical exclusions when authorizing OHV routes and/or recreation facilities.

 

BLM Response: In the vast majority of cases, proposed recreation developments, facilities, or plans will require NEPA documentation with public involvement/ notification. Any use of categorical exclusions will be guided by regulations and BLM Department Manual 516.



  • Comment: Increasing participants and decreasing areas may lead to more illegal damage.

 

BLM Response: Increasing populations in the West have increased demand on BLM land for all types of recreation opportunities. It is not the intent of the Recreation Guidelines to close large tracts of BLM land. Rather, the Recreation Guidelines provide tools to managers to meet planning challenges during this time of growth and change.



  • Comment: OHV users are singled out in the guidelines.

 

BLM Response: The Recreation Guidelines take into consideration and provide guidance for all activities that take place on BLM administered lands.



  • Comment: Consider growth in OHV use when planning.

BLM Response: Use of OHVs on public lands is a valid when done responsibly and in compliance with the Standards for Public Land Health. BLM realizes the popularity of OHVs will continue to increase and will consider this in long-term recreation planning.



  • Comment: Include OHV travel in dry washes in the plan.

 

BLM Response: OHV travel in dry washes will be considered in the travel management plans. Each area will be assessed on a case-by-case basis and input from scientific experts will be utilized in making decisions on use of the area.



  • Comment: Work with other agencies; implement similar policy to the U.S. Forest Service (USFS).

 

BLM Response: In a ongoing effort toward more consistent and seamless land management, the BLM continues to work with the USFS, as well as other federal and state agencies. Where policies or regulations differ, they will be identified as constraints in collaborative management efforts. This concept is discussed in E.4. of the Recreation Guidelines.

 

  • Comment: Do not allow cross-country travel.

BLM Response: Except in some specified areas, cross-country vehicle travel on BLM land is not appropriate for it leads to the proliferation of roads and trails. The guidelines provide a variety of tools for managers to address this problem.



  • Comment: Set aside non-motorized areas to provide natural soundscapes.

BLM Response: Setting aside non-motorized areas are allocative decisions that must be addressed through the land use planning process. BLM currently has ongoing efforts to look at setting aside lands for non-motorized use (i.e., wilderness inventory).



  • Comment: Educate the public; how does BLM plan to educate on the guidelines, rules, fines, etc.?

 

BLM Response: This comment is addressed in E.2. and E.3. in the Recreation Guidelines.



  • Comment: "G.4.b. makes no sense"; interpreted to mean that motorized use can only occur in areas in which no restrictions are necessary.

 

BLM Response: This guideline is confusing. Guideline G.4.b., will be modified to read: Cross-country travel (i.e., off of roads and trails) should only be permitted in areas that meet the designation criteria for open areas, and the Standards for Public Land Health.



  • Comment: Provide clear rules and fines.

BLM Response: BLM proposes no change in rules (i.e., regulations) at this time. E.2. and G.6. in the Recreation Guidelines provide guidance to improve information and education efforts.



  • Comment: Public lands should not be sold to the "highest bidder".

BLM Response: In some instances it is necessary for the agency to pursue outside funding sources (grants, partners, etc.) to accomplish on-the-ground projects to the quality and standard that the public expects. BLM is ultimately responsible for land management decisions for land it administers.



  • Comment: Designate roads, routes, and trails.

 

BLM Response: To address issues with increasing OHV use, the development of a designated roads and trails system will be seriously considered in transportation planning (see Guideline G.2.).



  • Comment: Redefine types of OHV; different OHVs have different impacts on the environment (e.g. motorcycles, ATVs, 4 wheel drives).

 

BLM Response: This suggestion is beyond the scope of these guidelines.



  • Comment: All uses (not just motorized use) must be included when addressing resource concerns.

BLM Response: Section G of the Recreation Guidelines addresses all forms of travel. Section G.2., specifically states that "Travel management plans should consider all forms of travel in the affected area (i.e. motorized, mechanized, and non-motorized)."



  • Comment: BLM should discern between cosmetic vs. real/actual damage.

 

BLM Response: The recreation guidelines primarily address land health standards. However, visual resources are a concern in overall recreation management and will also be considered in management decisions.



  • Comment: Close all illegal trails; do not grandfather them in.

BLM Response: Except for areas where transportation planning has been completed, or in Wilderness Study Areas, it is difficult to define "illegal trails". In areas that are currently "open" to vehicular use, trails are not "illegal". Section G. of the Recreation Guidelines identifies measures to help managers mitigate the proliferation of roads and trails.

  • Comment: How will the BLM's national and CO state OHV policies work together?

BLM Response: Any OHV strategy prepared for Colorado will be consistent with the National policy/guidance. Although unlikely, if consistencies are identified, the Colorado guidance will be modified to maintain consistency with National policy.

  • Comment: When the term "appropriate" is used in the guidelines (e.g., F.9., F.11.), who determines what is appropriate?

BLM Response: The authorized official determines what is "appropriate". The term "appropriate" is vague; Sections F.9., and F.11. will be reworded.

Guideline F.9. will be modified to read:

Set aside areas, limited in number and size, for certain high impact recreational uses, such as off-road vehicles, motorcycles, and target practice to be relatively unrestricted. Establishment of such areas must be consistent with the Standards for Public Land Health and other Resource Management Plan decisions.

Guideline F.11. will be modified to read:

Often a land area is utilized by many users; implement feasible management methods to maintain the essential enjoyment elements of the various user groups.

  • Comment: What is "unacceptable" proliferation of roads in G.3., and who determines it?

BLM Response: The placement of the word "unacceptable" as presently used is confusing. The intent is to prevent unacceptable resource damage. Unacceptable damage occurs when the Standards for Public Land Health are not/will not be met. Guideline G.3. will be modified to read:

Until local travel management plans are prepared and implemented, BLM will take prompt action using existing authorities to prevent the proliferation of roads and trails that have caused or will lead to conditions whereby the Standards for Public Land Health are not met.

 

  • Comment: A thorough assessment if OHV use is clearly necessary.

BLM Response: The management of OHV use on the public lands is a high priority throughout BLM. A national OHV guidance is being prepared, and Colorado BLM is examining management options.

 

  • Comment: BLM should develop a monitoring plan.

BLM Response: Monitoring is considered and addressed in individual plans.



  • Comment: BLM should develop an enforcement plan.

BLM Response: Colorado BLM is currently working with other land management agencies to develop effective and efficient law enforcement plans and procedures.

  • Comment: BLM should not allow motorized vehicles in administratively proposed wilderness areas and other wilderness quality lands.

BLM Response: Interim Management Policy (IMP) for Wilderness Study Areas (WSAs) provide direction regarding the use of vehicles in said areas. There are no open areas within WSAs. Some WSAs are closed to all vehicle use, while other WSAs allow vehicles on existing roads, as long as it is consistent with the IMP.

  • Comment: No supplementary funds should be sought for recreational activities.

BLM Response: The recreation budget in BLM, although increasing in recent years, is not sufficient to meet management demands and needs. Additional funding helps meet those needs.

 

  • Comment: Please eliminate the language that singles out motorized recreation.

BLM Response: Motorized use is not singled out in the recreation guidelines; the guidelines address all uses. For example, G.2. specifically states that transportation plans "should consider all forms of travel in the affected area (i.e., motorized, mechanized, non-motorized, etc.)

  • Comment: In F.9., of the Recreation Guidelines, objections to the wording "limited in number and size", referring to high impact recreational uses.

BLM Response: The clause is included to demonstrate that managed intensive recreation use of BLM is an exception, not the norm.

 

  • Comment: In reference to G.4.e. of the Recreation Guidelines, the wording suggests that abandoning and closing roads should only be done as a last resort.

BLM Response: The option of abandoning a road should be considered equally with other options to determine the best method to meet the Standards for Public Land Health.

 

  • Comment: Current wording of G.3 of the Recreation Guidelines will open the door to massive closures of public lands to various uses, especially motorized vehicle use.

BLM Response: This guideline reinforces existing regulations (43CFR8340 and 8360) as well as Executive Orders 11644 and 11989. To meet these regulatory requirements, it may be necessary to restrict certain uses. However, there is nothing in what is written in G.3. that would "open the door to massive closures of public lands".

 

  • Comment: F.8. of the Recreation Guidelines places environmental protection above recreation use.

BLM Response: The Land Health Standards are land use plan decisions that apply to all uses of public lands. The purpose of the Recreation Guidelines is to provide management with the tools to meet the standards.



  • Comment: At least some opportunities of each recreation type should remain open year round.

BLM Response: Generally, BLM lands are managed to accommodate a variety of uses. Decisions to allocate uses that would result in limitations to certain uses are completed through the land use planning process.



  • Comment: Off-road travel is generally no longer an appropriate use of our public lands, off-road play areas are not appropriate if they compromise land health standards.

 

BLM Response: The use of off-highway vehicles to gain access to and recreate on BLM lands will continue to be a valid use on the public lands. The use of such vehicles, however, must be responsible and in such a manner that meets the Standards for Public Land Health.



  • Comment: When any roads/trails are closed, the rationale must be made clear to the public through signs and other information.

BLM Response: To add clarity, Guideline G.6. will be modified to read:

Provide clear maps, signs, guidelines, descriptions, and other information for users of routes, trails, and other facilities or areas, including mileages and estimated hours of travel by type, limitations caused by travel surfaces and conditions, and availability of loop trails. Provide clear information to the public when closures, seasonal use, and other regulations or limits are placed on public lands.



  • Comment: It would be more prudent to spend time and energy toward education then in additional regulations and restrictions.

BLM Response: Information and education are key components for a successful recreation program. However, restrictions may be necessary in some areas to meet management objectives and the Standards for Public Land Health. It is not anticipated that new regulations will be necessary.

  • Comment: Motorized access must also recognize all RS2477 rights-of-way.

BLM Response: Transportation planning will consider all valid, existing rights including RS2477. Furthermore, any "emergency" actions must all consider valid, existing rights.

If you have any questions or would like additional information , please contact Dennis Zachman at the BLM Colorado State Office at 303-239-3883, or at dennis_zachman@blm.gov

Thank you for your interest and participation in this process.