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January 31, 2013

SUBMITTED ELECTRONICALLY TO trails@state.co.us Colorado State Trails Committee c/o Colorado State Trails Program 13787 S. Highway 85 Littleton CO 80125 RE: 2013 competitive OHV trail grants Dear Trails Committee Members: The Colorado Mountain Club (CMC) is pleased to submit our recommendations for the 2013competitive OHV grants, along with our rationale for each recommendation. The CMC appreciates the opportunity to provide written comments on grant applications and participate in the public review process. CMC remains a committed partner to helping gain the maximum public benefit from the grant program in a way that promotes a balance of recreation opportunities while safeguarding natural resources. General Recommendations:  Wildlife and habitat – CMC supports efforts to include the expertise of CPW wildlife staff in the grant review process. We urge CPW to continue to integrate the division’s wildlife expertise in support of the CPW mission. We recommend a formal and institutionalized scientific assessment of the potential impacts to wildlife and habitat for all State Trails grants (OHV and non-motorized) as part of the review process. We appreciate the first steps that have been taken in that direction. Law Enforcement Pilot Program – though this does not pertain to a specific grant, CMC wants to endorse this program. We support making the program permanent, as it is a complementary component of Colorado’s active and progressive management of OHV recreation. BLM Inventories – BLM should rely on BLM staff or professional contractors using BLM guidance for route inventories to establish a baseline for subsequent travel management planning. Relying on local OHV clubs is a conflict of interest, since the local clubs have a perverse incentive to try to maximize the baseline inventory with long disused or largely reclaimed tracks to try to increase the total opportunity for riding in the final TMP. This caveat applies to grants 15, 29 & 33.

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Specific Grant Recommendations: Generally, our assessment of competitive grants looked at three categories that could be applied to most grants: 1. Implementing “Active Management” for areas that are trying to implement travel plans, inventory routes at the beginning of a travel plan or generally shift from unmanaged recreation to a more sustainable system that reduces damage to natural resources. We view this as the highest priority grant and urge the State Trails Committee to fund these important requests. Grants CMC supports in this category include: #9 Hermosa Creek Trail OHV Project #10 Captain Jacks Trail 667 Rehabilitation #12 Flattops OHV Trail Crew #13 Trail Construction & Monitoring #15 Little Snake F.O., BLM, Motorized Route Inventory #17 Eagle-Holy Cross R.D. OHV crew #18 Divide R.D. OHV trail crew #21 UTV purchase, Uncompahgre F.O., BLM #25 SCC RGNF Trail Maintenance Project – Creede #27 RGNF forest wide signing #29 Tres Rios F.O., BLM OHV Grant #33 White River F.O., BLM, OHV trail crew 2. Maintenance for existing trail systems is necessary for high-use areas and sustainable management of OHVs that protects natural resources and other nearby recreational opportunities. We believe this critically important category is the second highest funding priority. Grants CMC supports in this category include: #3 Deadman Trail Bridge #6 Royal Gorge BLM OHV trail crew #8 Gunnison BLM OHV trail crew #16 Grand Mesa & Uncompahgre Project #24 Pikes Peak R.D. Sustainable OHV Management #36 Rampart Range Motorized Management Committee 3. Expanding Opportunity to provide new OHV riding opportunities. This traditional funding request for new trails and more opportunity can be an important tool in managing OHV recreation. We believe that the above categories of implementation of active management and maintenance of existing systems are of higher priority and should be funded first. Grants CMC supports in this category include: #2 Reno Divide Heavy Trail Maintenance #38 Rampart Trail Construction, Phase III 4. Other grants CMC supports (that do not neatly fall into the above categories) #30 Stay the Trail Ambassadors #32 Jenny Creek Motorized Trail Re-route & Restoration 2

#37 Colorado OHV Workshop

Competitive Grants CMC opposes: #11 Three District Single Track Maintenance -Significant trail upgrades/conversion under the guise of routine maintenance -Conversion of non-motorized trails to motorized without NEPA analysis -Already sufficient OHV grant funding for Pike San Isabel NF in other grants #20 Grand Junction Field Office, BLM -Funds planning & construction of controversial trails in Bangs Canyon around Rough Canyon #35 Wagon Wheel Trail Expansion -CMC and conservation community at large oppose this large-system vision for NW CO and NE Utah Any grant we neither endorse nor oppose, the CMC takes no position. Rationale for recommendations is in the attached appendix. Please do not hesitate to contact me if you have questions. Sincerely, Scott Braden Conservation Director scottbraden@cmc.org (303) 996-2768 CC: State Trails Program Staff Steve Yamashita Ken Brink, CPW Chris Sporl, USFS Jack Placchi, BLM

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Appendix – Grant Support Details OHV Competitive Grants, 2013 (for 2014 field season): CMC SUPPORTS: #2 Reno Divide Heavy Trail Maintenance (amt. requested $54,000). Provide for maintenance of 18 miles of multiple use single track trail near Crested Butte. Letter of support from High Country Citizens Alliance. #3 Deadman Trail Bridge, Gunnison R.D., GMUG (amt. $70,000). Build multiple-use bridge over stream in heavily used area. Concentrates crossing, other than equestrian, out of riparian area. CMC supported same proposal in 2012, but it wasn’t funded. #6 Royal Gorge BLM OHV trail crew (amt. $40,000). Provide trail maintenance and closure of user created trails in heavily used areas such as Gold Belt & Texas Creek. We supported same in 2012. #8 Gunnison BLM OHV trail crew (amt. $40,000). Provides maintenance & user education (25% of grant amount) in heavily used OHV areas of Hartman Rocks & Alpine Loop. #9 Hermosa Creek Trail OHV Project (amt. $46,450). Continues work began several years ago in heavily used multiuse area north of Durango & outside of Durango Mountain Resort. 30% of budget to be directed towards education, visitor contacts, enforcement. #10 Captain Jacks Trail 667 Rehabilitation (amt. $38,000). Re-routes 6 of 8 miles of single track trail from near stream bed with critical threatened population of Colorado greenback trout. Sponsor is Colorado Motorcycle Trail Riders Assn. Project endorsed by Trout Unlimited. #12 Flattops OHV Trail Crew; Blanco & Rifle R.D.s., WRNF (amt. $76,659). 3-person crew doing needed trail maintenance on these districts. Will buy a UTV. Do claim that visitor numbers are increasing, but have not done accurate counts. 20% of budget for education, enforcement. #13 Trail Construction & Monitoring, Uncompahgre F.O. , BLM (amt. $44,000). Will have Youth Corps crew, and hire LEO for three weeks in October for hunting season. 35% of grant for education & enforcement. Letter of support from local wildlife manager. #15 Little Snake F.O., BLM, Motorized Route Inventory (amt. $99,987). Doing route inventory using COHVCO data collection techniques. Letter of support from area wildlife manager in Meeker. Conditional support from Moffat B.O.C.C. in that they want coordination with Moffat County Land Use Board. BLM is trying to get data support from oil and gas industry. #16 Grand Mesa & Uncompahgre Project (USFS) by Western Slope ATV Assn. (amt. $84,000). Annual trail maintenance program on the Mesa & north end of Uncompahgre Plateau. Volunteer patrollers will have 2-way radios to call in problems to USFS or Mesa Cty. Sheriff. Support letter from Ron Velarde, NW CPW manager.

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#17 Eagle-Holy Cross R.D. OHV crew (amt. $42,840). 2 person crew on ATVs doing maintenance & education contacts; 40% of grant to be devoted to education & enforcement. Crew will be from Student Conservation Assn. Good 2012 report included. $20,300 in support (ATVs) from Nova Guides. Support letter from Rocky Mountain Elk Foundation. #18 Divide R.D. OHV trail crew (amt. $89,250). Have 4 person trail crew for maintenance and visitor contacts (education & enforcement is 15% of budget). 2 of the crew will be sent to FPO training. Will purchase one ATV and lease an excavator. #21 UTV purchase, Uncompahgre F.O., BLM (amt. $13,240). Need a vehicle of this size for sign installation, carrying extra staff engaging in travel plan implementation, etc. #24 Pikes Peak R.D. Sustainable OHV Management (amt. $195,800). Seasonal trail crew to work on three districts. Youth corps for a week. Install vault toilet at 357C trailhead. 3-5 miles of re-route on 717. Purchase UTV. More revegging in Hayman Burn. Large leverage $$. Letter of support from RMRI. #25 SCC RGNF Trail Maintenance Project – Creede (amt. $74,400). 18.8 miles of trail to be maintained; 5 different trails. No apparent overlap with grant #18. 0 % for education & enforcement, but grant narrative states crew will do visitor contacts & education as they work. #27 RGNF forest wide signing (amt. $58,615). Erect 80 portal signs, do extensive route signage, provide FPO training for seasonals & ATV Safety Institute Training. Also want to establish internship program with Adams State. Unclear how this relates to RRF’s Grant #39. #29 Tres Rios F.O., BLM OHV Grant (amt. $97,760). Has Phase I route inventory for 400,000 acres in NW part of field office: Disappointment Valley, Dry Creek Basin, Gypsum Valley. Second part of grant supports patrolling, education, enforcement on Tres Rios part of Alpine Loop. Support letter from Mountain Studies Institute in Silverton. #30 Stay the Trail Ambassadors (amt. $71,558). This is a continuation from the OHV Pilot Project. The group has done valuable educational contact work with users, per their Pilot reports. Letters of support from Jim Bedwell, USFS & Ben Lawhorn at Leave No Trace. #32 Jenny Creek Motorized Trail Re-route & Restoration, Boulder. R.D., ARNF (amt. $29,000). Finishes restoration part of project partially funded in 2012. #33 White River F.O., BLM, OHV trail crew (amt. $54,060). Doing inventory primarily in Magnolia Bench/Little Hills area southwest from Meeker and west of State Hwy. 13. Travel planning to follow. Will also maintain and sign existing routes on the entire Resource Area. #36 Rampart Range Motorized Management Committee (amt. $196,040). This is the primary maintenance grant that helps keep the Rampart Range “zoo” under reasonable control. Use trail dozer and excavator. #38 Rampart Trail Construction, Phase III; S. Platte R.D. PSINF (amt. $176,800). Will have 10 week crew to build up to 18 miles of new single track per the 2005 Rampart Range Plan (NEPA document). Will re-locate 300 yards of 677 where it crosses Sugar Creek. Still having sediment problems, as identified by CDPHE. Sugar Creek drainage also intended as mitigation for Prebles Jumping Mouse habitat to be lost if Chatfield Reservoir expansion plans go ahead.

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CMC OPPOSES: #11Three District Single Track Maintenance by Colo. Motorcycle Trail Riders Assn. (CMTRA) (amt. $56,800). We question the need for this grant, to work on several trails in the PPRD area. One of the identified trails, 731, apparently is actually an ATV trail with 50” restrictor barriers. Including their GM grant; the CMTRA Captain Jacks grant; and Grant #24; if all are fully funded; the Pikes Peak R.D. will receive $213,800. South Platte R.D. & Rampart Range MMC, including the GM grant; if all is funded; is on track to receive $452,840. The RRMMC further provides assistance to the San Carlos R.D., which has its own GM grant of $80,000. Regarding work on the South Park district, trails originating from the Horseshoe Campground are user-created trails without NEPA analysis, even if some appear on the MVUM. Trail 691 in particular on the west side of Sheep Mountain goes straight up the fall line and there is no trail on the east side. Some of the trails or trail segments proposed for motorcycle maintenance show no signs of motorcycle use and appear never to have been designated for motorcycle use at all. Because some segments of the trails are mere foot paths or don’t exist on the ground at all, maintenance would in fact mean trail construction, a significant upgrade changing the entire character of the trail. The amount of money going into the Pikes Peak and South Platte districts, combined & if everything gets fully funded, is in excess of $666,000. This is over 15% of the total money available, which is $4.2 million. #20 Grand Junction Field Office, BLM – Grand Valley Trails Grant 2014 (amt. $84,000). This grant apparently is all for planning, with youth component and NEPA documentation. While specific locations are not provided, the areas to be considered apparently are within North Fruita Desert & Bangs Canyon. About 10 miles in each area would be maintained and additional new miles dependent on NEPA. From the application: “These trails are becoming more of a priority as we have more motorized users coming to visit Western Slope.” The grant makes no reference to any kind of social survey of users to determine need. The claim in the proposal that “There has not been any controversy identified with this project proposal” is untrue. In fact, the NEPA document generated for the Bangs Canyon component; an environmental assessment (EA); is highly controversial. The need for 21 more miles of new trails in Bangs is based on a proposal from an outside group; and on anecdotal comments from an unknown & unidentified number of motorized users. The agency has not done any sort of social survey, but admits in the EA that other users, specifically hunters and hikers, may be displaced by new motorized trails. In addition, the Bangs EA does not consider the availability of other trail resources within the Resource Area; specifically North Fruita Desert, the acreage near the Grand Junction airport, Rabbit Valley and other areas. We note concern expressed by the OHV Subcommittee and CPW trails staff at the Good Management Grant review meeting on January 4, 2013 regarding reporting from this office and whether or not GM money is actually being used for OHV purposes. #35 Wagon Wheel Trail Expansion, Rio Blanco B.O.C.C. (amt. $265,300). Will build an OHV connector trail between east end of Meeker and intersection of Hwy. 13 & County Road 8; all to be built within CDOT right-of-way. B.O.C.C., Meeker, Meeker Chamber putting in $121,000 match. Wetlands in CDOT ROW. CMC and the Colorado and Utah public lands conservation community does not support the Wagon Wheel system vision of a large system throughout public lands in NW CO and NE UT. 6