Day: September 29, 2022 - Utah Public Lands Alliance

The Moab Travel Management Plan is vitally important to all motorized vehicle users, 4×4, ATV, and motorcycle. There is tremendous support for the most conservative Alternative B from SUWA, and if we don’t all get behind the effort to submit comments, we may lose 400+ miles of trails in Moab. Not only that devastating effect, but it will also lead to closures of many dispersed camping locations, and will likely also embolden SUWA to push for Wilderness designation.

There is a huge effort on behalf of many off road groups including not only UPLA, but Blue Ribbon Coalition/Sharetrails, Colorado Offroad Trail Defenders, and the Colorado Off Highway Vehicle Coalition. Let’s trust these organized groups to handle the legal demands.

What we need from every user, or potential user of these trails is to make their voices heard on specific trails that are important to them. Some of the items you may include in your comments are:

How often you’ve done the trail, or if you plan to do it in the future, mention it’s on your bucket list
What specific value or features make the trail special
Who did you go with? Friends, Family, Kids, Clubs
Did the trail have particularly heavy or light traffic when you did it
Is this trail an important connector to another trail
Are there camping sites along it? Did you camp?
Is it on publicly available resources such as Guidebooks, EJS Routes, Online Trail Maps? Mention where you’ve seen it featured
Photos that show popular features of the trail, or the general road condition or signage-Photos are vitally important to telling your personal story, don’t hesitate to share photos with people in them to personalize it

General comments about the potential impact to the local economy or other factors are also helpful such as How often you come to Moab? OR How long do you usually stay?

The most difficult thing about writing comments about specific trails is finding which trails may be affected. To help with that, we have compiled a list to help with the location of the affected areas, this list is still being compiled so check back to see any additions to the list.

Don’t get concerned about what Alternative is affected, if it’s on the list, tell them why it’s important
Comment on the trails that are specific to your experience. DO NOT COPY AND PASTE THIS LIST INTO YOUR PERSONAL COMMENTS, THAT RUNS A RISK OF HAVING THE PROFESSIONAL COMMENTS BEING WRITTEN DISCARDED AS DUPLICATES.

Don’t wait, start making your comments now, you can make as many and as often as things come to you.

2 Ways to Submit Comments:

Submit directly on the BLM website. Click on Participate Now, then scroll to the right to click on Participate Now a second time. If you use this method, please send a copy of your comments to brc@sharetrails.org
Submit using the Blue Ribbon Coalition Comment Writer. Scroll down to “Add Your Voice” It will generate a general template, be sure to edit it as much as you can and include your specific comments in it before you hit Send.

General Comments: We are extremely disappointed with the draft alternatives under consideration at this stage of the process. While alternative D is largely acceptable and keeps all of the most valuable routes open, the mass closures of important motorized routes contemplated in alternatives B and C are wholly unacceptable to the motorized community. These two alternatives represent a massive departure from both the 2008 RMP and the historical management of the area and are simply not justified either legally or factually.

Though alternative C appears to be positioned as the middle-ground “blended” or “balanced” alternative (thus we will treat it as the BLM’s likely preferred alternative in our comments), we see little difference between it and the “conservation” alternative B. Both alternatives would result in the unacceptable closure of at least portions of many of the most valuable motorized routes in the region, including multiple Jeep Safari trails and trails like Ten Mile Canyon and Hell Roaring Canyon which the BLM has previously acknowledged provide critically important motorized recreation opportunities. Even the pro-motorized alternative D inexplicably closes part of the Buttes and Towers Jeep Safari route, though it is acceptable in most other respects.

We submit these comments to request that the BLM adopt a modified version of Alternative D as the final travel management plan for this area, and we ask that you preserve the maximum number of opportunities for motorized recreation, particularly for full-size four-wheel-drive vehicles. As an alternative, adoption of Alternative C would need to include the following specific areas of concern.

Here’s our suggestions to help you identify affected trails…

Specific Areas of Concerns: These descriptions are intended to help you identify areas that you are familiar with to make comments on. DO NOT CUT AND PASTE THESE COMMENTS, IT MAY DAMAGE OUR OTHER EFFORTS AND MAKE COMPREHENSIVE COMMENTS BY OUR PROS DEEMED A DUPLICATE.

THERE IS NO NEED FOR YOU TO MENTION EACH OF THESE TRAILS, ONLY THE ONES THAT ARE SPECIAL TO YOU AND YOU HAVE A PERSONAL CONNECTION TO.

On September 30, we’ve added the primary reasons cited for each closure using the following letter designations that should be helpful in making comments

W-Wilderness characteristics-
R-Riparian and Vegetation impacts-splits or widening of trails, proximity to watersheds, soil erosion
WI-Wildlife Impacts, mostly bighorn sheep lambing
C-Cultural Impacts
U-User conflicts, can be river rafting, hiking, mountain biking
T-Trail Condition, lightly used or obscured, spur or duplicate not deemed necessary

The most important route we wish to comment on is D2759, commonly known as the Ten Mile Canyon Trail or the Ten Mile Wash Trail. Alternative C considers closing the lower two-thirds of this trail (D2759B) below the Midway Access Road. Alternative B goes even further and closes the entire Ten Mile Canyon trail and the Midway Access Road to motorized use. Both of these alternatives are utterly unacceptable to the motorized community, and we vehemently oppose closing any portion of Ten Mile Canyon to motorized use. Only alternate D keeps the full Ten Mile Canyon route open to motorized use; and we strongly urge its adoption. (W, R, WI, U)
We strongly oppose the closure of the upper two-thirds of the motorized route at the bottom of Hell Roaring Canyon (D1223C), as proposed in alternative C, and the closure of the entire trail past the Mineral Bottom airstrip as proposed in alternative B. (R, U, WI)
We object to the closure of the D-road portion of the Mineral Canyon road (D1217) as proposed in alternatives B and C. This extremely scenic route is featured in both a published guidebook and online trail guide and provides crucial access not only for motorized recreationists, but also for hikers and BASE jumpers. The closure of this road would severely harm multiple recreational user groups and is simply not warranted. The entire Mineral Canyon road, including the D1217 segment, serves an important purpose and need in providing recreational access for three distinct user groups: (1) motorized users, (2) hikers, and (3) BASE jumper vehicular retrieval. (WI, R, W)
Hey Joe Canyon (D1527) is an extremely scenic trail along the Green River through Labyrinth Canyon that has long been a staple of the Easter Jeep Safari trail system. Alternative B was modified to close both it and the neighboring route downstream along the Green River from Spring Canyon Bottom (D1526). We are concerned by the fact that the BLM would consider closing Hey Joe Canyon in any alternative (WI, R, W)
We object to the proposed closure in alternatives B and C of the trails in Upper Hidden Canyon (D2387, D2387A, D2398A, D2384). Together, these trails form a popular spur trail off the 3D Safari trail. The trail has been well managed and is lined with fences for nearly its entire length, so concerns for damage are minimized. (R, WI)
We strenuously object to the proposed closures of vitally important segments of the world-famous Sevenmile Rim (D2398B, D2398D, D2398F, D2437) Jeep Safari trail included in alternative B. It appears that there are mapping errors that may have been corrected by BLM that removed it from the C Closure list, but we urge that you keep these routes open in your final approval. (R, WI)
We vigorously object to the closure of D2393, which is proposed in all of the action alternatives. This route loops around Pasture Butte and is a critical segment of the Buttes and Towers Easter Jeep Safari Trail. The Buttes and Towers Trail is one of the most popular safari routes. (R, WI)
We strongly oppose the closure of D2624 and D2633, as proposed in alternatives B and C. D2624 is referred to by Moab locals as either the Lost World Butte trail or the Lost World Valley trail because it runs through the valley below Lost World Butte. It is a popular 4×4 trail that is part of the longer “Rainbow Spire” route, which consists of the Rainbow Rim trail (D2618), the Lost World Butte trail (D2624), the Rainbow Terrace trail (D2626), and the Dellenbaugh Tunnel leg of the Secret Spire Safari route (D2621 and D2053) (WI, R)
We strongly oppose the proposed closure of 7-Up Trail (D1944, D1945, D1946B, D1754, D1953) in alternatives B and C of D1944, which is the eastern end of the 7-Up trail which connects to Highway 313 at the switchbacks climbing out of Sevenmile Canyon. There is a popular challenging section of the trail, access to campsites, and the entire route makes a nice connection to Metal Masher and Gemini Bridges Road.(WI, T, U, R)
We object to the proposed closure of portions of West Arths Rim Loop in alternative C of D1915, D1916, and D1922, which are a critical part of a highly scenic, lesser-known loop trail off the northwestern end of Metal Masher on West Arths Rim. This loop consists of D1915, D1916, D1922, D1930, and D1931, and travels northwest along the rim of Box Canyon out to two scenic overlooks on the northwestern extremity of Arths Rim. A connecting road (D1930) then connects back to Metal Masher near the Widow Maker obstacle. The most scenic part of this loop following the Rim above Box Canyon is proposed for closure in alternatives B and C, which we believe to be unwarranted. (R, WI)
We object to the proposed spring seasonal closure of the Day Canyon Point (D1625A, D1625B, D1630, D1627, D1704) Jeep Safari trail in alternative C, and the proposed complete closure of this extremely valuable route in alternative B. We oppose the closure in alternative C of the side route D1704, which is incorrectly mapped as a dead-end when in fact it connects to a trail on SITLA land. The proposed seasonal closure from April 1 – June 15 would likely make the route no longer available for use during Easter Jeep Safari, at least outside of official EJS trail runs. (WI, U, R, W)
While seasonal closures may be appropriate on less popular routes, to have one of the most popular trails in Moab closed during peak spring season would cause severe harm to the motorized recreation experience in the area. We ask that the BLM adopt the alternative D designations with respect to D1625A, D1625B, D1630, D1627, D1704 and keep all of them open year-round.
The Deadman Point trail is an easy Easter Jeep Safari trail and consists of several different branching spur routes that go out to various overlooks of Labyrinth Canyon on Deadman Point between the mouth of Hell Roaring Canyon and Bowknot Bend. D1501 and D1507 are proposed for closure in alternative C, while all of the routes past the end of D1497A would be closed in alternative B. We strongly oppose all of these closures, which would deprive motorized users of access to important scenic overlooks on the rim of Labyrinth Canyon. (WI, W)
We strongly oppose the closure of routes in the Courthouse Rock and Tusher Canyon area including all of the following D2457, D2453, D2377, D2478, D8466, D2482, D2498, D2379 & D2375. These routes are very popular and affect Wipe Out Hill, connector routes, scenic canyons off Tusher Wash and Canyon. It appears that some of these closures may have been inadvertent errors in mapping. We urge them to be kept open in all Alternatives. (None)
The Mashed Potatoes trail (D2562) is proposed for closure in alternative B, which we adamantly oppose because it is a highly valuable Jeep Safari trail and is a major trail featured in published guidebooks. We are glad to see it remains open in alternative C, and ask the BLM to adopt this designation in the final travel plan. We also ask the BLM to correct its mapping of this route, which actually has two parallel paths in places. We also oppose closures of the following short spurs to scenic overlooks (D2560, D2559, D2524A, D2577, D2392A, D2375A, D2359, D0037, D2491, D2554, D2383B) (T)
Seven Mile Canyon Routes (D1980, D1972). It appears that D1972 and D1980 both have mapping errors, and support keeping the currently open portion of D1972 as proposed in Alternative C as it provides a scenic viewpoint. (T)
D1941 is proposed for remaining open in Alternative D with a seasonal closure, and we support adding this to Alternative C (T)
D1917A is an important and regularly used route which accesses a scenic overlook of a side spur of South Fork Sevenmile Canyon. It is simply a continuation of the southern portion of D1917, which begins on a SITLA parcel at the base of the Widow Maker obstacle on the Metal Masher Jeep Safari Trail. (T) D1917 and D1917A form a scenic side spur off the Metal Masher trail which is commonly driven in conjunction with it. We strongly oppose the closure of D1917A as proposed in alternative C, and we believe this closure may be proposed in error. (T)
Sevenmile Canyon Overlook (D1908A) is a highly scenic and lightly used half mile overlook that is currently slated for closure in B and C. We support keeping it open in all Alternatives. (T)
D1908 is a short spur that goes to a sheltered hollow along the side of Widow Maker Mesa. Dispersed camping is allowed along this trail and there are a couple places which would make good campsites. It is well-defined and regularly traveled, and there is no justification for closing it as is proposed in alternative B. We ask that this route be kept open to motorized use as proposed in alternatives C and D. (T)
D1843 Three Pools Pour Off is a 2 mile spur that goes to an overlook, it is open in Alternatives C and D, we advocate keeping it open. (T)
D1998A is a short spur that offers scenic overlooks of Monitor and Merrimac Buttes. We urge that it be kept open together with the rest of D1998.(T)
Arths Pasture Route D0017 appears to be closed in B, C, and D, most likely because of a mapping error. We strongly encourage keeping this scenic route open in all Alternatives. (T)
D1879 is proposed for closure in alternative B, open with a seasonal closure for bighorn sheep lambing in alternative C, and open in alternative D. While we are grateful this route is still open in alternative C, we believe the seasonal closure in alternative C is imposed in error, as the route is not in bighorn sheep lambing habitat as defined in the 2008 RMP. The route report incorrectly lists D1879 as being in a bighorn sheep lambing area with a camping restriction. In reality, it is not within a restricted camping zone established for bighorn sheep lambing habitat, but just outside of one. (WI)
D1876 Periscope Canyon is proposed for closure in alternatives B and C and kept open in alternative D. We do not believe it is in the bighorn lambing impact map, and should remain open. D1871 and D1872 provides access to scenic views and camping. D1860 and D1864 provide access to Metal Masher. (WI) D1804 is a valuable connector route, and may actually be a candidate for a future EJS route. We strongly encourage you to keep it open in all Alternatives. (T)
Golden Spike is proposed to remain open in Alternative C and D, but we strongly oppose the closure of this route in B, as well as D1579B and D1579C, which include features like the Golden Crack obstacle. Closing any of these routes would be a huge blow to the triad of trails in this area. Mapping errors exist in this area, for example the Skyline Drive section is improperly omitted on BLM maps and thus excluded from the authorized route map. (T)
Gold Bar Rim (D1595, D1579C, D1579D) These are proposed open in C, but the closure in B would affect all 3 of the popular trails in this area.(T)
Where Eagles Dare (D1579, D1579B) should both remain open in Alternative B and it is in C & D (T)
Rusty Nail D1592A, D1592B) is an extremely valuable motorized route, and while we are glad it is proposed to remain open under alternative C, the entire trail would be closed in alternate B. This is utterly unacceptable to the motorized community. Closing this route would leave only three other Easter Jeep Safari routes (Cliffhanger, Pritchett Canyon, and Hell’s Revenge (Escalator Version) suitable for heavily modified rock crawlers, plus the Coyote Canyon trail which is not used during EJS.
Four Arches Canyon D1775 is the route up Four Arches Canyon, which begins on a SITLA parcel in Crips Hole near a Boy Scout camp. This is a highly scenic and moderately challenging 4×4 which allows drivers to explore a neat canyon and view several natural arches. It is also a powerline access road and is necessary for powerline maintenance. We strongly oppose closing this route as proposed in alternative B, and ask that it be kept open as proposed in alternatives C and D
D1777 is an easy route up the bottom of Saucer Canyon, and offers a great camping area that would become inaccessible in alternative B. It appears that BLM route data may be incorrect causing it not be included properly in the routes.
Boulder Bridge D1781 and D1872 provides hiking access to a natural bridge. There is no justification for closing this route as proposed in alternative B, and we urge the BLM to keep it open as proposed in alternatives C and D.
D1602 is the route up Dry Fork Bull Canyon. This route is proposed to stay open in alternatives C and D but is proposed for closure in alternative B. The closure in alternative B was added at the request of Grand County, based on allegations of user conflict between motorized and non motorized users., which are unsubstantiated.

What Should I Do to Prevent Moab Closures