Turn Your Trail Experience Into a Powerful Voice

       — In Minutes

If you’ve ever ridden a trail, camped with your family, or explored Utah’s backcountry, you already have something incredibly valuable: real-world experience.

And right now, that experience matters more than ever.

When the Bureau of Land Management (BLM) considers closing roads and trails, they are required by law to consider substantive public comments—not just opinions, but well-structured, experience-based input.

The problem?
Most people don’t know how to write a “substantive” comment.

That’s exactly why we built the UPLA Comment Coach.

A Tool Built for Real Trail Users

👉 Start here: https://form.jotform.com/261215118081043

Our Comment Coach—powered by Jotform—takes the guesswork out of the process.

Instead of staring at a blank screen wondering what to say, you simply:

• Answer a few guided questions
• Share your trail experience
• Select from structured prompts
• Add your personal observations

That’s it.

From Simple Notes → Substantive Comment

Behind the scenes, the tool organizes your responses into a format that aligns with what the BLM must legally consider.

When you’re done:

• Your comment is automatically formatted correctly
• It is structured to be substantive
• It is emailed directly to you, ready to submit when the comment period opens

No writing skills required. No legal knowledge needed. You ;can edit the text or just copy and paste it to BLM or Forest Service.

What Makes a Comment “Substantive”?

A substantive comment:

• Identifies a specific route or issue
• Explains how and why you use it
• Provides firsthand observations
• Points out potential flaws in agency analysis
• Offers a clear recommendation

That’s exactly what the Comment Coach helps you do—without you having to learn the rules.

Real Example from the Tool

Here’s what a completed comment looks like after using the Comment Coach to answer a few questions:

My name is Loren Campbell. I am a member of Utah Public Lands Alliance, BlueRibbon Coalition and I am submitting comments regarding the reconsideration of route Test346 in Both the San Rafael Swell and Desert. I use this route for UTV/OHV, 4×4, Camping access.  I used it once before to camp, and want to be able to go back.. 

This route is important because it connects to other trails, dispersed Camping or Overlook Trail. This trail connects to several others which is important not only for its scenic value, but also provides connectivity that can be crucial in an emergency on the trail. There is also a fantastic camping site with a great overlook that is no longer available without this route.

From my direct experience, I have observed that responsible use observed 

I believe the closure may be flawed and should be reconsidered because Impacts overstated.

I recommend that the BLM Reopen the Route. Please reopen this route, we need it.

I confirm that this is based on my personal experience and thank you for reconsidering this closure.

Respectfully,

Loren Campbell
Virgin, UT

That’s the difference.

Not just a comment—
A comment that must be considered.

Why This Matters Right Now

Across Utah and the West, thousands of miles of routes are being evaluated for closure.

If we don’t speak up effectively, decisions will be made without the benefit of real user experience.

So how much of a difference can it make? In the San Rafael Swell Travel Plan that closed 660 miles of routes, the State of Utah did a detailed analysis of the 5-6000 comments, no routes were closed that had 20 or more substantive public comments. Most roads that had 7 or more substantive comments unless they crossed a known archeological or paleontological site. If there were fewer than 4 substantive comments, the closure rate was high. Generally, the public commented both sparingly and very poorly on short routes that led to overlooks or dispersed campsites, resulting in many closures. Submitting substantive comments can make a huge difference, and if you can get friends that went with you on that ride to also write comments, it can lead to reopening the routes and dispersed camping.

Agencies rely heavily on their own data—but your on-the-ground knowledge is often missing unless you submit it.

Your Voice Carries More Weight Than You Think

You don’t need to be an expert.
You don’t need to write perfectly.

You just need to:

• Share what you’ve seen
• Explain how you use the trail
• Submit your experience in a way that counts

The Comment Coach does the rest.

Take Action in 5 Minutes

👉 Use the UPLA Comment Coach now:
https://form.jotform.com/261215118081043

One Ride. One Form. Real Impact.

Every trail you ride is an opportunity to protect access.

With the UPLA Comment Coach, your experience becomes:

• Organized
• Credible
• Legally relevant

And most importantly—impossible to ignore.

Loren Campbell
President, Utah Public Lands Alliance

At the heart of every land use decision affecting closure of our public lands to OHV, both with administrative agencies of BLM and Forest Service, and court decisions is the Minimization Criteria. This regulation became the backbone for nearly every modern Travel Management Plan (TMP), route designation decision, OHV closure decision, and litigation involving motorized access. The minimization criteria requires that BLM must locate OHV routes to minimize impacts to

1) Resource damage (including soils, watersheds, vegetation, air quality, and other public land resources-and to prevent impairment of wilderness suitability.

2) Wildlife impacts including wildlife harassment and habitat disruption, with special attention to endangered or threatened speciies.

3) User Conflicts between motorized users, nonmotorized recreation, and nearby populated areas, including noise considerations.

4) Protection of Special areas such as wilderness and primitive areas.

The rule was not established under FLPMA by Congress and was not even alluded to when it discussed the principal of the multiple use mandate and sustained yield. It was created by Executive Orders 11644 and 11989 under Presidents Nixon and Carter, and resulted in the adoption of CFR 8342.1.

In the final days of the last administration, Nada Culver, BLM’s Former Director, published a blistering BLM Policy Memorandum on the application of the Minimization Criteria directing BLM employees to strictly enforce a requirement that they minimize OHV impacts (use) in every land use decision. Culver included a precursor ruling on the WEMO case that is the subject of the current closure. UPLA and BlueRibbon Coalition have been working to get this rule rescinded ever since Culver published her Memo, along with the underlying 1970s era Executive Orders. (See our joint petition urging recission of the minimization criteria.)

The great news is that we’re getting very close to a positive result. Next month we have a meeting with a key policy analyst in Washington DC that is receptive to our request. What they have asked for us to bring to the meeting is evidence of public support for this action.

Next week, the House of Representatives will be voting on an important update to the Endangered Species Act H.R. 1897 The ESA has been another constant source of OHV closures on our public lands. Congressman Bruce Westerman will be presenting H.R. 1897 for a full House Vote next week, and we would like your support for the bill. Here’s some of the reasons we support this amendment.

First, we strongly support the bill’s emphasis on measurable species recovery outcomes rather than indefinite protection status. While the ESA has played an important role in preventing extinction, its success should ultimately be judged by its ability to recover species to the point where protections are no longer necessary. Refocusing the statute toward recovery aligns incentives, improves accountability, and better serves both wildlife and the public.

Second, we appreciate the inclusion of economic and practical considerations in decision-making. Public lands are managed for multiple uses under statutes like FLPMA, and ESA implementation should recognize real-world impacts on communities, infrastructure, and responsible recreation. A more balanced approach will foster durable conservation solutions that can be successfully implemented and sustained over time.

Third, UPLA strongly supports provisions that ensure state and local input is meaningfully considered. Counties, state agencies, and local stakeholders possess critical on-the-ground knowledge and are often best positioned to implement effective conservation strategies. Incorporating this input will improve both the quality and legitimacy of ESA decisions.

Fourth, we support the establishment of a species ranking and prioritization system. Moving away from a one-size-fits-all framework allows agencies to allocate limited resources more effectively, focusing attention where it is most needed and where recovery is most achievable. This is a practical and results-oriented improvement over the current system.

Finally, we endorse the bill’s broader and more inclusive definition of “best available science.” Recognizing credible state, local, and field-based data alongside traditional sources will strengthen decision-making by incorporating real-world observations and long-term experience from those who actively work on the landscape.

UPLA also supports efforts within the legislation to reduce excessive and repetitive litigation that can delay or undermine effective conservation outcomes. The current system too often incentivizes serial lawsuits and forum shopping, creating uncertainty for land managers, stakeholders, and conservation efforts alike. Establishing clearer standards and reducing unnecessary litigation will help ensure that resources are directed toward on-the-ground recovery actions rather than prolonged legal disputes.

UPLA believes these reforms represent a constructive path forward—one that maintains a commitment to conservation while improving effectiveness, transparency, and collaboration.

Comments are currently closed, but email me your comments and/or voice of support and I will have them inserted into the Congressional record through our lobbyist. Please be sure to include your full name, address, and Club name in the email.

Thank you for your support!

Loren Campbell
President, UPLA

Read Our Letter to the Department of the Interior and Elected Officials

 Learn More Details and Add Your Name to Take Action by Visiting BlueRibbon Coalition’s Action Alert

NEPA rules that were proposed last summer have now been finalized, and they are very disturbing. The new rules dramatically reduce the requirement for Agencies to allow comments from the public, both in reductions in the stages or actions, the open period for comments (as little as 10 days), and revision of the Review Conferences to be conducted by the same person that signed the Decision rather than an independent person. These are only a few of our concerns, and we forwarded these comments to both Forest Service and elected officials.

There’s nothing you need to do at this time, but just want you to be aware of this and our pursuits.

Our friend Brett Stewart at Utah OHV Advocates has been very active in protecting our OHV rights for several years, and he provided this brief update of activities he has worked on. Thanks so much Brett!

• Moab Town Council wanted to change speed limits and it was already a mess. They placed two different speed limit signs in their city on the same street, which is very confusing. I recommended one speed limit and sign for all motorized vehicles. I reached out to the city lobbyists and asked him what he’s doing; that didn’t go well. Then I talked with Moab city councilman Jason Taylor and Rep. Monson, who represents that district, and they were awesome to work with. Councilmember Jason Taylor agreed it was a good idea to remove the second signs and will pursue with City Council.  Stay tuned.
• HB 49 was introduced, asking for an additional $400,000 to come out of the OHV restricted account for the DNR Rangers to give them a raise after they already received $3.8 million from our OHV account. We were able to kill that bill.
• HB 545 is a bill that had some language in it that would’ve made all of our grants in the state of Utah a reimbursement, with no upfront funding, which would’ve killed our grant program. We award about $5 million per year in grants out of the OHV account, many small government agencies and nonprofits don’t have the money to upfront it and then get reimbursed? The sponsor amended that, and we eliminated that part of the bill.
• SB 190 was labeled as a Trailer Bill, but deep into the language, it included off-highway vehicles. It would have made it so when you license your OHV and pay four years’ worth of fees in advance, you would be exempt for the life of that particular vehicle, which sounds appealing, but we believe the OHV program could’ve collapsed if everybody did it all at once. We got the sponsor willing to eliminate the OHV language, and the trailer bill passed.
• HB 444 is a very good bill to further the protection on Class D roads. We worked with the sponsor of that bill, Representative Troy Shelley, and he agreed to insert language in his bill regarding the color of  OHV safety flags on specific dunes in the State. Currently, Utah law says it needs to be red or orange, and as you know, very few, including myself, fly a red or orange flag. We were successful in getting the red or orange requirement removed from the law as of May 6. Now any flag that is at least 6×12 and at least 8′ above the ground (or 18″ above helmet) are compliant, so American and club flags are ok to fly. It should be noted that on parts of Little Sahara, a Federal law still requires red or orange flags, so this does not change that requirement.