Many of our treasured public lands in the state of Utah are going a variety of management planning revisions at this time or will be soon within the coming year. Current, active plans include the Bears Ears National Monument Resource Management Plan and the San Rafael Swell Travel Management Plan. For an overview of current and upcoming active plans, check out this article that provides an overview of those that are slated within the next several months.

The American people collectively own all public lands. They are one of the most valuable endowments of our citizenship, wherein every American may enjoy the rich beauty and vast array of natural and cultural resources that our public lands embody. Through the direction of the US Congress, various federal and state agencies like the Bureau of Land Management (BLM) and US Forest Service are designated to manage our public lands for the benefit of the American people. Agencies like the BLM and Forest Service do not own our public lands, they are merely responsible to manage it. Thus, as citizens, it is our right and responsibility to help direct each agency in public land management by participating in the planning process. Anyone who enjoys recreation or use of public lands for activities like off-roading, camping, horseback riding, hiking, mining, etc., must provide their input during the planning process to ensure that access to public lands for such purposes is prioritized and protected as management decisions are made.

In order for us to be effective as we participate in public land management planning, it is important to understand the goals and purpose of different types of plans. For example, right now we have the opportunity to provide public comment on a Resource Management Plan (for Bears Ears National Monument), and we’ll soon have the same opportunity to comment on a Travel Management Plan (for San Rafael Swell). What is the difference between a Resource Management Plan (RMP) versus a Travel Management Plan (TMP). RMPs and TMPs serve different but complementary purposes.

A Resource Management Plan is a comprehensive document that outlines the long-term management goals and strategies for a specific area of public land, such as a national forest, park, or wildlife refuge. RMPs typically address a wide range of natural and cultural resources, including wildlife habitats, water quality, vegetation, archaeological sites, scenic values, and recreational opportunities. These plans are often developed through a collaborative process involving stakeholders, agencies, and the public to ensure that multiple interests and perspectives are considered. RMPs provide guidance for land managers in making decisions about resource use, conservation, development, and restoration within the designated area. RMPs are intended to function like a 30,000-foot overview; they solely address management structure at a programmatic level, creating guidelines and guardrails for future site-specific and trail-specific plans. Per directives from Congress (36 CFR 212), RMPs do not make site-specific decisions regarding travel management because travel management decisions are made at the project level.

A Travel Management Plan focuses specifically on the management of motorized and non-motorized travel within a given area of public land. TMPs are developed to address issues related to off-road vehicle use, hiking, biking, horseback riding, and other forms of recreational travel. These plans aim to balance the public’s interests for recreational access with the need to protect natural and cultural resources, minimize conflicts among user groups, and ensure public safety. TMPs often involve the designation of specific routes, trails, and areas for different types of travel, as well as the implementation of regulations and enforcement measures to manage recreational use responsibly.

While RMPs focus on the broader management of natural and cultural resources, TMPs specifically address the management of recreational travel activities within a designated area of public land. Both types of plans are important tools for protecting public access to public lands, while ensuring the sustainable and responsible management of our treasured public lands for current and future generations. While it is of critical importance for outdoor recreation enthusiasts to participate in the planning process, it is equally important that we understand the goals and purposes of each plan to ensure that our public comments are effective, that the BLM, Forest Service, or other management agency actually uses our comments to shape the final decision for each plan. Increasingly, it is also critical that we hold managing agencies accountable to ensure that site-specific and trail-specific decisions are addressed solely within TMPs, and not implemented within RMPs.

Over the last several years, a disturbing trend in public land management planning is that public access and recreational uses take a backseat in priority in the planning process; an extreme environmentalist agenda is elevated in many public land management decisions. One example of this is the recent TMP that was implemented for the Labyrinth Rim & Gemini Bridges area near Moab. This is just one example, there are many more. Thus, our mission at UPLA is to inform and equip you to join in the effort to preserve public access to public lands for all forms of outdoor recreation. We offer resources and support to make it easy for you to participate in public land management planning, and to stay up-to-date on current plans that are open for public comment. We invite you to join us in the effort to protect public access to our nation’s beautiful public lands!

Rose Winn
Utah Public Lands Alliance
Natural Resource Consultant
Rose@UtahPLA.com

This page is dedicated to providing updated information on the Trail Canyon Travel Management Plan, E Planning Project Number DOI-BLM-UT-P020-2021-0002-EA. We will post new resources as they become available, with the most recent posts appearing at the top of this page after the static resource links at the top of the page.

Preliminary Alternative Maps were released in January 2021 with the results of the scoping report. In that scoping report, there were only 19 comments submitted.

The next phase will be the release of the Draft EA, expected this summer. If Alternative B were selected, as it was in Moab, very important routes including the Barracks Trail, Poverty Wash, and Hell Dive Canyon to Lambs Point will be closed. We need a massive effort to get people out and report their trails using www.TrailSaver.com Don’t wait, there’s a lot of trails that will need protecting.

If you have information that you would like added, please email us at landuse@utahpla.com

UPLA Articles

UPLA Article On Writing Substantive Comments 03/10/2024

UPLA Article with Links to All Utah Travel Management Planning Information

BLM Resources
Interactive Map from Scoping Report with Prelimary Alternatives

Trail Canyon Scoping Report 2021

Trail Canyon Scoping Route Reports 2021

So What Do We Need To Do Now?

1. Select an Area that has routes that are marked on the map as targeted for closure. Write down the route numbers.
2. Go to the BLM Route Report, refer to the link above. You can use the Search Bar on the webpage to find the Route Report for your trail, generally it will be about 4 pages long. Print it out, and try to understand what their resource concerns are. How do you determine what things mean in the Route Report? Google should be able to give you answers to abbreviations in the report. For example, I googled “What is PFYC Class 5?” and “What are abbreviation T E S T in BLM route reports for negative impacts” and it gave me all the answers.
3. Schedule time to go out and run the trail. Take your route report. Look for areas or conditions mentioned in the Route Report. Take photos along the route, especially noting any possible resource impacts they may have cited and think about alternatives when you’re on the trail.
4. When you get home, use TrailSaver to draft your substantive comments on the route. Be as specific as you can. 2 or 3 paragraphs on a route is an ideal length, include photos and gpx tracks. Videos are not recommended because of the large file size. If Archeological or Paleontology is listed, you won’t get a specific answer as to where that concern is located, but you can ask questions about possible mitigations around the concern such as rerouting the trail, informational signing, barriers to narrow trail to prevent stopping, etc. It is ok to mention how long you’ve been using the trail, with whom, etc, but this should be like the dessert to your meal, not the main course.
5. TrailSaver will email you a formatted draft of your report. You can edit, add to it or change it. When the BLM comment period opens, TrailSaver will send you another email with your report and more suggestions, along with instructions on how to submit reports to BLM.

Summary When you look at the comments required for one route, it seems like a lot, but when put in the scope of things, it might take you 20-30 minutes to write a good comment. Compare that to the fun you had running the trail, the people you enjoyed the company of on the trail, the overnight camping you did, and being able to enjoy this trail for generations to come and I hope you’ll agree it’s a good investment of your time. Please do your research and get out there and help save our trails!

We Need Your Support to Make This Come Together, please help!

www.TrailSaver.com

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The effort to remove access for Off Highway Vehicle Use is not just a movement, it is an all out assault plan that is well orchestrated between Extreme Environmental Groups and Top Management at the BLM and Secretary of the Interior.

To win a war, you must fight on several fronts simultaneously with different strategies and resources. Here’s a brief recap of what’s being done in Utah.

BlueRibbon Coalition serves as our early alert system to keep us abreast of the latest in developments. Many times actions taken in other states are precursors to what we will see next in Utah. BlueRibbon will fight for us in the courts, a very recent example of that is the Federal lawsuits to reverse the Labyrinth Canyon Travel Management Plan. Everyone should be a member of BlueRibbon Coalition, and when submitting comments on land actions, submit them personally and through BlueRibbon by copying them at landuse@sharetrails.org

Utah Public Lands Alliance is focused on preserving access for ALL User groups in Utah and surrounding areas. UPLA hired our first employee recently, Rose Winn, as our Natural Resource Consultant to help us craft both professional comments and provide training for our members. UPLA has been working very closely with BlueRibbon Coalition to develop a comprehensive strategy to take preemptive action against closure efforts. We are focusing on using the same rules that SUWA has employed for years to achieve their success to our favor. To score points in a game, you must have a strong offense strategy, we can’t just play defense..

UPLA recognizes that we have many great employees at BLM and Forest Service that we’ve been working with for years to improve, protect, and preserve our public lands, and we want to enhance and grow those relationships. One of our immediate focuses is to educate our members and subscribers on how to be more effective in commenting, which will influence more favorable decisions initially by Land Managers, and provide a basis for legal action when it’s needed. If you live or recreate in Utah, you should join and support Utah Public Lands Alliance.

Your local Clubs and other User Groups-It’s important that you join and support your local clubs and organizations. They are the glue that holds the fabric of the OHV and related user groups together. Many OHV members are also users of public lands in other activities such as hunting, fighting, equestrian, mountain biking and many others. Share your concerns with these groups as well about overreaches by the Federal Government, go to their meetings to explain yourself. If you need help preparing, reach out to UPLA or BlueRibbon for assistance.

State of Utah-Our State is fighting back hard against overreaches by the Federal Government with several factions of government:

Utah Public Lands Policy Coordinating Office (PLPCO) is the agency that is leading the administrative fight in keeping access to our public lands. They have been fighting for our RS2477 roads for years, but have also now turned their attention to include B and D Class Roads in the fight. PLPCO was also the first to produce intelligible maps for the San Rafael Swell Travel Management Plan.

Legislative-We were fortunate to have both Utah Senator David Hinkins and Speaker of the House Mike Schultz visit with us at the Big Ride on evening. The focus of the 2024 legislative session was on taking back control of our state from the Federal Government. Of particular note were 2 bills (H.B. 471 and S.B. 57 passed and signed by the Governor that will test the limits of the 10^th Amendment in the powers granted by the US Constitution to the Federal Government, with the remaining rights being the jurisdiction of the State.

County Governments-County governments are very important in our fight, and counties with public lands, especially with OHV access have gotten very involved in the fight. Reach out to your local County Commissioners and let them know why public access is so important.

Judicial-The State of Utah currently has more lawsuits filed against the Federal Government than at any other time in our history, and this aggressiveness will accelerate as we move ahead. In addition, the state is seeking to build a coalition with other Western States to fight together against these overreaches. With the Supreme Court balance we now have, this is the best opportunity we’ve ever had to reign in the expanding bureaucracy of our Federal Government.

Together, We Can Win

But We Can’t Do It Without You!

This is not a single skirmish, we must get and stay engaged for the long haul. We have broad support from many organizations and government agencies, but we can’t really make a difference without your personal support and involvement.  Let’s all Join the Fight to Win and Don’t Give Up!

Rose Winn, UPLA’s Natural Resource Consultant, BLM Western Solar Plan (PEIS Comment)

Please get yours sent in before April 18!

There is a shift happening on public lands with the core driver centered in renewable energy: solar and wind power. The climate change agenda is rapidly impacting the priorities that public land managers place on “multiple-use management” of our public lands.

There has been a significant increase of solar farms on public land in recent years. The BLM Western Solar Plan created in 2012 identifies public lands eligible for fast-track solar farm development in multiple states, including: Utah, Colorado, Arizona, Montana, New Mexico, California, Washington, Oregon, and others. The BLM is currently updating the Western Solar Plan in order to expand areas of public land suitable for solar energy development to meet a net carbon electricity goal by 2035. Public comments are now being accepted on the Solar Programmatic Environmental Impact Statement. We need OHV enthusiasts to submit public comments to tell BLM to exclude your favorite OHV riding areas from the plan. With this current plan there is a variance process that potential solar projects have to go through in order to be approved. These renewable energy developments often conflict with recreation use, which should be a core variance within the approval process.

On the positive side, all of the five Alternatives proposed for the Western Solar Plan exclude Special Recreation Management Areas (SRMAs) from solar energy development; thus, these areas could be affected only indirectly by solar energy facilities located close to their boundaries. However, on the negative side, the range of indirect impact on the quality and viability of the OHV riding experience at SRMAs is vast, including:

• Change in the overall character of undeveloped BLM-administered lands to an industrialized, developed area that would displace people who are seeking more rural or primitive surroundings for recreation.
• Changes to the visual landscape, impacts on vegetation, development of roads, and displacement of wildlife species resulting in reduction in recreational opportunities could degrade the recreational experience near where solar energy development occurs.

Additionally, the potential for solar projects to close public access to designated OHV routes that are outside of SRMAs is a real and impending threat to the future of OHV recreation in many popular areas of BLM land throughout the West, including Utah. The proposed plan states:

“Many BLM field offices have completed planning activities to designate lands for OHV use. Under these plans, areas open to application for solar energy development may be available for OHV use, and solar energy development in these areas would displace this use. Applications for solar energy facilities may include areas containing designated open OHV routes, thereby eliminating public access along those routes.”

It is imperative for OHV enthusiasts to submit comments on the BLM Western Solar Plan to urge the BLM to exclude areas with designated OHV routes from the range of available land for construction of solar projects, and, to exclude construction of solar projects near the borders of SRMAs.

Public comments will be accepted through April 18. For more information on the BLM Western Solar Plan, and to submit a comment, go to: https://eplanning.blm.gov/eplanning-ui/project/2022371/510

Rose prepared some talking points for you to use when writing your own comments. These should be used as idea starters for you, please don’t just copy and paste them. Form letters or comments with same language are not effective.  It’s not necessary to incorporate all of these in your comments, pick the couple that are most important to you, however, we need lots of comments regarding the first talking point and request them to remove that language about solar energy plants replacing currently designated OHV routes.

If you have questions or would like to discuss how you will craft a comment for the Western Solar Plan, please reach out to UPLA Public Policy Consultant, Rose Winn: rose@utahpla.com.

Plan website: https://eplanning.blm.gov/eplanning-ui/project/2022371/570

Public comment deadline: April 18, 2024

Send your comments via email to: solar@blm.gov

• Utah Public Land Alliance’s Natural Resources Consultant, Rose Winn, is tracking comments for this Solar Plan. Please add Rose to the “CC” field of your email: rose@utahpla.com.

(Sample comment letter  below, but please make it your own, don’t try to copy and paste.)

Key Talking Points:

• Note that the potential for solar projects to close public access to designated OHV routes that are outside of SRMAs is a real threat to the future of OHV recreation in many popular areas of BLM land. The proposed plan states on page 5-159 of the 2023 Draft Solar PEIS Volume 1 (Section 5.14 Recreation, 5.14.1 Direct and Indirect Impacts, 5.14.1.1 Construction and Operations):
  • “Many BLM field offices have completed planning activities to designate lands for OHV use. Under these plans, areas open to application for solar energy development may be available for OHV use, and solar energy development in these areas would displace this use. Applications for solar energy facilities may include areas containing designated open OHV routes, thereby eliminating public access along those routes.”
•  Urge the BLM to cite the following as explicit exclusions within all 5 Alternatives:
• • Exclude designated OHV routes and open OHV riding areas from the range of available land for construction of solar projects
  • Exclude construction of solar projects near the borders of Special Recreation Management Areas
  • Exclude all designated outdoor recreation areas (including dispersed camping, designated camping, mining, along with all forms of outdoor recreation) from the range of available land for construction of solar projects.
• Thank the BLM for excluding land within Special Recreation Management Areas from solar energy development, and urge them to maintain this exclusion within the final draft regardless of which Alternative or combination of Alternatives is selected.
• Name all BLM OHV riding areas that you have, or would like to in the future, recreate at. Wherever possible, itemize the features that make that riding area unique and of high-value to the OHV rider experience. Note how a solar facility development within or nearby that riding area would negatively impact the rider experience and/or wildlife and wildlife habitat in the region.
• The negative impacts of solar facilities on wildlife is of importance to OHV enthusiasts given that a major element of why we enjoy OHV recreation is to get out in nature and view / observe wildlife in its native habitat. Solar facilities destroy habitat for all species that inhabit the footprint where the facility is constructed; they displace wildlife, leading to higher concentrations of species in surrounding areas as those species are forced to flee the solar facility area to survive. This will inflict harm on wildlife as there will be more competition for food and habitat for all species including mammals, birds, amphibians, reptiles, and insects.
• Solar facilities on OHV riding areas would also displace OHV riders. This will create a higher concentration of people riding in other OHV areas, which will create new negative impact on natural and cultural resources in other areas, thus jeopardizing the long-term viability of other OHV areas, and thereby inflicting harm directly on the OHV recreation community. For this reason, the BLM should exclude designated OHV routes, open OHV riding areas, Special Recreation Management Areas, and lands near the borders of Special Recreation Management Areas from the range of available land for construction of solar projects.
• OHV recreation accounts for a huge segment of the outdoor recreation economy. Outdoor recreation contributes over $1.1 trillion to the US economy. For this reason the BLM should exclude designated OHV routes, open OHV riding areas, Special Recreation Management Areas, lands near the borders of Special Recreation Management Areas, and all designated outdoor recreation areas from the range of available land for construction of solar projects.
  • There is some info that may be of interest to cite from this article on the value of the outdoor recreation economy
• You may suggest that solar facility development is not suitable for construction on America’s public lands, which are intended to be used, stewarded, and protected for the benefit of all Americans. Solar facilities destroy the recreational, resource, cultural, and ecological values of our public lands. Solar facilities are best suited for urban and developed areas – such as rooftops in cities and elevated coverings over parking lots. One of the issues that the BLM has noted in the Western Solar Plan is a desire to place solar facilities near existing power transmission lines – so public lands, which are inherently distant from transmission lines – are unsuitable. Constructing solar facilities in urban, developed areas is more efficient as transmission lines are already in near proximity.
• If you’d like to see a sample comment letter, Sample Template Comment Letter

Our friend Jim Brewer has produced the best interactive map available for planning your trip to the Swell and mapping locations that you want to be sure are protected.

This latest interactive map provides valuable insight into the SRS TMP alternatives.  It includes a couple of the more popular maps as optional basemaps (Dick Brass Trails, Emery County OHV) as well as PLSS, surface management, BLM wilderness, and a TMA boundary    Also, you can choose from several different typical basemaps on the upper right for better route connection clarity.

The base Route Inventory is in red, so when you turn on each of the alternatives (in green) the red that remains are the closed routes.  Zooming in enables route labels and popups for each route will show details.  I had to fix labeling on a couple of routes in the Dick Brass system since they had them mixed up a little.

We also have added airstrips and fixed the Search feature so you can locate the route on the map.

My personal recommendations to start off with your map are the following:

• Turn On These Layers- BLM Wilderness Layer (show as hashed green lines), TMA Boundary, Surface Management Layer (Shows state lands in blue), Route Inventory (shows all routes inventoried, will display in Red at first)
• Good Map Layers on Left- Terrain with Labels and Imagery Hybrid for aerial views

We will post a video here soon to show you how to navigate the map.

If you’d like to contact Jim Brewer about a GIS project, his website is Western Expanse Inventory & Cartography

The tragic loss of 317 miles of roads and 120 dispersed campsites in Moab should serve as a call to action for all of us, and if we don’t rally to make a difference, it is likely the losses that lie ahead may be even worse. We have always been more concerned with losses laid out in Alternative C, but Moab’s Decision was much closer to Alternative B. Future decisions will definitely address the recreation aspects of the routes, but becoming more important are the resource impacts of each trail. We need to shift our focus to comment on the routes you love by taking note of the Resource Impacts that BLM has determined for each route. I’ll provide a link where you can find the BLM Route Reports with this information below.

Once again this will be going out again and riding the trails and documenting your findings with substantive comments.  We are working on a consolidated reporting tool to help draft your comments,  but more on that later.

So What is a Substantive Comment? A substantive comment identifies an issue you have with the document, says why it’s a problem, and offers other factual and unbiased information for BLM (or Forest Service) to consider. Substantive comments must be answered by the BLM, nonsubstantive comments are ignored.

Here are some qualities of what makes a substantive comment:

• References document pages, chapters or sections and uses objective information.
• Uses facts to question the adequacy, accuracy, methodology, or assumptions of the analysis.
• Presents traditional or ecological knowledge.
• Proposes a reasonable new alternative or revision to the alternatives presented.
• Identifies a passage in the document that is unclear or wrong.

Here’s some tips for making a substantive comment:

• Include any knowledge, experience, or evidence as it relates to your observations and comments.
• Provide GPS readings or landmarks, if possible, when referring to specific locations
• Present new information
• Share issues relevant to the environmental analysis.
• Suggest alternatives to the proposed project and the reasons why they should be considered.
• Avoid comments like “I do (or don’t like this”
• Remember that identifical comments are treated as one comment, including form letters. If you use a form letter, paste your personal comments at the very beginning of the form letter to make them stand out. Changed comments in the body of a form letter are likely to be overlooked.

Here is a list of comments that are not deemed substantive and won’t be answered

• Stating that you want your comment recorded as “substantive.”
• Crafting an emotionally compelling story without facts
• Stating only that you agree or disagree with a policy, resource decision, analysis finding, or presented alternative.
• Asking vague or open-ended questions
• Commenting on unrelated projects.

Here’s a couple good examples of substantive comments (fictitious, for example only)

Route SS1024 (Route Report Page 60) is identified for closure in Alternative B.C. This is an important connector route as listed in the Report, and leads to many activities including camping. to enable a loop route, rather than only an in and out trail. In and Out trails are far less desirable for users and the extra traffic resulting on In and Out Roads causing more of the negative impacts identified in the Route Report.

Crosses Washes or within 100 meters of an intermittent stream are listed as Resource impacts, but travel in the desert almost always involves crossing multiple washes and intermittent streams, that is the natural drainage system of the desert. Why are these crossings more impactful than others? Please clarify the potential negative impacts associated with vehicles crossing dry washes or streams.

 There are 8 Special Status Species listed in the report, but we observed none of these on our most recent trip. What mitigations have you considered to minimize these concerns; would seasonal closures minimize the impact on the species? Additionally, what mitigations have you considered for the PFYC Class 5 area of the trail? Can it be rerouted around the area of concern? Attached is a GPX file of the route we took, along with selected photos.

I disagree with closing Route SS1024 because it is the only way I have to access my private land.

Question? So What Should I Do?

1. Select an Area that has routes that are marked on the map as targeted for closure in Alternative B. Write down the route numbers.
2. Go to the BLM Route Report, for the Swell you can find it here. Just use the Search Bar on the webpage to find the Route Report for your trail, generally they will be about 4 pages long. Print it out, and try to understand what their resource concerns are. How do you determine what things mean in the Route Report? Google should be able to give you answers to abbreviations in the report. For example, I googled “What is PFYC Class 5?” and “What are abbreviation T E S T in BLM route reports for negative impacts” and it gave me all the answers.
3. Schedule time to go out and run the trail. Take your route report. Look for areas or conditions mentioned in the Route Report. Take photos along the route, especially noting any possible resource impacts they may have cited and think about alternatives when you’re on the trail.
4. When you get home, write your comments on the route. Be as specific as you can. 2 or 3 paragraphs on a route is an ideal length, include photos and gpx tracks. Videos are not recommended because of the large file size. If Archeological or Paleontology is listed, you won’t get a specific answer as to where that concern is located, but you can ask questions about possible mitigations around the concern such as rerouting the trail, informational signing, barriers to narrow trail to prevent stopping, etc. It is ok to mention how long you’ve been using the trail, with whom, etc, but this should be like the dessert to your meal, maybe delightful to you, but shouldn’t be the main course.
5. Submit Your Comments if the comment period is open. We will give you more details on how to copy us on your comments, please stand by on this until we work out the details. If the comment period is not open, get them ready to submit right after your ride while it’s clear in your mind. Again, stay tuned for more information on this.

Summary When you look at the comments required for one route, it seems like a lot, but when put in the scope of things, it might take you 20-30 minutes to write a good comment. Compare that to the fun you had running the trail, the people you enjoyed the company of on the trail, the overnight camping you did, and being able to enjoy this trail for generations to come and I hope you’ll agree it’s a good investment of your time. Please do your research and get out there and help save our trails!