How Bad Is the BLM Moab Decision?

Blue Routes Open, Red Closed, All Other Colors Restricted

It’s very difficult to comprehend the extent of the adverse actions against OHV access to our public lands. This interactive ArcGIS map of the Labyrinth Rims Gemini Bridges is layered so you can compare the closed routes to lands with wilderness characteristics and bighorn sheep lambing habitat to see that’s where the vast majority of the closures are. There’s also a layer showing SUWA’s Red Rock Wilderness proposal which also includes the areas with the most closures.

This map is the courtesy of Patrick McKay with CO Offroad Trail Defenders Virtual Crew, who has done immense work in trying to protect our access.

Labyrinth Rims Decision (arcgis.com)

If you’re fed up, take action by donating to Utah Public Lands Alliance. Up to the first $50,000, every donation will be matched dollar for dollar and the entire amount given to BlueRibbon Coalition for supercharging our fight. That would big a war chest of $100,000 to get them started!

 



Donate Today to Stop the Losses


It is with a heavy heart that we bring you the distressing news from Moab today—a destination cherished by many for its rugged trails and breathtaking landscapes. A staggering 317 miles of roads, including iconic trails like Hey Joe Canyon, Ten Mile Wash, and Hell Roaring Canyon, are facing closure by the Bureau of Land Management (BLM-FOREVER). This alarming trend is not isolated to Moab; it’s spreading across various regions, threatening the very essence of not only off-highway vehicle (OHV) activities, but everyone that uses motorized vehicles to get to the areas they enjoy recreating, including equestrians, rock climbers, backpackers, and virtually everyone that wants to get into the backcountry by vehicles before setting off on to enjoy their next adventure.

The recent decisions related to the BLM Conservation and Landscape Health Rule, Bears Ears and Grand Staircase National Monuments expansion, Middle Gila in Arizona, Rock Springs Resource Management Plan in Wyoming, Nez Perce Clearwater National Forest in Idaho, and Table Mesa in Arizona have further fueled concerns. These decisions are adversely affecting not only the off-road community but also devastating snowmobiling and other OHV activities in places like the Manti LaSal National Forest.

In times like these, being merely mad is not enough. We must unite and fight back to stem the tide of these continuous losses. Understanding the urgency of the situation, the Utah Public Lands Alliance (UPLA) has taken a stand and selected the BlueRibbon Coalition to lead this crucial fight. BlueRibbon has been fighting for our access for over 30 years, and we now want to supercharge their ability to lead this fight.

Now, we’re reaching out to you, the backbone of the off-road community, not just for comments or letters, but for your financial support. We need funds to mount a legal battle against these closures, and we’re asking your organization to stand with us in this critical moment.

UPLA is spearheading a fundraising campaign to benefit BlueRibbon Coalition defense efforts. We are so committed to this effort to save our future, UPLA is matching the first $50,000 in donations dollar for dollar, meaning your donation’s value will be doubled. In addition, we are seeking other clubs, businesses, and organizations to join this effort to extend the match beyond the first $50,000

Together We Can Win, But We Can’t Do It Without You.

Your support is not just a donation; it’s an investment in the future of off-road adventures.

to save the trails we love, protect our rights to explore, and ensure that future generations can experience the thrill of off-road adventures.

Thank You!

Loren Campbell

president@utahpla.com



Help Us Save 199 Miles of Moab Trails

The BLM is expected to release their Moab Labyrinth Canyon Travel Management Plan by September 30, and we are extremely concerned their plan is going to mirror other recent Federal government actions. We’re working closely with BlueRibbon Coalition to help prepare for legal appeals, but We Can’t Do It Without You.

The most common reasons for closure are that a trail is a duplicate, not being used, or is actively being reclaimed. It’s vital to prepare a good legal strategy to know details about every trail, including Trail Conditions, GPX tracks, Photos, and Why the Trail is Important, and we must gather this information BEFORE the closure takes effect.

Thanks to Patrick McKay with Colorado Offroad Trail Defenders, we’ve identified 199 miles of that need a status update.

What we need your help with is Running These Trails. Download the free tracks from UtahPLA.com  (We have both GPX and KML versions), load them into your navigation system, and go run the trails. We need you to record your track on the trail and report the Trail Using the UPLA form. Photos tell the story of a thousand words, so if you can submit a few pics that will really help.

Time is limited, so we hope that everyone going to Moab in the next month will help us collect data. Don’t worry about duplicates either, the more reports on the same trail add to our story.

Thank You, and Please Share This Message With All Your Friends

Click Here to Access the Tracks from our CalTopo Site where you can download them in any format you need

Click on From to Open Reporting Form



NHTSA Proposed Rule on Automated Emergency Braking Systems

We have another threat to OHV recreation, this time by the National Highway Transportation Safety Board in proposed rules that would affect many aspects of vehicles we use off highway. Learn more from this SEMA link on why you should oppose this rule. https://www.sema.org/…/sema-requests-feedback-impact…

AND THEN

 

Click Here to Submit your own Comments Opposing This Rule by August 14

UPLA submitted the following comments in opposition of this additional rule which will threaten OHV vehicles. Please click on the link above to learn more and

As an OHV enthusiast, I have serious concerns and reservations about NHTSA’s proposed rule regarding automated emergency braking systems (AEBS) for off-highway vehicles (OHVs). While safety is undoubtedly crucial, I believe this proposed rule could have several negative implications for the OHV community:

-Overreliance on technology: Implementing AEBS in OHVs might lead to riders becoming overly dependent on this technology. Off-roading requires skill, situational awareness, and quick decision-making, and relying too heavily on automated systems could erode these essential skills, potentially leading to complacency and increased accidents.
-Off-road terrain complexity: AEBS systems are primarily designed for use on paved roads, where conditions are more predictable. Off-road terrains can be highly diverse and unpredictable, featuring obstacles, mud, rocks, and varying slopes. The proposed rule does not take into account the complexities of off-road environments, which may render the AEBS less effective or even cause false alarms, disrupting the driving experience.
-Maintenance and reliability: OHVs are often exposed to rough and demanding environments, which could affect the reliability and performance of complex AEBS systems. If these systems become prone to malfunctions or require constant maintenance, it could be a significant burden for OHV owners and potentially compromise their safety.
-Personal responsibility: Off-roading is inherently an activity that involves an element of risk, and OHV enthusiasts understand and accept this fact. While safety measures are essential, they should not overshadow the responsibility of individual riders to drive cautiously and make informed decisions while navigating challenging terrains.
-Cost burden on consumers: Implementing AEBS systems in OHVs may result in increased manufacturing costs, which will ultimately be passed down to consumers. This could make OHVs less accessible to enthusiasts who rely on more affordable options to enjoy their passion for off-roading.
-Impact on aftermarket modifications: Many OHV owners customize their vehicles with aftermarket parts and modifications to suit their specific needs and preferences. The introduction of mandated AEBS systems might limit the scope for such modifications and reduce the freedom and creativity that enthusiasts enjoy.
-Training and awareness: Instead of focusing solely on mandating AEBS, the NHTSA should consider investing in education, training, and awareness campaigns to promote safe off-roading practices. Providing resources to enhance driving skills and responsible OHV use can be more effective in improving overall safety.
In conclusion, while safety is of paramount importance, the NHTSA’s proposed rule for AEBS in off-highway vehicles appears to be ill-suited for the unique challenges and characteristics of off-road environments. Instead, a more balanced approach that combines improved education, training, and voluntary safety measures could better serve the OHV community without compromising the essence of off-roading.As an OHV enthusiast, I have serious concerns and reservations about NHTSA’s proposed rule regarding automated emergency braking systems (AEBS) for off-highway vehicles (OHVs). While safety is undoubtedly crucial, I believe this proposed rule could have several negative implications for the OHV community:



Final UPLA Comments Filed on BLM Conservation and Landscape Health Rule

We filed our final comments on the proposed Rule. Please get your final comments in by July 5.

UPLA Comments July 4 2023



How to Write Effective Comments

Tips for Submitting Effective Comments in Land Manager Actions
Overview
A comment can express simple support or dissent for a regulatory action. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.
These tips are meant to help the public submit comments that have an impact and help agency policy makers improve federal regulations.
Summary
  • Read and understand the regulatory document you are commenting on
  • Feel free to reach out to the agency with questions
  • Be concise but support your claims
  • Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
  • Address trade-offs and opposing views in your comment
  • There is no minimum or maximum length for an effective comment
  • The comment process is not a vote – one well supported comment is often more influential than a thousand form letters
  • You may submit many separate comments, they do not have to be posted all at once. As you think of something, post it.
Detailed Recommendations
Comment periods close at 11:59 eastern time on the date comments are due – begin work well before the deadline.
Attempt to fully understand each issue; if you have questions or do not understand a part of the regulatory document, you may ask for help from the agency contact listed in the document.
Note: Although the agency contact can answer your questions about the document’s meaning, official comments must be submitted through the comment form.
Clearly identify the issues within the regulatory action on which you are commenting. If you are commenting on a particular word, phrase or sentence, provide the page number, column, and paragraph citation from the federal register document.
If a rule raises many issues, do not feel obligated to comment on every one – select those issues that concern and affect you the most and/or you understand the best.
Agencies often ask specific questions or raise issues in rulemaking proposals on subjects where they are actively looking for more information. While the agency will still accept comments on any part of the proposed regulation, please keep these questions and issues in mind while formulating your comment.
Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
If you disagree with a proposed action, suggest an alternative (including not regulating at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
Consider including examples of how the proposed rule would impact you negatively or positively.
Comments on the economic effects of rules that include quantitative and qualitative data are especially helpful.
Include the pros and cons and trade-offs of your position and explain them. Your position could consider other points of view, and respond to them with facts and sound reasoning.
If you are uploading more than one attachment to the comment web form, it is recommend that you use the following file titles:
Attachment1_<insert title of document>
Attachment2_<insert title of document>
Attachment3_<insert title of document>
This standardized file naming convention will help agency reviewers distinguish your submitted attachments and aid in the comment review process.
Keep a copy of your comment in a separate file – this practice helps ensure that you will not lose your comment if you have a problem submitting it using the Regulations.gov web form.
Specific Requests
The BLM has specifically requested public comment on the following aspects of the conservation lease proposal in the Conservation and Landscape Health Rule.
• Is the term “conservation lease” the best term for this tool?
• What is the appropriate default duration for conservation leases?
• Should the rule constrain which lands are available for conservation leasing? For example, should conservation leases be issued only in areas identified as eligible for conservation leasing in an RMP or areas the BLM has identified (either in an RMP or otherwise) as priority areas for ecosystem restoration or wildlife habitat?
• Should the rule clarify what actions conservation leases may allow?
• Should the rule expressly authorize the use of conservation leases to generate carbon offset credits?
• Should conservation leases be limited to protecting or restoring specific resources, such as wildlife habitat, public water supply watersheds, or cultural resources?
Posted Comments
After submission, your comment will be processed by the agency and posted to Regulations.gov. At times, an agency may choose not to post a submitted comment. Reasons for not posting the comment can include:
  • The comment is part of a mass submission campaign or is a duplicate.
  • The comment is incomplete.
  • The comment is not related to the regulation.
  • The comment has been identified as spam.
  • The comment contains Personally Identifiable Information (PII) data.
  • The comment contains profanity or other inappropriate language.
  • The submitter requested the comment not be posted.
Form Letters
Organizations often encourage their members to submit form letters designed to address issues common to their membership. Organizations including industry associations, labor unions, and conservation groups sometimes use form letters to voice their opposition or support of a proposed rulemaking. Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.