CO BHA Comments On Vail Trail Proposals

Colorado BHA recently submitted the letter below to the Eagle/Holy Cross Ranger District of the White River National Forest.


Backcountry Hunters & Anglers (BHA) mission is to ensure North America’s outdoor heritage of hunting and fishing in a natural setting, through education and work on behalf of our wild public lands, waters and wildlife. We are writing regarding the White River National Forest request for comments on three proposed mountain bike trails in Vail area (see 1/24/22 Forest Service News Release).

As detailed in a 2018 Colorado BHA report (“Impacts of Off-Road Recreation on Public Lands Habitat”), “Wildlife habitat in Colorado is being significantly impacted by the proliferation of mechanized (i.e., mountain bike) and motorized (ATV/OHV) trails on public lands. Sportsmen and wildlife managers are finding that elk hunting opportunities, in particular, are being compromised by trail development in many parts of the state.”[1]

For example, in a single decade, half of Eagle County’s elk population vanished. From Vail Pass to Glenwood Canyon—since 2007’s count by CPW, who use helicopters to check herd sizes in the winter—the numbers were down 50 percent. CPW previously issued about 2,000 hunting tags for the area. During 2018, 200 were issued. “It’s not like the elk are moving somewhere else, they are just dying off,” former Colorado Parks and Wildlife (CPW) supervisor (now serving in the state legislature) Perry Will said.[2]

Area 8 CPW staff had to rewrite their D-8 Mule Deer Herd Management Plan to accommodate an increasingly smaller herd and a lower carrying capacity. As of 2022, the local elk herd has experienced an approximately 60% decline over the last 15 years, despite drastic management changes by CPW. 


As a result, Colorado BHA is concerned about the growing cumulative impact of adding more mountain bike (and other) trails in this area considering the already struggling elk and mule deer populations/herds. Before addressing additional concerns (below), we would ask that the Forest Service (FS) consult—prior to considering these and any other new trails in the area—with both FS and CPW wildlife biologists to ascertain the potential impact of the three proposed trails on both mule deer and elk habitat in combination with the cumulative impact of trails already in existence along with any illegal, user-created trails. Our additional trail development concerns are addressed below:

  • Continued habitat fragmentation, and direct loss of habitat. Recreation has a radiating effect and will create a larger scale indirect loss of habitat.
  • As you know, although the forest service provides opportunities for outdoor recreation, it must be done in conjunction with ensuring wildlife habitat is not immoderately impacted.
  • Enforcement of seasonal closures is significantly lacking. Despite various efforts by volunteers and FS staff, unlawful use continues and results in net loss of habitat and the continued declines in wildlife populations.
  • The areas in question for new trail development still support wildlife, albeit in dwindling numbers. Despite the current disturbance level, this does not mean that certain wildlife species will continue to tolerate additional disturbance. Additional disturbance may result in complete abandonment of these areas.
  • Game Management Units (GMUs) 36 and 45 continue to experience declines in mule deer and elk populations. These species serve as indicators of imbalances in the entire local ecosystem. Despite dramatic reductions in hunting licenses, these herds have not shown signs of recovering.
  • Mill Creek and the Gold Peak area have seen significant mule deer displacement and disruption due to ski area expansions along with continued impacts and disturbance in the form of “green field trail development,” which could result in total loss of suitable habitat for mule deer in this area.
  • The area of lower Red Sandstone Creek provide movement corridors that connect lower elevations to higher elevations for elk and mule deer. Continued fragmentation and dispersed impacts on these corridors can disrupt these historical movements and access to critical habitat.

Before closing I want to thank you for your public service. As a former Air Force officer and current civilian federal agency employee, I appreciate the long hours and oftentimes difficult (if not thankless) multiple-use balancing act you and all of our public land agency professionals must manage year in and year out.

Please take our comments into consideration, include them in the public record regarding these trail development proposals, and don’t hesitate to contact us if you have any questions.


David Lien, Co-Chair

Colorado BHA Chapter

[email protected]

Additional/Related Information:

  • “More trails a slippery slope to less hunting.” Grand Junction (Colo.) Daily Sentinel: 12/9/21.
  • “Trails vs. Elk: ‘They’re Just Dying Off.’” Backcountry Hunters & Anglers: 12/3/21.
  • “Colorado BHA Report: Impacts of Off-Road Recreation on Public Lands Habitat.” Backcountry Hunters & Anglers: 5/21/18.
  • Sylvia Kantor. “Seeking Ground Less Traveled: Elk Responses to Recreation.” Science Findings #219 (U.S. Department of Agriculture-Forest Service Pacific Northwest Research Station): September 2019.
  • Colorado Parks and Wildlife (CPW). “Emblems of the West: Colorado Parks and Wildlife researchers have set out to evaluate how human recreation may be influencing Colorado’s elk populations.” Colorado Outdoors: 3/22/21.
  • A set of related studies compiled by Keep Routt Wild.
  • Colorado Parks and Wildlife. “Colorado’s 2021 Guide for Planning Trails with Wildlife in Mind.” Appendix A includes standard protocols for how and where the trails are developed (i.e., Avoid, Minimize, Mitigate).
  • “Opportunities to Improve Sensitive Habitat and Movement Route Connectivity for Colorado’s Big Game Species.” Colorado Department of Natural Resources: 9/7/21.
  • Colorado Parks and Wildlife (CPW). “2020 Status Report: Big Game Winter Range and Migration Corridors.” CPW: May 2020.
  • Jon Holst, Colorado Field Representative for the Theodore Roosevelt Conservation Partnership. “Proposed management plan prioritizes wildlife.” Grand Junction (Colo.) Daily Sentinel: 11/7/21.
  • Jeremy Dertien, Courtney Larson and Sarah Reed. “Don’t hike so close to me: How the presence of humans can disturb wildlife up to half a mile away.” The Conversation: 7/14/21.
  • Christine Peterson. “Resort Town Blues.” Backcountry Journal: Winter 2021, p. 44.
  • Ryan Stuart. “Study: Mountain Bikes Disturb Wildlife More Than Previously Thought.” Men’s Journal: December 2020.
  • Jim Mimiaga. “Local elk herds decline; Colorado Parks and Wildlife seeks solution.” The Journal: 2/5/20.
  • Scott Condon. “Elk herd population plummets in Aspen, Vail areas as human use grows.” The Aspen Times: 2/1/20.
  • Christine Peterson. “Hiking trails are a path to destruction for Colorado elk: Recreationalists in Vail are having a devastating impact on the local herd.” High Country News: 8/27/19.
  • Christine Peterson. “Americans' love of hiking has driven elk to the brink, scientists say.” The Guardian: 8/25/19.
  • Patrick Durkin. “Silent Fight: ‘Non-Consumptive Users’ Disturb Wildlife.” American Hunter: July 2019.
  • Judith Kohler. “Elk vs. trails: Proposal in Steamboat Springs highlights conflicts over public lands (Mountain bikers want to ride in Routt National Forest, but others are concerned about the impacts on wildlife).” The Denver Post: 2/24/19.
  • Jonathan Romeo. “Where have all the elk gone? In Southwest Colorado, herds show distressing signs.” The Durango Herald: 11/15/18.
  • Matt Kroschel. “‘They’re Just Dying Off’: Elk Herds Disappearing In Eagle Valley.” CBS4-Denver: 6/22/18.
  • Pam Boyd. “Where has all the wildlife gone: CPW officials cite 50 percent drop in Eagle Valley’s elk population.” Vail Daily: 6/16/18.
  • Jonathan Romeo. “Illegal trail building a vexing problem for public land managers: Mountain bike paths built in recent years.” The Durango Herald: 3/20/18.
  • Editorial. “Do we truly value wildlife? Then it’s time to acknowledge that it’s up to everyone to help.” Vail Daily: 2/27/18.

Founded by Mike Beagle, a former U.S. Army field artillery officer, and formed around an Oregon campfire, in 2004, Backcountry Hunters & Anglers is the voice for our nation’s wild public lands, waters and wildlife. With over 40,000 members spread out across all 50 states and 13 Canadian provinces and territories—including chapters in 48 states, two Canadian provinces and one territory, and Washington, D.C.—BHA brings an authentic, informed, boots-on-the-ground voice to the conservation of public lands. Since the Colorado BHA chapter was founded by David Petersen (a former U.S. Marine Corps helicopter pilot) in 2005 (the first official BHA chapter), they’ve grown their boots-on-the-ground presence to some 2,000 dedicated hunters and anglers.




[1] “Colorado BHA Report: Impacts of Off-Road Recreation on Public Lands Habitat.” Backcountry Hunters & Anglers: 5/21/18; George Wuerthner. “Impacts of Mountain Biking.” The Wildlife News: 6/18/19.

[2] Matt Kroschel. “‘They’re Just Dying Off’: Elk Herds Disappearing In Eagle Valley.” CBS4-Denver: 6/22/18.

About David Lien

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