CO BHA Public Comment – Jumbo Mountain Trail Management

Public Comment – Jumbo Mountain Trail Management

August 7, 2021

Thank you for this opportunity to provide comment on the Jumbo Mountain Trail plan.  I’m submitting written comments on behalf of the Colorado Chapter of Backcountry Hunters and Anglers who I represent as the Assistant West Slope Regional Director.  While this letter reflects the views of Colorado’s BHA Chapter, it’s also worth noting my family and I live, work and recreate in the North Fork Valley and the Jumbo Mountain area is recognized as being an integral part of Paonia’s and the greater North Fork Valley’s recreational and outdoor culture.

The main factors we would like the BLM to consider in their decision-making process include the following:

Historical Use:

Going back as recently as 10-15 years ago and well beyond, the Jumbo Mountain area was predominantly a healthy winter range for herds of elk and mule deer.  From fall through spring, these herds would be found in big numbers utilizing the browse and relatively undisturbed habitat that the Jumbo area provided.  While quality winter range is critical to the survivorship of the entire make-up of these herds it's especially so for the female population and their young of the year, that is the cows and calves in elk herds and the does and fawns in deer herds.  

Fast forward to today and you will find almost no elk in the Jumbo area and a fraction of the deer population.  Numbers in both species in the valley and surrounding high country are down.

The historical use of Jumbo as a place of high wildlife usage and low human impact has flipped and has become a very high usage area for recreation.

Deer and elk use winter range because they have to.  They have no other choice and their lives depend on it.  Humans can recreate in a host of places at their choosing and at their leisure.  Backcountry Hunters and Anglers would ask the BLM to recognize the historical use and importance of the Jumbo area as it pertains to wildlife and in developing this trail plan, which leads to the next factor to discuss: the trails themselves.

Trail Development:

Jumbo Mountain had a network of game trails and cattle trails that provided both humans and animals the means to navigate the area.  Several decades ago, some well-intentioned locals decided to improve a few of these trails to allow better access for hiking, running and more specifically, mountain biking.  These trails were pirated in, meaning there was no oversight, inspection or approval from the BLM.  Again, this wasn’t done out of spite or ill-intent and with a relatively low number of people who knew about and used the upgraded trail system, wildlife herds were generally unaffected.

Fast forwarding once again to present day and the simple “pirated trail network” has become a labyrinth of trails criss-crossing and switchbacking up every acre of Jumbo Mountain.  New trails have been illegally put in and the necessary habitat for wildlife has been seriously compromised.  The trail density is well beyond that suggested by Colorado Parks and Wildilfe’s Guide to Planning Trails with Wildlife in Mind (see Appendix A for trail density recommendations on elk and mule deer).  If the weather and trail conditions allow it, there will be mountain bikers, hikers and runners using these trails winter, spring, summer, and fall.  Some dogs are kept on leashes by their owners, many are off leash or worse yet, not with their owners at all and simply running loose in the area.  The over-development of trails and lack of oversight of trail development by the BLM has led to a public space where wildlife no longer has a place and humans have taken over the landscape.  It’s out of balance.

Economic Impact:

The Jumbo area is widely known as a place where locals and some nonresident hunters could experience a good hunt for deer and elk.  Mature bucks, which do a better job of breeding does, were relatively common in the area, a sign of a healthy herd.  Elk that utilized Jumbo were staying on public land, remaining accessible to public land hunters and staying off private land where they potentially damage orchards, eat livestock operators’ hay crops, damage/destroy fences, and are forced to cross more roads inevitably leading to vehicle collisions.

Hunting dollars have a massive ripple effect within the North Fork Valley, not to mention western Colorado and the state as a whole.  From groceries, to gas, to license purchases, to processing and taxidermy, to outfitting services, to restaurants and hotels, the list goes on and on.  This happens every fall from September to November and it’s significant.  Hunting license sales are the main source of funding for Colorado Parks and Wildlife which oversees ALL wildlife (terrestrial and aquatic) in Colorado as well as all the state parks.  Other user groups can’t even come close to touching the economic importance hunters provide to local communities as well as CPW’s ability to operate.

While having access to places where people can hike, bike, run and get their dogs out is very important to the well-being of all communities, those activities don’t provide jobs or hold the economic clout that hunting does.  If for no other reason than a dollars and cents standpoint, keeping this factor in mind should be at the forefront of the BLM’s decision-making process as they evaluate the Jumbo Mountain trails as well as the other areas they manage here in the North Fork Valley.


In summary, BHA would make the following recommendations to the BLM for their new trail management plan on Jumbo Mountain:

  • Shut down and reclaim all new trails within the last five years. This can be done through collaborative efforts between our Colorado Parks and Wildlife District Wildlife Manager and local mountain bikers.  We’ve been conducting loose meetings already and feel confident a balance can be found.  As a scientific, locally and state approved reference the CPW’s Guide to Planning Trails with Wildlife in Mind suggests trail densities of less than one linear mile of trail per square mile on average and avoidance of any new trails within CPW-mapped winter range (Jumbo Mountain is within CPW-mapped winter range).  It’s worth noting the BLM was part of the task force on creating this guide.
  • Implement seasonal closures on the Jumbo trail system. Again, referencing CPW’s recommendations in Appendix A on the Trail Planning Guide, trail closures on winter range should begin December 1st and run through April 30.  Understanding this area is already well established as a high-use area for recreation, trail closure dates could be discussed to accommodate all users as best possible but avoidance of wildlife disturbance should be the priority in these conversations.
  • All dogs must be kept on a leash.
  • Place a kiosk or information sign at the Apple Valley trail access so the general public can be educated and informed on these new regulations. There are many new residents in the North Fork Valley who simply don’t understand the ramifications of their actions on resident wildlife and having a well-placed and visible sign explaining trail use would be very beneficial.

We recognize that the Jumbo Mountain area means a lot to many people in our valley.  It’s a wonderful place to recreate, get outside and enjoy all that our public lands provide.  The fact that it’s adjacent to the town of Paonia makes it all that more meaningful and unique.  However, it’s important to remember our public lands aren’t there for just one or two demographics.  In an increasingly crowded and arid western Colorado, wildlife requires space.  When given space, those wildlife populations will thrive and bring additional benefit to BLM-managed ground and the communities that help steward them.

Adam Gall

Assistant Regional Director, Central Western Slope

Backcountry Hunters & Anglers

The Sportsman's Voice for Our Wild Public Lands, Waters and Wildlife


About Adam Gall

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