Comments on CPW Non-Motorized Recreational Trail Grant Application Process
State Trails Committee
State Trails Program
13787 South Hwy 85 N.
Littleton, CO 80125
Please accept the following comments on the current non-motorized trail grant program. We appreciate the opportunity for public review and comment on trails grant proposals submitted to the State Trails Committee, and our Habitat Watch Volunteers will be providing their comments on project –specific proposals during this public comment period. The following comments are directed more to the overall trails grant process and reflect our concerns as sportsmen who hunt and fish on our public lands.
I am the Chairman of the Colorado Chapter of Backcountry Hunters & Anglers (BHA), and represent over 1,000 members from all parts of the State. Our membership constitutes a group of sportsmen and -women who are united by a passion to protect and conserve the public forests, mountains, prairies, streams and lakes that support our hunting and angling traditions. We are traditional-values Colorado hunters and anglers who cherish the peace, solitude and challenge of the quiet-use backcountry experience.
CO BHA members share a deep concern that traditional backcountry values — solitude, silence, personal challenge, physical fitness, adventure — are being lost to habitat destruction from industrial development, illegal motorized use/abuse, and overuse of public lands. CO BHA works to slow these destructive trends in order to protect our outdoor heritage and to assure that future generations of hunters and anglers can enjoy the same genuine, backcountry opportunities we know today.
We believe in managing fish, wildlife and their habitats as a public trust and a priceless resource. We believe in keeping undeveloped public lands truly wild. Colorado BHA uses education, advocacy, cooperation and hard work to promote conservation of public lands fish and wildlife habitat, science-based stewardship of fish and wildlife, and fair and equitable access for all. We strive to uphold and exemplify the traditional American outdoor values of quiet use, muscle-powered access, and ethical, fair-chase sportsmanship.
Colorado BHA is committed to the long-term conservation of the still-wild and largely unspoiled public lands backcountry upon which Colorado’s world-class game and fish resources depend and upon which the future of traditional-values hunting and angling rely. Through tireless volunteerism, we strive to assure the following:
- That future generations of Americans will have the same opportunities to enjoy and protect the wild public lands and waters that we and previous generations have embraced as a national birthright.
- That our public lands backcountry will continue to comprise healthy, ecologically complete ecosystems with balanced populations of predators and prey.
Construction and Maintenance Grants
Colorado BHA is very interested in the grant applications that are submitted to the State trails committee. Our Chapter has a group of Habitat Watch Volunteers that have local boots on the ground knowledge of the public lands and wildlife near the places they live. These volunteers often participate in travel management planning processes on our local forest and BLM lands to provide input to the agencies on our values as sportsmen. However, when reviewing the grant applications the information is not always clear and sometimes seemingly misleading.
When reviewing the applications submitted to the trails committee, we assume that the construction and maintenance proposals are based upon approved travel management plans which have been fully analyzed by the federal agencies under NEPA, and that we the public and Colorado Parks and Wildlife (CPW) Area wildlife biologists and DWM’s have had the opportunity to participate in the process. However, unless we were involved in the planning process, we may not have knowledge or access to those planning documents. Exhibit A does include a checklist of mandatory items that does shed some light on this, but we feel it could be improved.
Many of the proposals appear to come from user groups and proponents, with limited involvement from the agency. The attached form with agency approval is helpful but they are not clear as to whether the project has received comprehensive NEPA analysis or if the proposal is conceptual in nature. Our primary concern is that the project should demonstrate that it has been planned and implemented according to biological principals to avoid or reduce habitat fragmentation, retain large blocks of core habitat, protect migration corridors and key concentration areas, and provide habitat connectivity on the landscape. The application should include a clear reference and/or a link to the approved NEPA document and travel management plan.
Exhibit A does at least include a mandatory item for Construction/Maintenance Grants that the CPW District Wildlife Manager has been contacted and informed of the project. However, this item does not demonstrate that the DWM was contacted or informed of the project prior to construction or maintenance. As a result, we would like to see a similar form or checklist from the local CPW Area Wildlife Manager included with each application which demonstrates that the Area wildlife biologist and local DWM were involved in the planning process early and meaningfully. The form should include a summary of the wildlife manager’s recommendations for avoiding and/or mitigating adverse impacts to wildlife habitat and big game populations.
We often see mitigation measures included in Construction and Maintenance applications which are designed to avoid impacts to big game on their winter range (seasonal trail closures) but no assurance they are effective. In our experience, user compliance with seasonal closures is often impractical or ineffective within the project area. Non-motorized trails are usually accessed from trailheads on county roads where the land management agency has no jurisdiction. Implementation of the travel management plans is not being conducted in a complete and balanced way. New trails are constructed and maintained with State grant funding, but the agencies do not have funding to decommission unwanted routes or install locking gates to control use. The agencies also lack sufficient law enforcement personnel to ensure compliance by trail users during the closure period.
The State trails grant committee needs to ensure that implementation of travel management plans on public lands is conducted in a complete and balanced way, and funding is included that will be directed towards habitat protection, mitigation, and enforcement. We believe that each project proposal should clearly demonstrate that funds requested for construction and maintenance are equitably matched with funds to simultaneously implement decommissioning and the installation of physical structures to meet wildlife objectives, and provide sufficient law enforcement to ensure user compliance.
Most of all, we want to ensure that CPW fulfills its mission to “perpetuate the wildlife resources of the State”. We do not believe that CPW is or should be obligated to fund projects that run counter to its wildlife mission.
Backcountry Hunters & Anglers recognize there is a growing demand for mountain bike trail systems on public lands. We also firmly believe that development of these trail systems should only occur when they are compatible with biological principals that will provide sufficient habitat to sustain viable populations of wildlife. There is a large and growing body of research that clearly demonstrates that wildlife habitat effectiveness and big game can be adversely affected by trail development and mountain bike use (refer to : Audrey R. Taylor and Richard L. Knight 2003. WILDLIFE RESPONSES TO RECREATION AND ASSOCIATED VISITOR PERCEPTIONS. Ecological Applications 13:951–963. http://dx.doi.org/10.1890/1051-0761(2003)13[951:WRTRAA]2.0.CO;2 Liddle, Michael. Recreation ecology: the ecological impact of outdoor recreation and ecotourism. Chapman & Hall Ltd, 1997. -- Naylor, Leslie M., Michael J. Wisdom, and Robert G. Anthony. "Behavioral responses of North American elk to recreational activity." The Journal of Wildlife Management 73.3 (2009): 328-338. -- Wisdom, Michael J., et al. "Effects of off-road recreation on mule deer and elk." (2004)).
Based on our experiences as hunters and upon feedback we receive from CPW wildlife managers, those effects are also resulting in adverse impacts to our big game populations where extensive trail development and mountain bike use is occurring.
Management of our public lands is entrusted to the federal agencies, and under NEPA they are required to conduct an objective analysis of all resources and environmental impacts and to provide opportunity for public review and comment. The current Planning/Support Grant process is not analogous to the federal NEPA process, and we are extremely concerned that it is being removed from the agencies and handed over to the interests and goals of user groups.
Our review of these applications indicate that they are largely proponent and user-group based, with support from “stakeholders” who are primarily county and municipal bodies that stand to gain economically. The current planning grants result in trails master plans which lack early and meaningful input from local CPW biologists and DWM’s, or the opportunity for other interested parties such as BHA or other conservation groups to participate in their planning process. The results of these trails master plans are then being handed over to grant funded contractors to complete environmental documents for the agency to demonstrate as NEPA.
Not all of the planning proposals are based upon larger scale agency travel plans. Often they are tiered to land use plans which simply designate an area as suitable for mountain bike trails. This level of planning lacks any specific direction to retain large blocks of intact habitat, provide habitat connectivity, or prevent habitat fragmentation. Big game seasonal concentration areas are recognized in land use plans, and seasonal closures are recommended to mitigate impacts to big game. These are not site specific analyses of existing or potential trail systems.
The trails master plans consistently demonstrate a lack of landscape-level wildlife analysis and adequate consideration of long term effects to wildlife habitat capability and populations. Sensitive wildlife areas are not being avoided. Mitigations are suggested but not implemented by the grants. This suggests that the local wildlife managers within the CPW and federal agencies are not included in a meaningful way early in the planning process of designing the trail systems.
In fact, Exhibit A attached to each Planning/Support Grant application does not even require the applicant to demonstrate that the CPW District Wildlife Manager has been contacted and informed of the project. We strongly believe that this criterion should also be mandatory to clearly demonstrate that our wildlife managers have been included in the planning process. As I stated previously, we would like to see a form or checklist from the local CPW Area Wildlife Manager included with each application which demonstrates that the Area wildlife biologist and local DWM’s were involved early in the planning process, and that their review included site specific habitat and population management analysis of the proposal. The form should include a summary of the wildlife manager’s recommendations for avoiding and/or mitigating adverse impacts to wildlife habitat and big game populations.
Most of the recent non-motorized trails planning proposals include mitigation measures to offset impacts to big game winter range. Seasonal closures can be effective mitigation when successfully implemented. However, in some cases these actions cannot be successfully implemented and therefore the project should avoid the area entirely. We do not see any recognition of this by the user groups. We would like to see the trails committee include a requirement to monitor existing trails projects for the effectiveness of this mitigation. Are the seasonal closures working? To what degree are users complying with seasonal closures? Do they actually reduce or mitigate the anticipated impacts to big game populations?
We realize that balancing the needs of wildlife with the desires of mechanized (and other) outdoor recreationalists is a difficult task and we thank you for your public service and efforts.
David Lien Craig Grother
Chairman Regional Director, Central West Slope
Colorado Chapter Colorado Chapter
Backcountry Hunters & Anglers Backcountry Hunters & Anglers
Founded by a former U.S. Army field artillery officer, Mike Beagle, and formed around an Oregon campfire, in 2004, BHA is the sportsmen’s voice for our nation’s wild public lands, waters and wildlife. With over 17,000 members spread out across all 50 states and Canada—including chapters representing 35 states and Washington, D.C., and two international chapters, in Alberta and British Columbia—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 U.S. Marine Corps veteran) in 2005 (the first official BHA chapter), they’ve grown their boots-on-the-ground presence to over 1,100 dedicated hunters and anglers.
Backcountry Hunters & Anglers is the sportsmen’s voice for our wild public lands, waters and wildlife