As members of Backcountry Hunters and Anglers, we are passionate about preserving the natural habitats of game and nongame species alike. It's time to take action to mitigate the impact of recreation trails on wildlife populations in southwest Colorado. COMMENTS DUE BY THURSDAY FEBRUARY 23. This is not the time to be complacent. It is a David vs Goliath era for wildlife conservation.

Many studies show how trail development/density/use can all have negative impacts on a variety of species. Public land managers have consistently turned a blind eye to illegal trail creation and eventually incorporate the illicit trails into management plans. Further, enforcement of seasonal closures meant to mitigate impacts to wildlife is almost non-existent and non-compliance is well documented. Now, a worst case scenario trail development plan, in part, initiated by illegal mountain bike trail construction has emerged on Jackson Mountain near Pagosa Springs. This project, if approved in its current iteration, will set precedent for recreationists to build trails wherever they like on public lands without consequence and to the detriment of our wildlife.

The Jackson Mountain “Area of Focus” and proposed trail system overlaps with important deer and elk migration corridors, and a significant portion is an important winter concentration area for elk. This is the wrong project in the wrong place. 

As members of Backcountry Hunters and Anglers, we have the power to create awareness and effect change. Let's join together in voicing our concerns to the Forest Service and promote sustainable trail development practices that prioritize the well-being of wildlife. We urge you to submit your comments to the Forest Service at the provided link. Below are some talking points to consider in drafting your comments. 

• Land managers cannot continue to reward illegal trail building with trail incorporation in their plans

• CPW's concerns early in the development of the illegal trails were largely ignored by the FS and alternative sites with less impacts to wildlife were not considered.

• Deer and Elk herds are in decline in the area, additional stressors will compound declining populations

• Existing measures like seasonal closures are ineffective without enforcement and enforcement is lacking due to funding issues within land management agencies.

• We can't trust a community that constructed trails without approval to follow rules regarding seasonal wildlife closures

• The planning of this trail system does not incorporate recommendations from CPW in “Colorado’s Guide to Planning Trails with Wildlife in Mind” 

• Trails on the Northern, Western, and Southern sides of Jackson Mountain will have the greatest wildlife impact, we don't want to see any of these trails developed

• Not all of the trails in the Jackson Mountain area that are proposed are currently on the ground as "non-system" trails. Increasing access to sensitive habitat on the N, W & S sides of Jackson Mountain will come with a possible increase in future illicit non-system trail construction

• Clearing of understory through mastication will increase visual and audible impacts from recreation. Trail development that coincides with forestry and fire mitigation projects within the same project area must allow for proper distribution of refuge habitat for animals to utilize when disturbed by recreation.

Please stand up for wildlife by advocating that the Jackson Mountain trails system either be scrapped entirely or highly modified to consider negative impacts to wildlife. Substantive comments need to be submitted by February 23, 2023 at the link below:

https://cara.fs2c.usda.gov/Public//CommentInput?Project=61809

TIPS FOR COMMENTING:

• Comments are not votes, they need to represent more than opinion. Cite sources, read the project scoping letter and get scientific.

• Keep a cool tone. Comments that are unprofessional don't hold value.

• Don't copy and paste this email - Comments like this are treated as a collective and are non-substantive

• Bring in your outside knowledge of the issue