Summary of the statewide BLM Proposal: 

The Colorado Bureau of Land  Management is seeking input on a Proposal to amend all existing Resource Management Plans in the State to protect wildlife habitat and winter range. While the Proposal appears to address Oil and Gas most directly, public meetings have allowed the scope of the Proposal to be expanded to address almost anything thought to be impacting wildlife populations. Even with just gas and oil development being targeted, amending standards like route densities for areas could have a significant impact on recreational access to many areas. Our concerns expand if the Proposal targets more uses. We are asking for your comments to make sure motorized opportunities are not lost. 

Our concerns for your comments (please rewrite to ensure they are not consolidated)

1. BLM has been mandated to minimize impacts of motorized recreation on wildlife since the issuance of Executive Order 11644 issued by President Richard Nixon in 1972.  Over the subsequent 50 plus years, no other activity on federal lands has received this level of scrutiny.  As a result of the previous management of motorized recreation, the objectives in the Proposal have already been addressed in Resource Management Plans across the state.  CPW, US Fish and Wildlife Service have been very active in the development of these plans and these decisions should not be reopened but rather protected.

2. In addition to the mandated mitigation of wildlife impacts since 1972, the motorized community has self taxed to support the CPW OHV grant program to ensure that management decisions can be enforce and resources protected on the ground. This program provides more than $6 million in annual grants across the State.  Every Field Office in the State has a dedicated maintenance crew for motorized trails, gets dedicated funding for signage and is supported by the Stay the Trail program which educates users about issues like why seasonal closures of routes are important. Stay the Trail has a demonstrated history of improving compliance with management decisions. The competitive portion of the program also provides direct funding to the BLM for law enforcement and other management needs.

3.  Basic questions and terms in the Proposal are not defined or addressed. Examples of this would include: What species are being addressed in the Proposal? What species are not being addressed in the Proposal?  This basic information is important as many challenges to species population levels are not related to habitat constraints and to minimizing unintended consequences to other uses like recreation.  

4.  Throughout the Proposal terms like “important habitat”  or “high priority” habitat are used to outline the scope of the effort but these terms are never defined or outlined. Examples of this include: Important habitat as defined by who?  What factors were used to identify the characteristics of that area to make the habitat important? How were areas found to have these characteristics and other areas not have these characteristics?  How was importance of habitat balanced or addressed across the multiple species? Without this analysis, the risk of unintended consequences from the Proposal expands greatly.

5.  Is BLM even the right Organization to address a desire for larger wildlife populations?  General wildlife management is the jurisdiction of Colorado Parks and Wildlife.  Without CPW restricting hunting license sales, which directly impact wildlife populations, addressing habitat issues that only indirectly impact species, will only increase hunter success for the species.

6. The Proposal identifies compliance with the 30x30 Objective for public lands outlined in President Biden’s Executive Order 14008.  Based on our calculations, Colorado has achieved 30x30 goals for a long time. There have been large Congressional designations including Wilderness, National Conservation Areas and National Parks. How is the 30x30 goal relevant to the Proposal as it has been achieved already?

7. Executive Order 14008 clearly identifies improving recreational opportunities five times but only arguably addresses wildlife habitat.  How will the EO priorities be addressed in the Proposal?  How will designations that protect and improve recreational opportunities in existing RMP be protected and preserved in the new analysis being undertaken, especially when these designations were made to protect wildlife on the landscape?

8.  The economic impact of these changes must be addressed with high levels of detail given the reliance of huge portions of the state on non-consumptive recreational activity.

9.  Recreational impacts and restrictions must be addressed based on the 2021 CPW “Trails and Wildlife Guide” as BLM signed this document along with the US Forest Service and almost a dozen other agencies.

More information on the US Fish and Wildlife Service efforts

EplanningUi (blm.gov)

Deadline for comments

September 2, 2022