CORE submitted these comments on behalf our members, sponsors and supporters:
Hello BLM Camping and Travel Management Team,
Introduction:
My name is Marcus Trusty. I am the founder/president of Colorado Offroad Enterprise (CORE), based in Buena Vista, CO. CORE is a motorized action group dedicated to keeping all motorized roads and trails open in Central Colorado. CORE currently helps maintain 15 adopted trails in the Central Colorado Region. During 2019, we completed nearly 2,000 volunteer hours through our organization. We have a volunteer agreement with the Royal George Field Office and have helped with the BLM areas in Chaffee County for five years.
I am a third-generation Chaffee County Native and own a local business that has been in operation for 15 years. I have spent a considerable amount of time on BLM-managed land in Chaffee County, participating in all types of recreation, including dispersed camping.
Camping in Central Colorado is a complex activity, one in which people engage for various reasons. In many cases, camping is considered and analyzed as recreation; however, many seasonal employees of the local summer economy live on public lands during the summer months. Public Land camping has become the go-to for cheap housing within proximity to businesses, municipalities, and recreation areas.
A. Introduction and Background:
The project introduction references "high-quality camping experiences." How does the BLM measure high quality concerning camping? For many, camping is the recreational experience sought by users. This experience could include quiet, seclusion, views, and no visual impacts of other campers. However, for many others, camping is the means to different recreational experiences. Many users are camping to have a base in the area to engage in many forms of recreation. In those instances, just having a campsite on public land is desirable and is not measured by the “quality” of that site. In other cases, users are short-term living in camps, which is how trash and human waste has accumulated in a short time.
Why is this project solely focused on a few areas within the Chaffee County Boundaries? Users do not recreate within arbitrary county boundaries, and it's well established that recreation is dynamic and not static. This project takes a more static look at camping within a few areas; however, without including a more regional approach, if the project decision restricts camping in these areas, the decision will merely push camping into other areas within Chaffee County or the Central Colorado region.
B. Purpose and Need:
The first paragraph is clear in articulating the BLM's obligations and standards for entering into this process. Overuse of a resource will include on-ground evidence and scientific facts supporting that overuse. The second paragraph of the Purpose and Need appears to try and support the first paragraph. However, there are several non-scientific statements made that rely on personal accounts without facts or research. The second paragraph refers to 'User Conflict.' Still, it does nothing to explain how this stated conflict is an Interpersonal Conflict, meaning there is a specific and defined on-ground conflict that can be mitigated through management, and presumably, this process. Without specifics, this process could also include Social Values Conflict. Social Values Conflict is not clearly defined and includes negative emotions directed at a user group. Without stating which 'User Conflict' the BLM is referring to, this process could be too heavily influenced by those who do not like camping and think all camping is damaging. That non-scientific bias would produce a plan that does not work as intended.
The last two sentences of the Purpose and Need are likely referring to the Envision Chaffee County Process, and the Chaffee County Recreation Survey results developed from that group. The results from that survey used the exact phrase eluding to decrease in visitor satisfaction related to the increase in dispersed camping. While all survey information derived through that process is important, the BLM should evaluate it in context with all information regarding the local population and visitor statistics. The Envision project had 2,543 complete responses to their non-scientific recreation survey. With a Chaffee County population of 18,507 as of the last census, the survey responses represent 13% of the local population. While it's important to evaluate the concerns of the 13% of people who filled out the survey, many of whom are residents, it's also essential to compare it to the 87% of county residents who did not find enough issues with the quality of their recreation experience to take time to register a response or complaint. To take it a step further, the Envision Process concluded that Four Million recreation users visit Chaffee County each year. Survey responses from 2,543 users, some of which recorded a negative user experience, compared to Four Million visitors are not statistically significant.
How is the BLM accounting for the "stress" associated with finding a campsite? The project's final decision could very likely restrict camping; how would a restriction in camping solve stress related to finding a campsite?
The Purpose and Need are also lacking reference to Short-Term Living. Short-Term Living is taking place on BLM via camping and, in many cases, is taking place in the areas focused on during this process. If this issue is not acknowledged or addressed, the outcome of this process will not be effective. People living on public lands all summer push those who visit Chaffee County for recreation to seek new places to camp. In many circumstances, these short-term campers do not have access to many of the existing campsites because they are occupied by people living in the area for the summer months. This is an unfortunate omission and should be addressed during the process.
C. Area Descriptions:
Shavano Area
This area has become one of the most attractive for short-term living due to the proximity of Salida. Many people are camping in this area to work and recreate in Salida and Southern Chaffee County. The lack of a travel management network for the routes should be the beginning of this process before addressing camping. Additionally, the routes in this area continue for many miles onto National Forest-managed land. If the BLM were to restrict camping in some fashion within the Shavano Area Boundaries, what would stop campers from driving .5 miles farther up the road and recreating these same campsites on The Forest? This real possibility could double the negative impacts by campers creating new sites in undisturbed areas.
The BLM should designate a route network in the Shavano Area and establish existing sites as dispersed camping sites. The camping impacts on the ground are already present, and people are camping here for several desirable reasons. The BLM should not close or restrict camping in this area because these same impacts and sites will pop up in another location.
Burmac/Methodist Area
This area is an example of short-term living in specific conflict with users looking to access the area trails. These specifics include finding places to park for day use, competing for areas to camp overnight, and the possibility of encountering illegal behavior. These issues are examples of Interpersonal Conflict. If the short-term living issues due to the proximity of Salida are not addressed, there will continue to be problems in this area.
Fourmile North
Fourmile North is suffering from three distinct issues, which have led to the current camping concerns.
First, the 2002 Fourmile Travel Management Decision closed numerous full-size vehicle routes to motorized use and converted several others to 50" trails. These actions restricted overnight use of several existing campsites along the closed routes. Since people generally don't camp off their ATV, the decision also rendered the campsites along the converted 50" trails useless. Several additional decisions closing routes or route sections and short spurs in the past 20 years have contributed to restricting the available camping.
Second, as noted, there has been an increase in additional trails and recreational opportunities. This has drawn more people to the area for recreation; many of these people seek overnight options.
Third, this area is frequented by people short-term living during the summer to work in and around Buena Vista.
These three issues, which have all contributed to the Fourmile North camping issues, should be considered by the BLM for this area. All the pre-2002 sites that are no longer accessible to a vehicle have now shown back up on the current allowable routes. The BLM and The Forest have never addressed if many of these sites are new or if they replaced the sites that are no longer accessible. An increase in recreation opportunities has drawn more users, and the proximity to Buena Vista is driving issues. The BLM should thoroughly analyze all three variables before formulating alternatives for Fourmile North. Ideally, more areas like Turtle Rock should be implemented where existing sites are grouped. The BLM should also heed this example where closing routes had unintended consequences and has contributed to the current problem.
Browns Canyon National Monument/Hecla Junction
This area is somewhat of an overflow issue concerning Segment 2 of the BLM/AHRA management area, Hecla Junction. Many of these sites serve river users looking to get away from the business of the Hecla site but are looking for camping proximity to the river access. This area should be considered an extension of the BLM/AHRA Hecla site, and management should follow within the same parameters. Multiple camping-based internet pages recommend this area for river camping access and Browns Canyon National Monument.
Pass Creek
The Pass Creek area should not be on this list according to the Purpose and Need. Pass Creek has five campsites inventoried within the 5,200-acre area, which is does not fit within the stated justification for inclusion into this process found on page 4.
Staff have also identified increased instances of human waste and trash surrounding preferred camping areas as well as conflicts between visitors or other land users. Anecdotally, the staff is also beginning to notice a decrease in visitor satisfaction as vehicle based campsites become unsightly from trash and human waste or are experiencing stress in trying to locate camping opportunities. This all indicates a need to move forward in developing a management framework and strategy for vehicle based dispersed camping in the Shavano area.
The project claims that this area was included because it could be impacted in the future.
Given the proximity to Poncha Springs and other high-valued recreation assets, it is anticipated that use in this area will see increased visitation and camping demand.
How can BLM consider this area for potential future impacts and the future project decision, but has chosen not to expand this camping management project beyond the Chaffee County boundaries? There are several areas under BLM management adjacent to and within Chaffee County that the project decision will most certainly impact.
Miscellaneous Lands
The project lists several additional dispersed camping sights that were documented within Chaffee County at some point. The project does not detail why these sights were registered concerning this project or by whom. The project lists a blanket statement for justification as to why they are included.
Recreation use and camping impacts are relatively limited in these areas but are in close proximity to high valued recreation resources such as the Arkansas River and popular trail systems.
There appears to be an assumption within this language that these sights are new. This would then justify a management implementation to control dispersed camping in these areas. The BLM should attempt to document and understand the history of these sites and why they are used. The two sites north of Buena Vista have been used for decades, and the two sites documented at the entrance to Chinaman Gulch, Carnage Canyon, and the two sights in Bald Mountain Gulch have also been used for several decades. However, in all these instances, new sights have not popped up in these areas. The BLM should understand why and how this project could cause new impacts where none currently exist. This reality is also why this project should not be focused solely on Chaffee County.
