Commenting on Trail Management Plans

How to Write a Letter to a Land Management Agency

 

By Karen Marshall and Denise Y. O’Meara, RLA for ELCR

Using Commentary to Protect Your Trail Access

When it comes to trails on public lands, there’s no time like the present for us equestrians to make our needs and opinions known.  By ‘present’ we mean Public Comment Time – those time periods when governmental agencies seek public commentary on the development of new or revised trail management plans.

State and federal forest service and other land management agencies frequently revise their public property management plans. These proposed management plan changes are then opened up for public comment for a designated period of time.

Trail management plans, generally included within overall forest or park management plans, provide guidance specific to trails, including equine trails. The comment period is an opportunity for equine and other users of public lands to express their opinions on the proposed changes and participate in the decision process.
 

Access To and Use of Public Land Trails is at Stake

Where trails involve multiple user types, trail safety is a primary consideration in any management decisions. User input into public lands management must be recognized and considered so that safety will not be compromised due to animosity between users. When different users feel that their trail needs are not being met, it can and does lead to proliferation of user-created trails, refusal to comply with perfectly appropriate management changes and closures, and the need for additional law enforcement.  Serious safety issues can lead to trail closure.

A number of factors can influence the effectiveness of the public’s comments regarding public land management and implementation plans. Here are some suggested do’s and don’ts regarding the composition of letters to these public agencies, as gleaned from previous public comment requests.

DONT’s

Don’t Generalize – Be Specific

• Don’t make a general statement that is not a specific comment related to the proposal and its effects. Example: If you just say that you disagree with proposed trail closures, it is a “non-issue” in the eyes of the forest service and will be tossed aside.

• Don’t express general support for another comment already provided. If all you do is say you support an organization and its stance and comments, your comment will be listed as “non-significant“.

Don’t Whine or Blame– Be Forthright

• Don’t use a complaining tone.  State the particular issue, how it affects you or your group, and offer potential solutions.  Example: ‘We really hate it that you closed that trail.  We want our trail back!”  Instead, say “We understand that your agency had reasons for closing that trail. We do not currently have an alternative trail so can’t connect from Trail A to Trail B.  Here are some ideas on what could be done, and how my organization can help.”

DO’s

Be courteous.

• Express appreciation for the agency’s past and current efforts to provide for public recreational use of the forests.

• Express appreciation for the agency’s respect for and attention to horseback users and trails.

Introduce yourself.

• If writing on behalf of an equestrian organization, mention its membership and its positive economic and social impact on the community.
• Provide some information on the extent to which you or your organization uses public lands for trail riding.

Emphasize the importance of your input on this issue.

• Say that, and preferably how, your members will be directly affected by the results of this analysis and its subsequent implementation. Ask the agency to consider your comments as generally representative of your [X number of] paid members’ concerns.
• Note the extent of use by equestrians of the trail system under review and its significance to those riders. Say how a proposed change or new trail will contribute to or detract from an enjoyable, beautiful, scenic ride.
• Illustrate what is spent during a typical trail ride there. Note bridle tag and other fees paid to the park system.
• Include volunteer work on trails and any memorandums of understanding between your organization and this or other agencies regarding trail maintenance.
• Note other organizations that also support your position.

Address the issue or proposed changes for which public input has been requested.

• Be concise. Rambling on about things not directly related to the issue is not useful. Make comments that are significant and substantive:  specific comments regarding the proposal, specific disagreements with the proposal, not yet decided by law, regulation, or policy, etc. If you give arguments and reasons as to why trails in a public forest should remain open – attack the wording, the research, the assumptions, etc.

Make some positive recommendations to resolve the issue underlying the proposed changes.

• See examples under issue-specific comments below.

Write the letter!

• A letter you’ve never written will never be read. An opinion never spoken will never be heard.
• Trails have failed because others have done a better job at writing letters saying why they don’t want a trail.

DO Include Issue-Specifc Comments

Trail sharing and user conflict

There are many management options short of separating or eliminating uses – such as education, peer-patrolling, or alternating days – which can work to manage diverse uses compatibly.

Trail management and sustainability

• An effective management plan for trail systems is one of the best tools available for alleviating the environmental impacts and user conflicts inherent in recreational use. Failure to put that plan into practice will only lead to the spread of illegal and/or unmanaged use.

• Unmanaged use has immeasurably greater impacts on resources, as there is nothing preventing this use from impacting soils, wildlife, archaeology or any of the other myriad resource concerns on public lands.

• Although proper law enforcement should play a part in any recreation management strategy, enforcement alone cannot be successful without appropriate opportunities for recreational users.

 

Off-road vehicle access to public forest trails

• Off-road vehicle registrations have increased in comparison to other types of recreational access.  But this does not entitle off-roaders to a disproportionate allocation of public forest acreage. Equestrians should point out that such consumer choices do not mandate public agencies to provide places for off-roaders to ride, especially where it is indicated that their choice of transport poses an increased threat to natural resources.

• Quote off-road user statistics from your state.  For example: Statistics from Minnesota indicate that over one-half of the ATVs registered for recreation are not being used in public forests. Most of those who do ride on public lands do so for very limited purposes, and only a few times a year. A fairly small minority of riders accounts for the bulk of all ATV riding.

• Compare the impacts of equestrian vs. off-road vehicle volume and frequency of use on safety, trail conditions and environmental quality.

• Encourage your public agency to provide a credible trail riding compliance plan that includes a proactive enforcement protocol. For example, providing buffer zones between motorized and silent user designated areas (incompatible uses) is a simple, reasonable and readily implementable solution.

• Many miles of undesignated trails are also legally ridden by ATVs where the managing agency has placed most of that acreage into the most heavily-motorized “open unless posted closed” management category. Request that in order to provide silent users with equal opportunities to enjoy their sport on a level commensurate with that being presented the motor sports public, more areas must be designated as ATV/OHV Free Zones.

• Point out cultural or heritage sites in the area under review. Suggest how establishing trails, loops or connectors to these sites could increase their value in the community and thereby the importance of their preservation. Remind the agency that horseback riding and driving is an ancient form of transportation and recreation that contributes to diversity and the continuation of a historic tradition.