February 23, 2021
Whit Bunting, Field Manager
Kanab Utah Field Office
Bureau of Land Management
Interior Region 7
The UT/AZ ATV Club has been an established club in Kanab for many years and our members have been riding the roads in the Trail Canyon Management Area since before the club’s existence. With more than two-hundred members in the club, we believe we have a fairly good understanding of the historical use of the roads in this area and offer the following comments to the current draft proposal to the Trail Canyon Travel Management Plan.
We understand that this Travel Plan was re-written because of a court order, and we can appreciate the size of this undertaking. As part of the motor sport community, any proposed road closures are reason for concern and are taken quite seriously. It’s not just our local ATV club being affected, but all the motorized user groups which includes, for example, hunters, ranchers, and people that vacation here for recreational reasons. The economical impact to our local community from OHV use is quite substantial and we feel it important to continue to provide as many miles of riding opportunities as possible. The club would prefer Alternative “A”, which would continue to allow for the most miles available for motorized use.
If, for some reason Alternative “A” is not the chosen option, the next least restrictive option, Alternative “D”, would be somewhat acceptable with some modifications. Alternatives “B” and “C” are far too restrictive and our club is emphatically against either one of those alternatives. If, for some reason alternative “B” or “C” is being considered, our club will be requesting a meeting to discuss and hopefully mitigate some of these more restrictive closures. Using the maps provided, nearly all the roads proposed to be closed in alternative “D” were personally viewed and rated by our club members. Rather than list each road in Alternative “D”, and how we perceived the closures, we decided to focus on our highest priorities.
Roads 10G and 17B are currently stand-alone dead-end roads that terminate close to each other. The two roads connected historically but were separated because of the WSA. Our club is in favor of recreating these two roads into a loop using the old, existing roads. If this option is not feasible, the club would be willing to investigate the possibility of creating a new trail just outside of the WSA boundary to create a loop using these two roads.
Road 20A currently connects to 14B and is not a dead-end road as indicated on the map. Allowing this connection to remain open helps maintain an existing route that connects Road 20 and Road 10
Road 36B is not a dead-end road as indicated on the map. This route connects to Road 30 and provides an interesting alternative to travel to the Dinosaur Track Site. Our club is requesting that Road 36B remain open and the existing connection to Road 30 remain as it currently is.
Road 60HC is proposed for closure and our club is requesting that it remains open. This road allows for a short loop around a remarkably interesting rock formation and is a fun geologic feature to observe.
Road 61A is an especially important route for the OHV community and we believe that the BLM needs to take another look at this proposed closure. From the Peekaboo Staging Area this road provides access along Rt 89 southeasterly to connect to Road 61. The closure of Road 61A would encourage people to travel down Rt 89 on or alongside the pavement creating an extremely unsafe condition. After a discussion with UDOT regarding this crossing, it was determined that this trail was in the UDOT right of way. The Club was instrumental in getting signs installed on Rt 89 indicating an ATV crossing in that location. Once the installation of the signs was completed, UDOT was satisfied with the current situation. Rerouting the trail to cross Rt 89 directly across from Road 61 would not be a good alternative to this. This new crossing location would create another hazardous situation as well because the approach to Rt 89 would be an uphill approach and would have OHVs accelerating as they approach the state highway. Our club requires the location of 61A to remain open and its location remain where it currently is.
Road 61L provides a nice scenic view and would allow for a desirable loop when connected to Road 60A. Although not currently connected on the map, we would like to propose this for consideration.
Road 64T allows people to connect from Road 61 to Road 64 and should remain open. Without this connection, people are forced to travel additional mileage to make this connection.
Also, although the following roads were listed as closures in Alternative “D”, they were never located on the maps provided by the BLM as proposed closures. TC0032, TC0035, TC0053, TC0061, TC0074, TC0082.
One last comment regarding this Trail Canyon TMP. We discovered while performing our road inspections that the signs showing the road numbers on several of the roads were missing. Without the signs, it sometimes took extra effort to assure that we were indeed at the correct road. In future plans, it would be beneficial to include GPS coordinates at the intersections of the proposed closure and the adjoining open road.
Thank you for the opportunity to provide our comments. We trust our comments provided to you will be considered when completing the final TMP for this area. Please know that the UT/AZ ATV Club is always available to assist in the creation of these and other plans.
President, UT/AZ ATV Club