Some Keys to Commenting on Travel Management Planning

The “D” of the TREAD Principles is “Do Your Part”, which means taking a proactive approach to conservation and getting involved by providing solutions. One way to “Do Your Part” is to participate in travel management planning by providing comments during public comment periods. A travel management plan includes a wide-ranging analysis considering the access needs of public land users and is conducted by the land management agency. Access needs are evaluated in conjunction with the agency’s legal mandate to protect natural and cultural resources on public lands. Providing comments on travel management plans is about more than just having your voice heard, it is the opportunity to provide meaningful insight that can help to shape how areas are managed by the agencies and it gives you standing to appeal decisions.

The “E” of the TREAD Principles is “Educate Yourself”, we thought it was important to provide you with some information that will hopefully, better allow you to “Do Your Part”. So please know that not all comments are created equal. Comments need to be “substantive” in order to be considered. Form letters, even a copy and paste of verbiage that someone else provided, are not considered substantive. When the agencies receive 1,000 form letters of basically identical comments, they are counted as 1 comment – because they all say the same thing. Additionally, the agencies are required to respond to substantive comments while no response is required for non-substantive comments.

In order to help our members, partners and the off-road community as a whole provide comments that will be considered substantive, we are highlighting the following guidelines which are provided in the National Environmental Policy Act (NEPA) Handbook.

Substantive comments do one or more of the following:

• question, with reasonable basis, the accuracy of information in the EIS (Environmental Impact Statement) or EA (Environmental Assessment);

• question, with reasonable basis, the adequacy of, methodology for, or assumptions used for the environmental analysis;

• present new information relevant to the analysis;

• present reasonable alternatives other than those analyzed in the EIS or EA;

• cause changes or revisions in one or more of the alternatives.

Comments that are not considered substantive include the following:

• comments in favor of or against the proposed action or alternatives without reasoning that meet the criteria listed above (such as “we disagree with Alternative Two and believe the BLM should select Alternative Three”).

• comments that only agree or disagree with BLM policy or resource decisions without justification or supporting data that meet the criteria listed above (such as “more grazing should be permitted”).

• comments that don’t pertain to the project area or the project (such as “the government should eliminate all dams,” when the project is about a grazing permit).

• comments that take the form of vague, open-ended questions.

You can access the National Environmental Policy Act Handbook here: https://www.blm.gov/sites/blm.gov/files/uploads/Media_Library_BLM_Policy_Handbook_h1790-1.pdf

Public comments are an important part of land management. By providing comments during a public comment period you become an important partner in the effort to keep public lands open for responsible recreation.

As it relates to the Travel Management Plan of the Labyrinth Rims / Gemini Bridges Special Recreation Management Area (Greater Moab Area):

As a result of a court settlement, the travel management plan of the Labyrinth Rims / Gemini Bridges Special Recreation Management Area is now underway. The comment period opened on September 7 and will continue until October 7, 2022. The BLM will host a virtual public meeting on September 22, 2022 from 5:00 – 6:30 pm which will include a presentation about the travel management area, an overview of the alternatives, a demonstration of how to provide written comments and an opportunity to ask questions. The link to the virtual public meeting is included below.


Tread Lightly! strongly encourages individuals interested in the travel management of the Richfield, Price, Moab, Kanab, and Vernal BLM field offices to participate. You can access the settlement document here: https://eplanning.blm.gov/public_projects/nepa/93510/169299/205894/Final_Settlement_Agreement.pdf

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