The Bureau of Land Management Taos Field Office appears to be including illegally constructed mountain bike trails in their current Sombrillo Travel Management Plan and treating them on equal footing with authorized trails.

Recent illegal trail construction has seriously damaged the Sombrillo Area of Critical Environmental Concern (ACEC).

• These trails were constructed before the BLM made any required NEPA assessments.
  
• The BLM has claimed that all trails in the Sombrillo ACEC are “unauthorized.”
  • This statement contradicts the facts.
  • Long-term (>60-years-old) trails that began as cow trails, then horseback trails, and hiking trails, before mountain bikes even existed, have been used by hikers and bikers for decades.  The BLM website includes them as the only trails in the ACEC^[1]”The Nambe Badlands Trail consists of two loops that cover about 5 miles of rolling terrain with several steep pitches.  There are also excellent views of colorful eroded badlands.”, … Continue reading
  • The historic trails existed before the ACEC was designated in 1988.  The BLM officially assessed them for impacts to the critical resources during the initial ACEC evaluation phases.
  • There is a considerable difference between these legacy and illegal trails recently constructed by rogue mountain bikers using shovels, picks, and saws before any environmental assessments.
• The National Environmental Protection Act, Federal Land Policy and Management Act, and the Paleontological Resource Protection Act, require official environmental assessments before trail construction begins.
  
• The BLM Taos Field Office has been aware of illegal trail building in the Sombrillo ACEC since 2010.
  
• In 2012 the BLM asked the Santa Fe Fat Tire Society to cease all trail building in the ACEC.
  • At that time, the BLM closed and reclaimed the illegal trails.
  • However, the illegal trail building continued.
  • A BLM Taos Field Office Recreation Planner was involved in the illegal trail planning and building (he is no longer working for the BLM Taos Field Office).
    
• A popular strategy of rogue trail builders is to construct illegal trails hoping that the official land manager will eventually approve them.  Some BLM Taos Field Office employees knew of the illicit trail building and at times aided and promoted the illegal trail building.
  
• Even though the mountain bike clubs knew of the illegal trails that were built in the Sombrillo ACEC, they promoted huge group rides to burn in these trails on the sensitive formations and soils where they were covertly constructed. These mega-group rides upset many to the point that they are now proposing the entire area be closed to everyone.  Unfortunately, the community of responsible mountain bikers, hikers, horsemen, and the fragile landscape, are suffering the consequences of irresponsible mountain bikers.
  
• Allowing the BLM Taos Field Office to treat these illegal trails on equal footing with historical or proposed new routes promotes more illegal trail building activity and damage to the resources that the BLM is authorized to protect.