Illegal Trails

Historical trails in the Nambé Badlands

Trails have existed since the 1960s in the Sombrillo Area of Critical Environmental Concern (ACEC). 

These historical trails were established by BLM cattle lease permittees[1]Ignacio Roybal, Jose Vigil, Longino Vigil, Pablo Roybal, and Alfredo Roybal of Nambé.  Horseback riders, hikers, and eventually mountain bikers[2]Mountain bikes were first commercially available in 1978 embraced these existing trails for recreational use.

The Sombrillo ACEC was established in 1988 to protect paleontological, geologic, scenic, and cultural resources in the Sombrillo Travel Management Area (TMA).

Local residents of Nambé coordinated trail maintenance of trails with the BLM.  This trail maintenance involves erosion control, rerouting water runnels off the trails, picking up litter, and using natural downfall branches and rocks for trail borders.  Mountain biking was sustainable, meaning the fragile landscape was minimally impacted by mountain bikers.

  • New trails were not constructed
  • Trail users stayed on existing trails.
  • Mountain bikers followed established rules of the trail

For many decades, an honor-system approach worked well for good trail ethics in this fragile, highly erosive landscape. The number of single-track trails was plentiful, and it was rare to encounter anyone else on the miles of established trails.

2010-2013

Between 2010-2013 members of the Santa Fe Fat Tire Society (SFFTS) and a BLM employee apparently began constructing mountain bike trails in the Sombrillo ACEC.  These trail-building activities were posted on the SFFTS Facebook page. Construction of trails before any official National Environmental Protection Act (NEPA) environmental assessments are made is illegal.

During this period a former recreation manager from the BLM Taos Field Office apparently aided members of the SFFTS in their unauthorized trail building.  We recently learned from the SFFTS that a recreation manager from the BLM Taos Field Office told the SFFTS they had permission to build trails[3]“In 2010 members of the Santa Fe Fat Tire Society were told by a recreation manager from the BLM Taos Field Office that they had permission to build trails. After construction began, the … Continue reading.

This timeline details the trail building in the Sombrillo ACEC.

Local residents of Nambé formally complained to the BLM Taos Field Office about the illegal trail building in the Sombrillo ACEC.  A meeting between mountain bike club representatives, long-time local trail users, and the BLM was held.  The result was closure, and signing of “trails closed”, and the reclamation of these illegal trails.

In 2019, some members of the SFFTS mountain bike club resurrected new trail planning and flagging operations in the Sombrillo ACEC and Nambé Badlands.  This is evidenced by posts on the SFFTS Facebook page.  This recent push of building new trails, by some members of SFFTS and perhaps others, has been extensive, constructing almost as many new trail miles as the existing trail network.  The SFFTS has big plans to develop the Sombrillo ACEC into a popular mountain bike destination, like Fruita, by Grand Junction, Colorado.

These new trails were constructed before any of the required environmental assessments of BLM’s 1976 Federal Land Policy and Management Act, Paleontological Resource Protection Act[4]The Paleontological Resources Preservation Act authorizes civil and criminal penalties for illegal collecting, damaging, otherwise altering or defacing, or for selling paleontological resources, and … Continue reading, and the National Environmental Protection Act were made.

Any trail flagging and construction must proceed after the official BLM Travel Management Plan — part of the National Environmental Policy Act (NEPA) process, is complete.  The BLM law enforcement emphasized that planning, flagging, and construction are not allowed until the official Travel Management Plan is complete.  The BLM is investigating the trail building and trail signing in the Nambé Badlands and Sombrillo ACEC.

Perhaps whoever is constructing the illegal trails in the Sombrillo ACEC is attempting a strategy that other illegal trail builders have used on public lands?  A strategy that has been used by rogue trail builders in other areas has been to build illegal trails before the NEPA Travel Management Plans are complete — hoping that the public land manager will include the illegal trails in the trail inventory considered for final approval.

The Taos BLM Field Office is including illegally constructed trails in the inventory for the Sombrillo Travel Management Plan.  We are opposed to BLM including any illegally built trail in this inventory.  To do so disregards the laws of NEPA and gives implied approval to illegal trail building!

To voice your concern please contact the BLM Taos Field Office, using the email link below.

The Friends of the Nambé Badlands encourage the broader mountain bike community to publicly speak out against illegal trail building and to promote responsible mountain biking.  We love mountain biking in the Nambé Badlands, as do many other responsible mountain bikers.  The illegal actions of a few rogue actors risk all of us losing access, while also ruining the reputation of mountain bikers.  Let’s find a way to foster responsible mountain biking and work within the laws with the BLM to maintain and build a sustainable trail network that hikers, equestrians, and mountain bikers can share for decades to come.

BLM Taos Field Office

This map shows the GPS measured trails in the Sombrillo Area of Environmental Concern as of 5/1/2021.  Click on the numbered white circles to see details on the corresponding illegal trails.

These trails can be classified into four groups based on:

  1. When they were constructed {prior to 2011, after 2011}; and
  2. Whether they were assigned a BLM trail segment number and included in the 2019 Sombrillo Travel Management Plan and Environmental Impact Statement {have a BLM trail segment number, do not have a BLM trail segment number}

The color-coding on the map follows this schema:

  • Trails existing on the ground prior to 2011. Green, light green, dark green, blue, and light blue trails. The blue trails were primarily used for hiking up until approximately 2018.
  • Trails that were non-existent on the ground prior to 2011:  Red, orange, magenta, pink, orange, and dark red trails.
  • Trails, of any color, that have a similar colored trail segment number were included in the 2019 BLM Travel Management Plan and EIS. (trails
  • Trails with no colored number are unknown to BLM and are not referenced in any BLM documentation.

The white circles with numbers inside of them are links to detailed drill-down GIS, photographic, and social media analyses of those trails. Click on any of these links to go to the web pages that contain these analyses.

References

References
1 Ignacio Roybal, Jose Vigil, Longino Vigil, Pablo Roybal, and Alfredo Roybal of Nambé
2 Mountain bikes were first commercially available in 1978
3 In 2010 members of the Santa Fe Fat Tire Society were told by a recreation manager from the BLM Taos Field Office that they had permission to build trails. After construction began, the recreation manager realized that correct procedures had not been followed and informed SFFTS that the trail work must not continue and SFFTS stopped all trail building activities.” — December 8, 2021 email correspondence from the SFFTS to the Friends of the Nambé Badlands.
4 The Paleontological Resources Preservation Act authorizes civil and criminal penalties for illegal collecting, damaging, otherwise altering or defacing, or for selling paleontological resources, and the proposed rule further details the processes related to the civil penalties, including hearing requests and appeals of the violation or the amount of the civil penalties.
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