Developing Travel Settlement: 11 Plans, RS 2477, 2026 Order

The Utah BLM travel management settlement is a January 2017 court-supervised agreement that ended nearly a decade of litigation over off-highway vehicle use on federal public land in eastern and southern Utah. It requires the Bureau of Land Management to complete eleven new travel management plans covering more than six million acres, and to expressly consider impacts on wilderness character, sensitive resources, and cultural sites before designating any route as open to OHVs.¹ As of mid-2026, four plans are finalized, two of those are being reopened, seven remain in development, and a May 2026 executive order has unsettled the legal framework the plans were built on.

What the Settlement Requires

The parties filed the agreement on January 25, 2017, before Senior District Court Judge Dale Kimball in the U.S. District Court for the District of Utah, ending a case that ten conservation groups led by the Southern Utah Wilderness Alliance had filed in December 2008. Earthjustice served as lead counsel. OHV groups intervened and supported the settlement; the Utah School and Institutional Trust Lands Administration and several oil and gas companies did not oppose it.²

The heart of the deal is the eleven new travel management plans, covering land managed by the Moab, Price, Richfield, Kanab, and Vernal field offices. Before designating any route as open to motorized vehicles, the BLM must expressly consider impacts to lands with wilderness character, sensitive natural resources, and cultural resources, and must work to minimize those impacts.¹

The agreement also required the BLM to update its 2011 air resource management strategy for Utah within one year, with specific attention to air quality effects of oil and gas activity in the Uinta Basin, and to conduct on-the-ground cultural surveys in areas likely to contain historic and archaeological resources, in consultation with tribes, the State of Utah, and cultural experts.³ The environmental plaintiffs received $400,000 for attorneys’ fees, costs, and expenses.⁴

Why the Case Was Filed

In the final months of the George W. Bush administration, the BLM finalized six land use and OHV travel plans covering more than ten million acres of federal land in Utah. Conservation groups argued the plans favored motorized recreation and oil and gas development at the expense of wildlands, wildlife habitat, and archaeological sites near Arches, Canyonlands, Glen Canyon National Recreation Area, and Dinosaur National Monument.² In January 2009, Earthjustice obtained a temporary restraining order blocking certain oil and gas leases, and Interior Secretary Ken Salazar halted the leases for further environmental review.⁵ Roughly eight and a half years of litigation followed before the parties reached the 2017 agreement.

Status of the Eleven Travel Management Plans

The original settlement set deadlines running to 2025, but most have slipped. Where things stand in mid-2026:

Finalized. The San Rafael Desert plan was completed in August 2020, the Canyon Rims/Indian Creek plan in May 2021, the Labyrinth Rims/Gemini Bridges plan in September 2023, the San Rafael Swell plan in December 2024, and the Henry Mountains/Fremont Gorge plan in January 2025.⁶

Being reopened. The San Rafael Desert and San Rafael Swell plans are undergoing reassessment, with a public comment period that ran May 7 to June 8, 2026. The BLM is evaluating whether routes currently closed or limited to OHVs should be reopened.⁷ The Labyrinth Rims/Gemini Bridges plan is also under reassessment; public comments on that process closed in October 2025.⁸

Still in development. The Dinosaur (North) and Trail Canyon plans are tentatively slated for completion by late 2026. Paunsaugunt is estimated for 2027. The Dolores River plan has completed public scoping and is tentatively targeted for winter 2027. Book Cliffs is estimated for 2027 or 2028, and Nine Mile Canyon for 2028.⁶⁸

Who Is Challenging the Plans

The State of Utah, eight counties, and several motorized recreation organizations have opposed the settlement and the plans coming out of it. Utah’s Public Lands Policy Coordinating Office argues the process consistently produces restricted access and harms multiple-use activities, and the state’s official position is that BLM should provide “the most access for all users of all ages and abilities.”⁸ The opposing counties are Kane, Carbon, Duchesne, Daggett, Grand, Emery, San Juan, and Uintah.⁹ In November 2018, a court rejected the State of Utah’s efforts to derail the settlement’s protections.⁵

The Labyrinth Rims/Gemini Bridges plan has drawn two separate appeals to the Interior Board of Land Appeals. Utah filed a petition in October 2023, arguing the BLM’s closure of 114 miles of claimed RS 2477 rights-of-way violated the Federal Land Policy and Management Act and cut off access to state trust lands.¹⁰ A coalition of OHV groups including the Colorado Off-Highway Vehicle Coalition and Trails Preservation Alliance filed a separate appeal in April 2025, alleging NEPA violations and arguing the BLM should have prepared a full environmental impact statement rather than an environmental assessment.¹¹ The IBLA denied Utah’s request for a stay, so the plan remains in effect while the appeal proceeds.⁶ Separate litigation over the San Rafael Swell plan, filed by the BlueRibbon Coalition in March 2025, is stayed at the Trump administration’s request, and a State of Utah challenge to the San Rafael Desert plan is also stayed.¹²

The RS 2477 Wildcard

A separate legal fight over who owns the roads runs alongside the travel management dispute. Revised Statute 2477, part of the 1866 Mining Law, let anyone establish a right-of-way for a highway across unreserved federal land. Congress repealed that grant in 1976 through FLPMA but preserved rights-of-way that already existed.¹³ Starting in 2012, the State of Utah and 22 counties filed more than 20 federal lawsuits asserting roughly 12,000 RS 2477 claims covering nearly 36,000 miles of routes, including thousands of miles within national monuments, national parks, and proposed wilderness areas.¹⁴

The federal district court in 2015 set up a “bellwether” process using 15 test claims in Kane County, with a three-week bench trial held in February 2020.¹³ In July 2025, the court ruled on three of those roads, finding that the House Rock Valley Road and two segments of the Hole-in-the-Rock Road qualify as valid RS 2477 rights-of-way. The court explicitly cautioned that the ruling is “not meant to be indicative of how the court will rule for the other Bellwether roads.”¹⁵ The scope of those specific rights-of-way still has to be determined, and thousands of other claims remain unresolved. The connection to the settlement is direct: if a county holds a valid right-of-way on a route, the BLM’s authority to close it to motorized use is legally contested, and Utah’s Labyrinth Rims/Gemini Bridges appeal rests partly on that argument.¹⁰

The 2026 Executive Order

On May 29, 2026, President Trump signed Executive Order 14408, “Removing Unnecessary and Counterproductive Restrictions on Access to Federal Lands,” which rescinded Executive Orders 11644 (1972) and 11989 (1977).¹⁶ Those two orders had been the foundation of federal OHV management for more than five decades, including the “minimization criteria” that required agencies to minimize damage to soil, vegetation, and watersheds, minimize harassment of wildlife, and minimize conflicts between motorized and non-motorized users.¹⁷

The new order directs the Secretaries of the Interior and Agriculture and other agency heads to begin rulemakings to rescind or revise the regulations that implemented the revoked orders.¹⁸ The administration described the old criteria as “ill-defined,” “vague,” and “subjective,” and said existing statutes like NEPA, the Endangered Species Act, and FLPMA provide sufficient authority to manage vehicle use. Its stated goal is to replace the minimization framework with one prioritizing “more access, recreational opportunities, and greater multiple use benefits.”¹⁶

The Winter Wildlands Alliance called the future of the travel management rule “uncertain” after the rescission.¹⁹ SUWA said the move “risks chaos and confusion” and called the concurrent reopening of the San Rafael Desert and San Rafael Swell plans a “political decision” to expand motorized access at the expense of other users and resources.¹²

The executive order itself states that it does not create any right or benefit enforceable at law against the United States.¹⁶ How it interacts with the court-supervised 2017 settlement, which still binds the BLM to complete seven more travel management plans under specific procedural requirements, is an open question that the ongoing appeals, stayed litigation, and reopened plans will begin to answer.

1
SUWA. Travel Plans and Off-Road Vehicles Overview
2
Earthjustice. Settlement Reached on Utah Land Use Plans
3
BLM. BLM, OHV Advocates, Conservation Groups to Settle Longstanding Litigation
4
E&E News. BLM, Greens End Long Legal Battle Over Motorized Vehicles
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Earthjustice. Utah Resource Management Plans and Lease Sale Challenge
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BLM. Travel Management Plans Explained – Utah
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BLM ePlanning. San Rafael Swell Travel Management Area
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Utah PLPCO. Travel Management Plans
9
High Country News. BLM Utah Public Land Settlement Roads Recreation
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Utah PLPCO. State of Utah Petition for Stay – Labyrinth Rims and Gemini Bridges Travel Management Plan
11
Colorado TPA. Rider Groups Appeal BLM’s Labyrinth Gemini Bridges Travel Management Plan Citing Legal Violations
12
SUWA. SUWA Statement on BLM’s Intent to Expand Destructive Motorized Use in the San Rafael Swell and San Rafael Desert
13
Utah PLPCO. R.S. 2477
14
SUWA. Phantom Roads – R.S. 2477
15
GovInfo. Order in Kane County RS 2477 Bellwether Case
16
White House. Removing Unnecessary and Counterproductive Restrictions on Access to Federal Lands
17
SUWA. President Trump Revokes Executive Orders Protecting Public Lands From Unmanaged Motorized Recreation
18
White House. Fact Sheet: President Donald J. Trump Removes Unnecessary and Counterproductive Restrictions on Access to Federal Lands
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Winter Wildlands Alliance. Trump Administration Rescinds Two Executive Orders