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Houston, we have a problem

8865 Views 66 Replies 33 Participants Last post by  Morlahach
After the '06 KTR was done and put to bed, I got this email from a fella at the Moab BLM office:

Hi there,

I received a report about the Kokopelli Trail Race you held on public land last weekend. The description on your website makes it quite clear that your event was competitive as defined by BLM and therefore required a Special Recreation Permit (SRP):

Competitive use means any organized, sanctioned, or structured use, event, or activity on public land in which two or more contestants compete and either of the following elements apply:

1) Participants register, enter, or complete an application for the event, OR

2) A predetermined course or area is designated

Source: BLM Manual H-2930-1, Recreation Permit Administration

Please call me at 435-259-2136 to discuss this further.

Please note that a competitive SRP is also required for your upcoming event, the Grand Loop Race. I have spoken with Andy Windsor, the recreation permit administrator for the Grand Junction BLM Field Office about this event. I highly recommend you contact him at 970-244-3044.

Sincerely,

--Chad Niehaus
Outdoor Recreation Planner
BLM Moab Field Office
Slightly alarmed, I sent back this response:

Chad-

Thanks for contacting me. I'm curious about the 'report' that you received.

Was it a complaint (and if so, about what?) or simply a note that the event had taken place?

Of the two numbered points you listed, number 1 does not apply. There was no registration, no application, and no entry fee. No one paid anything, no one signed anything, and there were no services offered.

But number 2 does--all that showed up agreed to follow the route of the Kokopelli Trail. Not all followed the exact trail, and very few completed the entire route.

According to the definition of "competitive use" that you listed, if myself and two friends showed up at the Slickrock Trailhead, unloaded our bikes, strapped on our helmets and said, "Let's race. First one around the Practice Loop wins", we would also need a SRP?

That doesn't make any sense at all, to me.

Care to elaborate?

Thanks,

MC

P.S. I'll be happy to contact Andy about this as well.
After a few anxious days, I received this response:

Hi Mike,

Thanks for the quick response. I read the information on your website about the lack of registration, application, and entry fee for the race. You will notice that only one of the conditions has to apply for the event to be considered competitive.

You must admit there is a difference between two friends challenging each other to a dash around the practice loop and a 142-mile "ultimate spring race" with rules (e.g., no support vehicles, allowing participants to filter water) that "has seen a dramatic increase in popularity." The report I received, which was a complaint of sorts because the person found a relatively large amount of litter (Snickers, Emergen-C, Little Debbie, and energy bar wrappers, water bottles, several bike tubes, and a pair of bib overalls) along the portion of the trail near Sand Flats the day the race started, is under the impression that 56 people started the event this year.

Talk to you soon,

--Chad
I gave it some thought and sent this back to him:

Chad-

I do admit that there is a big difference between two impromptu racers and several that are pre-planning on it. But then I can also see (and I'm sure that you can too) that racers that are well-versed in backcountry etiquette enough to attempt the Kokopelli unsupported and in one push are not your average tourists convening at Slickrock on a Saturday in May. The racers don't litter, they see, understand, and respect the significance of crypto crust, they rely on a light, fast ethic to get through the desert quickly and they leave no trace when doing so. They are self-sufficient and responsible--they HAVE to be to even attempt something like this.

From my perspective, there isn't a user group out there more ideally suited (in theory and in practice) to enjoy this area without impacting it or other groups using it. Can't say the same about moto's doing 60, sideways, around blind corners (racing or not) near Westwater, 20+ jeeps caravanning through Yellowjacket (and the resulting exhaust, candy wrappers, and oil drippings left behind), or the group of 15+ ATV's that pulled completely off the trail (and into crust) so that they could stop to take pictures and drink beer near the Top of the World junction. And don't get me started on the impact of drill rigs and the roads built to service them.

My point is simple: the letter of the law may have been bent, but certainly no harm was done by anyone in this group. We're talking about a handful of bike riders that traversed an existing heavily traveled route under their own power, left no trace, and went back to their jobs on Monday morning with a story to tell. I fail to see a problem with that. In fact it's the opposite--I think this sort of behavior should be rewarded and encouraged.

As to the complaint that you received: litter at or near the Slickrock trailhead and on the Sand Flats road is not a new thing, and it was certainly not left there by the racers. I'd venture a guess that that trailhead and that road are among the most popular destinations in North America for mountain bikers and other recreationalists. After the racers left the Slickrock parking lot (and there were many, many non-racers camped/partying/riding there that night) I followed along much of the route in my truck, walking some of the techier stretches, taking pictures and looking for litter, and found not so much as one GU wrapper. I also was the last one to leave the Loma Trailhead after the racers had dispersed that night--not so much as a hint of trash anywhere, and I looked very hard to find some.

The items that you noted:

-no support vehicles,
-allowing participants to filter water
-has seen a dramatic increase in popularity


...are worth mentioning from my point of view, too.

-Support vehicles: Any excess traffic out there on that trail is a bad thing, IMO. Anytime you allow people to have support in a race, you encourage them to be unprepared for what's in store. By discouraging support vehicles I feel that I've increased the safety of all racers AND non-participants on that route, that day, because the racers are expecting nothing more than what they can provide themselves. They don't ride fast, don't take chances, and don't put themselves into harms way. There WERE two injuries on the course (1 collarbone break, 1 shoulder separation) and both racers managed to extricate themselves from the course without need for SAR or emergency vehicles.

-Allowing participants to filter water. After much thought, I can't see where this is a bad thing from any perspective. Racers were educated on (and discouraged from) taking water from puddles/potholes in rock (like on the Yellowjacket section) that animals might use/depend on. But racers were encouraged to filter/treat the water from the Fisher Creek ditch (just west of N Beaver mesa) and from the Colorado River. Please educate me on how this is a negative scenario?

-Dramatic increase in popularity. I'm torn on this one. As long as people are responsible for and capable of taking care of themselves out there, I think riding the Kokopelli in a day is a great way to get people out to enjoy and experience the Colorado Plateau. That said, it was clear that not all racers were comfortable in the desert on that hot day. I think it's probably time to let people ride it "in a day" of their own accord--organizing them has been fun but it has also run its course.

Looking forward to your response.

Thanks,

MC
I never got a response to that last one, and (erroneously, duh) assumed that that was the end of it.

I'd forgotten all about it until a few days ago, when another email popped up from the same chap, inquiring as to whether I'd pulled a permit for this year's race.

Hi Mike,

It has been a year since we last communicated, but as you will likely
recall we were emailing back and forth about permit requirements to conduct
a competitive event on BLM land. Have you been working with the Grand
Junction BLM to obtain a permit for your races?

Thanks,
--Chad Niehaus
Since I'm not involved and didn't truly know the status of the race this year, I answered back that:

Hey Chad-

Thanks for the note. After our discussions last year, and considering how big the race had become, I decided to cancel any further races.

I heard a rumor that there might be a race of sorts on the Kokopelli Trail late this month, but I have zero involvement with it.

Cheers,

MC
I now know that a certain individual (that shall remain nameless) has been contacted by the BLM about his role in "organizing" the 07 KTR.

What's it all mean? Y'all might have some gubmint company on Friday night. And future events of a similar ilk need to start planning around this sort of thing.

Thoughts?

MC
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G
Some thoughts

Mike,

I should probably gather my thoughts a little more. I'm all excited about riding the KT this weekend though, and Dave riding the Grand Loop has got me checking things here frequently. I'll sound off, and hopefully not lack for sense.

I think your responses describing this ride conveyed what many others also feel. It really is a gray area trying to differentiate between any group ride, and an 'event' like this. If I invite six friends on a ride and three bring someone I don't know, how much different is that from sharing info on an internet forum between folks with common interests? And when is the line of 'advertising' crossed, versus 'inviting' folks on a ride? Do you have to 'know' someone to a certain degree? Is a certain number of riders OK? I guess it's one of those things where you know it when you see it. Too bad the "you" in that statement is then imposing regulations on the "it".

Addressing a specific point, that litter comment is ridiculous! A pair of 'bib overalls'??!! I'm also somewhat surprised that so many tubes would be left in the described area. I guess Sand Flats rd. is a lot harder on bikes than I realized. It sounds like a generic description of things someone would be ticked off to find after a bike race. Good thing we kept the porta potties clean, and got them out of there in time! I've worked in the Sand Flats Recreation area, and can attest that there is tons of 'litter' left up there any given weekend. Most of it is cylindrical aluminum, and rarely is it cleaned up quickly enough that you could pinpoint the evening it was left.

I've been worried about this sort of regulation. I think certain land management agencies are not able to fit this type of ride into their policies very well. I know some people are worried that these rides are getting too big. That may be. I for one enjoy participating, knowing that anyone who might like (and is hopefully prepared) can also give it a shot. The more the merrier, and more competitive the better. I tend to lose interest when things are only for the select few (however they are selected). That's been one of the things I really enjoyed about the last two KTR's. I really hope that events like it can continue to be held. There are lots of ways to see that happen, but maybe that's a discussion for another place.

FW
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Not a surprise

I ran across a promoter for a front range event that had learned about a race that was planned for the fall that would probably utilize the same trails that he ran a "legit" (read mindless XC) race on. He was livid that there was an event that did not go through the same approval process has his did. He felt that he paid his dues and did it the right way and no one else should be able to run an event on "his" (read I paid for) trail system. I'm willing to bet that this guy will drop a dime on the event and try to get it cancelled before it even gets off the ground. I guess we will just wait and see.
Shoot, I was wondering what happened to my emergency bib overalls I carried last year. I dug into my pack at Yellowjacket to guard me from a bee sting, only to find they had gone missing! :arf:

I can also say I am fairly certain that the above mentioned individual has not heard any word back from the BLM after his reply to their initial contact.
I'm no attorney, and haven't read the BLM language. I have, however, participated in many car "races" (at tracks). These were always called "Driver's Education" for legal and insurance reasons.

This leads me to suggest calling the event something other than "Kokopelli Trail _____". Perhaps "Kokepelli Endurance Education" is better. If a given individual wishes to ride quickly, that may be his perogative, but the occasion as a whole is surely meant to be nothing more than an enjoyable learning experience.

PS - I love learning experiences.
rapwithtom said:
I'm no attorney, and haven't read the BLM language. I have, however, participated in many car "races" (at tracks). These were always called "Driver's Education" for legal and insurance reasons.

This leads me to suggest calling the event something other than "Kokopelli Trail _____". Perhaps "Kokepelli Endurance Education" is better. If a given individual wishes to ride quickly, that may be his perogative, but the occasion as a whole is surely meant to be nothing more than an enjoyable learning experience.

PS - I love learning experiences.
Thats exactly what organizers do for road events like centuries or double centuries. Some land managers or state highway people get all excited when the word "race" is applied and it brings out all sorts of canned regulations. You take any CTC event and they specifically do not call it a race, but they do have mass starts and in some of the events have timed finishes. There are fees - but those are only "buying" into the right to use one of the aid stations along the route - off guvmint property.

I see KTR as no different than a club road ride which has green sign sprints along the way and also keeps people times. I think Chad is taking a very strict interpretation of this.
Interesting. Partly sounds like a money grab.

You could also call it a training event.
BLM web site

II. WHEN PERMITS ARE NOT NEEDED

C. A competitive event is not commercial, complies with land use plan decisions and designations, does not award cash prizes, is not publicly advertised, poses no risk for damage to public land or related water resource values, and requires no management and monitoring. Examples: A fun run, which is held on county roads crossing BLM lands, when the participants do not leave the road right of way; a scout troop challenges another troop in an orienteering event.
The note I received:
Hi Adam,

Based on postings on this forum, it would appear that you are the closest thing to an event organizer for the '07 KTR. If this is indeed the case, please be advised that the KTR requires a competitive Special Recreation Permit (SRP) as the event meets the following criteria:

"Competitive use means any organized, sanctioned, or structured use, event, or activity on public land in which two or more contestants compete and either of the following elements apply:

1. Participants register, enter, or complete an
application for the event; or
2. A predetermined course or area is designated."

This was explained to the previous organizer of the KTR, whom I understand now has no connection to the race.

Please let me know how you plan to proceed. If you are not the appropriate person to speak to regarding this issue, please pass the correct contact info on to me at your earliest convenience.

Sincerely,
--Chad Niehaus
Outdoor Recreation Planner
BLM Moab Field Office
(435) 259-2136
This is the reply that was sent to Chad Wednesday morning:

Chad,

The KTR itself really does not have a formal organizer. I suggested a time and place to start the ride this year, and people responded to that. However, there is really no way of knowing if any of those people will actually show up at that time. There is no fee, no registration, no sponsors, no support, no prizes and no expectations, beyond what the individual rider brings with him. We follow a basic set of rules, to help ensure that people are not placing any burden on others enjoying the route. In short, it is a ride for people who like to challenge themselves in a unique and satisfying way.

Competitive use means any organized, sanctioned, or structured use, event, or activity on public land in which two or more contestants compete and either of the following elements apply:

1. Participants register, enter, or complete an application for the event; or
2. A predetermined course or area is designated.


Using the above definition, the KTR only loosely qualifies as a competitive event. The ride is not organized, not any more than a suggested start time and place, and certainly not structured.

The KTR does follow a specific route, but based on that very vague guideline, almost any weekend ride could qualify as a competitive event.

In fact, the KTR almost exactly meets the criteria for not needing a permit at all.

2932.12 When may BLM waive the requirement to obtain a permit?

We may waive the requirement to obtain a permit if:
(1) Is not commercial;
(2) Does not award cash prizes;
(3) Is not publicly advertised;
(4) Poses no appreciable risk for damage to public land or related water resource values; and
(5) Requires no specific management or monitoring.


You have asked me how I plan to proceed, and frankly I am not sure how to reply to that question. Obtaining a permit is unlikely, given the 180-day time period cited to obtain one. I plan on starting my one-day ride of the KT at the same time and place that I have been planning on for months. I can't speak for others who have expressed the same desire. If they are there, I will be happy to ride with them. If not, I will be happy to ride the route alone.

If you have any more questions or concerns, please let me know.
There has been no response.
alizbee said:
The note I received:

(3) Is not publicly advertised;

There has been no response.
Adam I hate to say it but the KTR IS publicly advertised. You had a website telling everyone date and time and direction. I noticed that the website is now down but google still lists as #4 when you do a search on "kokopelli trail race" and if you select cache you see the page.

Good luck on the event and I hope "The Man" does not keep you down.
blargo said:
Adam I hate to say it but the KTR IS publicly advertised. You had a website telling everyone date and time and direction. I noticed that the website is now down but google still lists as #4 when you do a search on "kokopelli trail race" and if you select cache you see the page.

Good luck on the event and I hope "The Man" does not keep you down.
It was a blog - not a website, and there is a difference. Just a free thinking individual expressing his thoughts and that is not advertising.
The problem isn't really if we think it's advertising. It matters how the BLM officials interpret it. Semantics aside that's always how things are going to work on the surface. By surface I mean, if "company" shows up Friday night.

I think the future of these events eventually boils down to it becoming openly talked about but congregation points like this will be word-of-mouth only. I don't think that ultimately solves the problem though since secrets are impossible to keep in this day & age.

Maybe the evolution of these events is such that there either the proper permits are filed, or people always do it solo. The ironic thing is that even if 50 people are going to do the KTR this year, and each of them chooses to do it at their own time of choosing, that still violates the following rule:

2. A predetermined course or area is designated.
I understand that many of these regulations are often counter to each other and a lot of leeway is given so that people who try to avert the law will be subject to prosecution when they do something wrong. The rub obviously lies in a case like this, when the interpretation is on the more Draconian side of things.

Probably the only long-term way to play it is to, as Danny Devito suggests in Johnny Dangerously, "Play ball!"
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I am wondering if this could be motivated by complaints from tour operator(s) that do(es) rides on the KTR? I talked to one such tour operator when I was ordering the updated maps and guide (mine were from the early 90's). He was friendly, but seemed to have the attitude that it was dangerous for me to try to do the KT in a day (maybe 'cause I'm a girl?). I could see how a tour operator might interpret this group ride as detracting from marketing the KT in 3-4 days as a "challenging" ride (as the literature on said tour operator's website does). On the other hand, I've told plenty of people that I was planning to do this ride, and not one of them said "oh, I'd like to do that..." Even bike racer friends of mine from back east couldn't fathom why I'd want to do a completely self-supported ride of this length (ones who readily do 24 hour events). I think an event like this would only boost a tour company's business by getting word out about the trail - it has become clear to me that it is only a small fraction of the population who actually wants to do this kind of thing on their own. But that doesn't mean that all tour operators see it that way...

I'm not pointing fingers at any operator in particular, just hypothesizing, since it seems a bit out of the blue that the BLM would have "complaints" and be contacting the so-called organizers about it. There must be some kind of motivation driving the BLM inquiries, so it seems that finding that motivation might help determine how to address it.

My motivation for posting? Since I got sick and can't join the ride this year, I want to do it next year, and don't want to see the BLM "shutting it down".


BTW - I used the term "ride" rather than "race," since I agree that the term race can raise red flags in some quarters..

Morgan
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It is a tuff call!

I'm a race promoter that goes through the proper channels to put on my event. I do this because I eventually want to make a buck (not a killing) doing what I love to do.

I also see no issue with what's going on with the KTR. It really boils down to the local agencies and how they interpret it. I've talked with several other agencies about events I want to do in the future and some are more than accommodating with the idea of "group rides" and would rather not bother with the whole process of permitting (they don't have time). Others are a lot more strict.

I, and several other people I know, are still going to show up. For me... I know nothing of this "race" and just want to ride my bike. I'm not even sure of my route and where I might end up (because I'm truly not). Maybe I'll see some other folks there too! What's Ranger "Dick" going to do, show up with his posse and take us out? I doubt it. However, I know people that had thier asses handed to them for not going through the proper channels...We will see!

Just one more thought...Most agencies do appreciate a heads up with this type of thing...And it might go a long way to do so in the future.
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I agree. I'm just going to show up for a ride. I need to make it to Moab by the end of my ride, because that's where my dry clothes and my beer will be..
Racing doesn't seem to matter...

If you read the BLM website and all the rules, it doesn't matter if it's a ride or a race. In fact they don't have a great way to deal with this in their system since no one really "owns" KTR. Who is going to apply for a permit for a race they don't own? Who can pay for insurance for people they don't know are coming, at a race/event that has no fee and no organization? They aren't going to bust 2 people racing around slickrock but where do they draw the line? I can see the position that they are in working with the law as it's written. However KTR specifically is more tradition now than ever with MC letting it go. Other than a date/time chosen in the traditional range and using the set of rules used by pretty much every other self supported MC style race, that's all there is. Heck we don't even know who will show up at the start nor does anyone police the race other than ourselves.

I am still planning on showing up and I'm guessing many others are as well. I think we need to continue to show that we are truely self supported and maybe more importantly stewards of the land like MC wrote in his initial emails with the BLM last year. Unfortunately the BLM hasn't replied to the email this year. It would appear that something like the KTR truely does qualify for a SRP waiver based on their rules but again that seems to be at the will of the BLM. Perhaps they are coming to watch over us this year and there can be an open dialogue after the race about granting a waiver in advance next year? Certainly that would be a positive solution for all involved and the future of the event and other events like it. Or perhaps there intentions are more negative I don't know? That would certainly be a shame based on the fact that replies have been made to their inquires.

What I do know is that I want to enjoy the Kokopelli trail with my friends and leave it just as I found it. I hope anyone else showing up feels the same way and acts accordingly.
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Ditto!

Pivvay said:
If you read the BLM website and all the rules, it doesn't matter if it's a ride or a race. In fact they don't have a great way to deal with this in their system since no one really "owns" KTR. Who is going to apply for a permit for a race they don't own? Who can pay for insurance for people they don't know are coming, at a race/event that has no fee and no organization? They aren't going to bust 2 people racing around slickrock but where do they draw the line? I can see the position that they are in working with the law as it's written. However KTR specifically is more tradition now than ever with MC letting it go. Other than a date/time chosen in the traditional range and using the set of rules used by pretty much every other self supported MC style race, that's all there is. Heck we don't even know who will show up at the start nor does anyone police the race other than ourselves.

I am still planning on showing up and I'm guessing many others are as well. I think we need to continue to show that we are truely self supported and maybe more importantly stewards of the land like MC wrote in his initial emails with the BLM last year. Unfortunately the BLM hasn't replied to the email this year. It would appear that something like the KTR truely does qualify for a SRP waiver based on their rules but again that seems to be at the will of the BLM. Perhaps they are coming to watch over us this year and there can be an open dialogue after the race about granting a waiver in advance next year? Certainly that would be a positive solution for all involved and the future of the event and other events like it. Or perhaps there intentions are more negative I don't know? That would certainly be a shame based on the fact the replies have been made to their inquires.

What I do know is that I want to enjoy the Kokopelli trail with my friends and leave it just as I found it. I hope anyone else showing up feels the same way and acts accordingly.
Hopefully there are no issues and everyone who shows can have a killer ride!
mcgurme said:
I am wondering if this could be motivated by complaints from tour operator(s) that do(es) rides on the KTR?
I don't think so - i'm pretty sure i know which tour operator you are talking about.

mcgurme said:
I talked to one such tour operator when I was ordering the updated maps and guide (mine were from the early 90's). He was friendly, but seemed to have the attitude that it was dangerous for me to try to do the KT in a day (maybe 'cause I'm a girl?).
I know this is DEFINITELY not the case becuase you are girl. I'm a girl and I can tell you he has the upmost respect for women and their abilities. if he didn't - i'd beat it into his thick head! :p

mcgurme said:
I could see how a tour operator might interpret this group ride as detracting from marketing the KT in 3-4 days as a "challenging" ride (as the literature on said tour operator's website does).
it's IS a challenging ride. It's a challenging ride for the average joe(tte) blow mtn biker to do in 3 days as he runs it and it's INSANSELY challenging in the TT/no support format of the KTR.

i dare say the 2 types of people that would chose the KTR vs the 3 day support tour are 2 different types of folks.

mcgurme said:
I think an event like this would only boost a tour company's business by getting word out about the trail - it has become clear to me that it is only a small fraction of the population who actually wants to do this kind of thing on their own. But that doesn't mean that all tour operators see it that way...
his 2 spring trips sellout in less then 1 day. he's not hurting for business nor does he feel the KTR detracts from his tour.

mcgurme said:
There must be some kind of motivation driving the BLM inquiries, so it seems that finding that motivation might help determine how to address it.
i understand where you are coming from - it may be it just got so big it's not "under the radar" any more

mcgurme said:
My motivation for posting? Since I got sick and can't join the ride this year, I want to do it next year, and don't want to see the BLM "shutting it down".
I hope you can do it next year too. rock on sister!

as for me - i'm hanging out @ the slickrock trailhead tomorrow afternoon under my ez-up w/my feet propped up eating bon-bons waiting to give my friends a nice cold drink and a hug after a long day in the saddle.
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Perception is Reality

rapwithtom said:
I'm no attorney, and haven't read the BLM language. I have, however, participated in many car "races" (at tracks). These were always called "Driver's Education" for legal and insurance reasons.

This leads me to suggest calling the event something other than "Kokopelli Trail _____". Perhaps "Kokepelli Endurance Education" is better...
Yes. This is key.

I've been part of promoting the Vapor Trail 125 (http://vaportrail125.com) for the past couple seasons. The first year we called it an ultra-endurance race, and we had race officials, ACA sanctioning, and charged a hefty fee. Forest Service permit required that we have Search and Rescue with EMT available on course, ready for crisis.

When we started organizing the 2nd year, our S&R resources fell through. It was pretty much a deal-breaker. We cancelled.

Then we had some candid conversations with ACA and with the USFS. We discovered that, if we waived the entry fee and didn't call it a race, we could have an ACA-sanctioned (and insured) Training Ride. This really reduced the amount of resources we needed to provide, and most importantly it meant that NO USFS permit was required. They just asked us to let them know when it was happening, and cap the numbers to 75.

Since we are a bike shop putting on an event, we need to be insured against liability. But that's really all we need.

We are marking 125 miles worth of course, we are going to have an EMT on call (he'll just be going about his business with a cell phone in his pocket), and we have some friends who've volunteered to set up some aid stations. The event is capped at 30. And the shop owner and his bro-in-law are going to ride motos for 24 hours keeping an eye out for trouble. But that's just stuff we're doing as a courtesy.

So, this is an example of an interaction with the gubmint to put on an event that's a little more official than something like KTR. But only a little more. I'm definitely not advocating that we should all be cooperating with the g-men, especially when the chief executive is a morally bankrupt a-hole (and I say that with all due respect), but if we're going to promote the events AT ALL, there are some things that can be done to keep from getting cross-ways with the civil servants.

My $.02
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Hi BRG,

I'm sure you are right, since you know the chap. I didn't name any particular operators, because it was just a guess and I don't want to cause trouble for anyone (especially since the person in question was very helpful to me, so I'm glad I was wrong). My hypothesis came from a "follow the money" kind of thinking.... i.e. trying to figure out who might have something to loose from the KTR. So even though I am likely wrong about the "who," I do think it would be beneficial to figure out the "why". It is apparent that someone complained after last year's event. Who would stand to benefit from making such a complaint? I don't know the answer, but it seems strange to me that the BLM would be pursuing an anti-KTR effort just for lack of anything better to do. Someone here suggested that it's because this is getting to be a "big" event - but that in and of itself still doesn't say why this would raise a concern or cause a "complaint". It could be as simple as liability/rescue concern, but the "complaint" mentioned in MikeC's correspondences with BLM indicate it might be deeper than that... (conspiracy theorists unite!)

In any case, maybe I'll see you at the slickrock - I had considered showing up there to see some of the finishers come in, cheer them on, and get a preview of what I might look like if I ever do this race!
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