< PREVIOUS ]   [ 2003 Index ]   [ Ed Quillen HOME ]   [ SEARCH ]   [ NEXT >


A little old law behind some big new conflicts

Published 8 June 2003 in The Denver Post.
Copyright ©2003 by Ed Quillen. All rights reserved.

For such a little old federal law, RS-2477 can sure cause some big controversies. It's an old law because Revised Statute 2477 was passed in 1866. It's little law because it's only 19 words long: The right-of-way for construction of highways over public lands, not reserved for public uses, is hereby granted.

Back then, there were no federal land-management agencies. After the United States acquired territory, some land was set aside, or reserved, like an Indian reservation or a military reservation. They're called reservations because they are on reserved lands.

Most of the territory became public domain or public lands, open to homesteading and mining claims, and that was the case when RS-2477 became law in 1866. Basically, it says that if there's a public road constructed across public land, the public's right to use the road remains, even if there's a change in the status of the public land it crosses.

The change might be the creation of a national forest (called a forest reserve a century ago) or the patenting of a mining claim. There might be a homestead, or a land sale, or a national monument or park. The most widespread change came in 1976, with the passage of the Federal Land Policy Management Act, which in effect reserved all public land managed by the federal Bureau of Land Management.

In all those cases, if the road was there before the land left the public domain, then there's a public right-of-way under RS-2477.

But the brevity of RS-2477 makes it open to many interpretations. A highway in 1866, when horses were the dominant transportation in Colorado Territory, doesn't mean the same thing as a highway does now. Construction then certainly didn't mean bulldozers, but did it require more than moving a few rocks? How wide was this right-of-way? And if it was hereby granted, to whom was it granted?

Over the years, some answers have evolved. County governments generally get the right-of-way, its width determined by state law. The rest is more or less up to the U.S. Department of the Interior, and its policies change with elections.

In 1988, the Republican Interior Department defined construction quite loosely: removing high vegetation, moving large rocks out of the way, or filling low spots, as well as the passage of vehicles by users over time, although a pedestrian or pack animal trail may qualify. Generally, all a county had to do was say that it had been a public road before the land was reserved, since a statement by an appropriate public body that the highway was and still is considered a public highway will be accepted.

In 1994, the Democratic Interior Secretary required an on-site examination to determine whether construction of the alleged right-of-way had occurred, and pack trails didn't quality, since an RS-2477 route had to be used by the public for the passage of vehicles carrying people or goods from place to place.

Now we have a Republican Interior Secretary, Gale Norton, and she recently reached to an agreement with Utah concerning how RS-2477 claims will be processed. In some ways it is more restrictive than previous policies -- for instance, there will be no RS-2477 claims inside in national parks, refuges and wilderness areas, even if someone can show that there was a public road across the land before it was reserved. Also, decaying pack trails aren't covered, for the road must be capable of accommodating automobiles or trucks with four wheels and have received regular periodic maintenance.

Interior has said that it wants to make similar agreements with other states, generally consistent with the department's Memorandum of Understanding with Utah.

However, Colorado's relevant laws differ from Utah's. That was stressed by Greg Walcher, director of our state department of natural resources, in a three-page letter to Interior dated May 15. Among other things, he argued that mere passage of vehicles, rather than four-wheeled vehicles and regular maintenance, is enough under Colorado law to support an RS-2477 claim,

This has all sorts of bearing on wilderness designations and the like, but out here in the boondocks, most RS-2477 litigation comes about because some rich outsider buys a ranch, then closes the traditional road to the adjacent public land. Locals who want to preserve their access put pressure on the county to pursue an RS-2477 claim.

So it should be interesting to see how the Bush Administration plays this out. It has a motorized-recreation constituency which wants access. It also has a rich-weasel consistency which wants to keep us peons away from those expensive rural mansions. And there's no way to please both.


< PREVIOUS ]   [ 2003 Index ]   [ Ed Quillen HOME ]   [ SEARCH ]   [ NEXT >