This National Management Strategy was developed by the Bureau of Land Management in 2001 to help deal with Off-Highway Vehicle issues on federal land. It is used as a reference guide in the BLM Policy Manual 1626 for travel management planning.
This strategy is somewhat RS 2477 friendly, suggesting the following on page 9 of this PDF file.
“The BLM completes ORV designations as part of its land-use planning process. In developing land-use plans the BLM takes the following actions relating to ORV use on public lands. . . Applies legal requirements of laws such as FLPMA, National Environmental Policy Act of 1969 (NEPA), R.S. 2477 rights-of-way, valid existing rights, the Alaska National Interest Lands Conservation Act, the Threatened and Endangered Species Act, and the Wilderness Act.”
We know that the Bureau does not follow this process or we wouldn’t need to defend the right to way. It is, however, one small citation that may be referred to during advocacy work.