Thank you for following up on this and posting the official response from the Public Lands Officer.
In keeping with "clarification or confusion" theme we have going here, I would question their designation of the Powderface Road as RDS 780104. I found this in the "Elbow-Sheep Wildland Provincial Park Management Plan, September 1998" document:
Quote:
4.6.2 Access/roads/trails/reclamation
In addition to Highway 40, there is an old forestry road right- of- way in the park (Alberta Transportation RDS 780104); however it has been closed by policy to unauthorized motorized use since 1979. It parallels the Little Elbow and Sheep Rivers and is now used primarily for hiking, mountain biking and horseback riding.
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Link to full .pdf document here:
https://www.albertaparks.ca/media/27...p_mngtplan.pdf
Since Powderface Road was clearly in use for motorized travel prior to 1998, and does not match the location described in the 1998 government document, I would question the validity of the response you received. Because I'm like that when evaluating conflicting information.
In case anyone is curious about the RDS (Provisonal Roadway Reservation) designation, here is a link to the 2013 document:
https://open.alberta.ca/dataset/4ac8...2013-05-13.pdf
Until further information is made available, I agree with your assessment of the 20' rule.