That's one interpretation. Common sense, however, dictates that one would not call a winter recreation area a winter recreation area in the summer. For example, if you had an outdoor ice rink that doubled as a basketball court in the summer, you wouldn't call it an ice rink in the summer, you'd call it a basketball court.
Correspondingly, its not like people only use these areas designated as winter recreation areas in the winter. People use them in the summer too.
The point being, statutes and codes need to be sufficiently clear in order to let people know that they exist. This one here, appears somewhat ambiguous. Hence, a constitutionally vague argument would be appropriate.
Might not work, but worth a shot.