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Red_Chili
08-24-2007, 11:30 AM
BLUERIBBON COALITION LAND USE ADVISORY Greetings BRC members,
New Moab Plan Available
The BLM's Moab Field Office has released their Draft Resource Management Plan (DRMP) and Draft Environmental Impact Statement (DEIS). The combined document is available for download at: http://www.blm.gov/ut/st/en/fo/moab/planning.html (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2198&MID=679&LID=41).
BLM is taking comment until November 30, 2007. Stay tuned for regular email updates and BRC's thorough analysis of the new plan.
Ric Foster
Public Lands Dept. Manager
BlueRibbon Coalition

Red_Chili
08-24-2007, 01:04 PM
I am noticing all around the country, with the OHV rule in particular, tens of thousands of miles of trails and roads are proposed for closure. Without a doubt we need to sharpen our letter writing pencils and hammer on our typewriters like never before, this thing is taking us on with a VENGEANCE!

MDH33
08-24-2007, 01:43 PM
Haven't read it yet but I downloaded the pdf.

timmbuck2
08-24-2007, 02:04 PM
uhhh...I have a question.....what's a typewriter?? :confused:


:D

T



I am noticing all around the country, with the OHV rule in particular, tens of thousands of miles of trails and roads are proposed for closure. Without a doubt we need to sharpen our letter writing pencils and hammer on our typewriters like never before, this thing is taking us on with a VENGEANCE!

MDH33
08-24-2007, 03:01 PM
I am noticing all around the country, with the OHV rule in particular, tens of thousands of miles of trails and roads are proposed for closure. Without a doubt we need to sharpen our letter writing pencils and hammer on our typewriters like never before, this thing is taking us on with a VENGEANCE!

I did a precursory perusal of the document and none of the alternatives sounds as bad as you might initially think. The "closures" are mostly areas that will have existing routes re-named as "designated routes" instead of an entire area being "open" to cross-country/off-trail travel. This is the same philosophy our club adheres to with "stay on the Trail" and "Tread Lightly".

I plan on digging deeper when time allows and will definitely be writing a letter.

Red_Chili
08-24-2007, 03:26 PM
I did a precursory perusal of the document and none of the alternatives sounds as bad as you might initially think. The "closures" are mostly areas that will have existing routes re-named as "designated routes" instead of an entire area being "open" to cross-country/off-trail travel. This is the same philosophy our club adheres to with "stay on the Trail" and "Tread Lightly".

I plan on digging deeper when time allows and will definitely be writing a letter.
I too oppose cross-country travel, but this approach adopted black and white kills desert motorcycle racing, for instance, and you can say goodbye to sand play as well - such as the sand dunes enjoyed by our club. So there are unintended (or intended?) consequences to a broad, no loopholes policy.

But regards losing tens of thousands of miles of routes nationally, that is no exaggeration: in New Mexico, for instance, the Coconino National Forest stretches over 1.8 million acres of forested lands. Currently, there are thousands of miles of road and hundreds of miles of trail that are being used by folks from all over Arizona. These trail miles are being reduced to 25.5 miles. To close all trails but a paltry 25.5 miles is an outrage. All as a result of the OHV Rule, which seems to be being interpreted as an opportunity to close OHV routes rather than inventory them.

It is happening in Taylor Park. In the Gunnison. Right in our backyard.

If we snooze, if we say "oh, well, I don't visit there" or "I don't ride a motorcycle/don't ride an ATV/ don't like 'em anyway", or "it's probably for the best environmentally", we will lose our favorite routes.

The land manager's motivation is to get the routes - with their cost and controversy - off his/her books. Without having to inventory them, as mandated, because they have no funds to do so.

Lose lose. We lose.

Red_Chili
08-27-2007, 01:42 PM
More info...
________________________________
Moab BLM'S Draft Resource Management Plan
and Draft Environmental Impact Statement AT A GLANCE:
Moab BLM's website is pretty easy to navigate. Check http://www.blm.gov/ut/st/en/fo/moab/planning.html (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2211&MID=684&LID=41) for the complete Draft RMP and Draft EIS as well as all the background documents.
Comments may be submitted electronically at: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to: Moab Field Office RMP Comments, Bureau of Land Management, Moab Field Office, 82 East Dogwood, Moab, Utah 84532. To facilitate analysis of comments and information submitted, we strongly encourage you to submit comments in an electronic format.
NOTE:
Please do not send the overworked and underpaid BRC staff emails complaining that the maps are un-readable. We know. If you contact the BLM regarding this, please be polite. We are working with Moab BLM to find a solution.
Brief Description of an EIS
Chapter 1 is the Purpose and Need, where BLM is supposed to define specific areas where management needs to be changed. Chapter 1 also describes the Planning Issues and Planning Criteria.
Chapter 2 is a detailed description of the Alternatives.
Chapter 3 is the Affected Environment section where the agency described the current condition and existing management.
Chapter 4 is the environmental analysis.
Chapter 5 describes the public involvement, consultation and coordination.
Key Sections of the Document:
It will be helpful to review the Dear Reader (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2212&MID=684&LID=41) letter and the Executive Summary (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2213&MID=684&LID=41). The Executive Summary is worth review and gives a brief description of the "theme" of the Alternatives, but it won't give you much detail.
Chapter 2 (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2214&MID=684&LID=41) describes the Alternatives and includes the "matrix" (pages 2-7 through 2-56). The matrix is a comparison of how each Alternative addresses the key issues. Important sections include "Recreation" (pages 2-17 through 2-20) and "Travel Management" (pages 2-48 through 2-50). This will be a lot easier to understand if you print and reference maps 2-8 A through D as well as 2-9 B through D. (Don't miss the description of how BLM addressed SUWA's "Red Rock Heritage Travel Plan Alternative" on page 2-107.)
Also important are the Recreation Rules in Appendix E (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2215&MID=684&LID=41), where you will find the Moab BLM's policy on Dispersed Camping and other activities.
Appendix G (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2216&MID=684&LID=41) is the explanation of how the Moab BLM developed the Travel Plan. It will help if you can print and reference the following maps:
Maps 2-10 A through D
Maps 2-11 B through E
Maps 2-11-F B through D
The very brave will want to view Appendix F (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2217&MID=684&LID=41), the Special Recreation Management Areas (SRMA). But making sense of all of the various "overlays" isn't for the faint of heart!
Appendix F is a critical section. But the way the BLM is managing the SRMA's is unnecessarily confusing. Pay close attention! You'll need to fully understand the difference between Physical and Administrative management zones (Primitive, Back Country, Middle Country, Front County and Rural), Goals, Settings and Outcomes. The final step is to overlay all of that with the travel management program and see if it makes any sense at all. Again, you'll need maps 2-8 A through D.
Advanced level Access Advocates may want to review the "lands with wilderness character" and Areas of Critical Environmental Concern sections. (Chapter 2, pages
2-16 through 2-17, Appendix P and Maps 2-24 B and C for lands with wilderness character. ACEC's are on pages 2-33 through 2-39. Reference maps 2-14 A through C.)
Long time BRC members probably just felt a chill down their spines. The "lands with wilderness character" business is the legacy of Bruce Babbitt and his illegal effort to double the amount of Wilderness Study Areas in Utah. It's a long story, and we'll post details on our Moab Update webpage soon. But it is a key problem for recreation, and not just for motorized recreation. This is because some recent BLM plans require the agency to "enhance" wilderness character, instead of say, "maintain" or "protect against significant impacts." What this means is that eventually, these lands will be managed as Wilderness.
De-facto Wilderness. Nice....
That's why BRC and other multiple use stakeholders oppose this designation altogether. Let me be perfectly clear. Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of the Federal Land Policy and Management Act (FLPMA). Congress instructed the agency to inventory all of their lands, identify which were definitely not of wilderness quality and then to begin an intensive inventory and analysis to determine which of the remaining lands would be recommended for inclusion into the National Wilderness Preservation System.
The process was completed in 1991. All stakeholders (including Wilderness Advocacy Groups) have exhausted the protest and appeal options. After 10 years the "603 Process" left Utah with approximately 3.2 million acres designated as Wilderness Study Areas. Of those, approximately 1.9 million acres were deemed "suitable and manageable" and were recommended to Congress for Wilderness designation. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for inclusion in the National Wilderness Preservation System, subject to existing uses.
There is no justification, no legal mandate and no process requirement for engaging in an ongoing, never ending wilderness inventory and review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American People. Other than the management of existing WSAs, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
IMPORTANT INFO ABOUT MAKING COMMENTS:
Your comments on the Alternatives are extremely important. But the BLM is saying comments containing only opinion or preferences will be considered and included as part of the decision making process, but they will not receive a formal response from the BLM.
Comments will be most helpful if you can state specifically what you like and what you don't like about each of the Alternatives. Suggest changes and be specific. Include information, sources, or methodologies if possible. Also, it is good if you can reference a section or page number.
BLM is also encouraging feedback concerning the adequacy and accuracy of the four proposed alternatives, the analysis of their respective management decisions, and any new information that would help the BLM produce a Proposed Plan.
Comments may be submitted electronically to: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to: Moab Field Office RMP Comments, Bureau of Land Management, Moab Field Office, 82 East Dogwood, Moab, Utah 84532. To facilitate analysis of comments and information submitted, we strongly encourage you to submit comments in an electronic format.

Uncle Ben
08-28-2007, 08:33 AM
Another blip....don't ignor this.....it's just like your right to vote!


The Moab Draft Resource Management Plan (DRMP) is now available!



This document will determine how motorized recreation is managed in Moab for the next 15-20 years. Closures to cross-country travel areas and some existing routes are recommended in most of the alternatives. BRC, USA-ALL, U4WDA, RR4W and others are working on analyses of the DRMP, and more specific information will be available soon.



The comment period extends through November 30th. There are also 4 public meetings. Moab on 9/25, Monticello on 9/26, Grand Junction on 9/27 and Salt Lake City on 10/3. It is important that the motorized recreation community makes a strong showing with both comments and attendance at these meetings (full schedule and details available at http://www.usaall.org/moab).



Mail comments to:

Bureau of Land Management

Moab Field Office

RMP Comments

82 East Dogwood

Moab, UT 84532

435-259-2100



Email comments to:

UT_Moab_Comments@blm.gov



To view the full DRMP, visit:

http://www.blm.gov/ut/st/en/fo/moab/planning/draft_rmp_eia.html



For more information, visit:

http://www.usaall.org/moab

Red_Chili
10-12-2007, 12:40 PM
BLUERIBBON COALITION LANDUSE UPDATE! Dear Moab Partner,
A couple of recent news reports and "op-eds" about the Moab RMP and Travel Plan appeared recently in the Utah media and it motivated me to send out a quick email update.
There is a lot of talk about whether or not the Moab BLM will extend the November 30, 2007, comment period, and both the Deseret News and Salt Lake Tribune responded to a Southern Utah Wilderness Alliance media release.
See:
Study period: BLM should allow more time to review Moab plan
http://origin.sltrib.com/ci_7129206 (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2442&MID=730&LID=41)
More comment time sought on Moab plan
Critics say OHV proposal doesn't go far enough
http://deseretnews.com/article/1,5143,695212955,00.html (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2443&MID=730&LID=41)

Interestingly, BRC was contacted by the Tribune's editorial board confirming whether or not BRC had requested an extension. They said they had been told we had done so.
In fact, we have not. And the reason is because of you! Because of our Moab Partners we were geared up and ready for this one no matter what the deadline was.

QUICK MOAB PARTNER UPDATE:
Our review of the DEIS is almost complete. We are also getting information from key stakeholders such as Ber Knight, from the Red Rock Four Wheelers (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2445&MID=730&LID=41), as well as other key individuals and groups.
Speaking of that, BRC wants to send a special thanks to Utah Four Wheel Drive Association (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2446&MID=730&LID=41) for getting info out . Many thanks also to Clif Koontz and Dale Parriott from RwR (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2447&MID=730&LID=41) and Elite Motorcycle Adventures (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2448&MID=730&LID=41) respectively. Koontz and Parriott have made many excellent suggestions and it's awesome to see such enthusiastic local involvement.
Our goal is to have our review of the DEIS finished by October 17, 2007. It will take a couple of days then to formulate a BRC Moab Action Alert using that review. That would give us just enough time, even if the deadline is not extended, to get the word out to our members and get comments into the BLM.
We are going to have to rely on our Moab Partners to help get our Moab Action Alert out to interested folks. So.... please forward our Moab Action Alert to as many interested folks as you can.

SPECIAL MESSAGE FROM BRC'S PUBLIC LANDS GUYS:
We want to (again) express our gratitude to you folks. The Moab Partner program took in $28,899.27 to date. AWESOME!!
Now, this is far short of our budget of $90,000. But, it was enough to hire two biologists to review the analysis as well as to pay for a full legal review of the entire document.

A BIT OF INSIDE BASEBALL FOR OUR MOAB PARTNERS:

Our priority is review of the specific language contained in the plan. My favorite example is where the Moab BLM says campsites may (will) be closed when impacts become "obtrusive." Of course, the term "obtrusive" does not occur in any of the BLM's planning regulations. BRC gives the Moab BLM credit for having the chutzpah to attempt to define the term in their document, however. Moab BLM says "obtrusive" can refer to "any or all of the following problems: human sanitation, trash, hacked trees, trampled vegetation and fire danger from excessive campfires."
I want to know how in the world anyone could pitch a tent and enjoy a desert evening sunset without trampling some vegetation??? Unbelievable. I could go on and on because this sort of thing is prevalent throughout the document, but I hope you understand how dangerous such language can be.
Because of our fundraising shortfall, we cannot afford at this time to review soils and vegetation data. BRC hopes to do additional fundraising in the coming weeks, but we are considering "deficit spending" if our DEIS review indicates it is needed.
As far as the additional fundraising needs goes, BRC is considering a Club/Organization/Business level for the Moab Partnership. This was a controversial idea because nobody at BRC wanted to diminish or "cheapen" the commitment our Moab Partners have already made. That is why our Club/Organization/Business level will be at a $1,200.00 yearly enrollment.
That's going to be pretty expensive for some clubs that would like to join. But your willingness to join at the full-boat $120.00 yearly level early on, before the DEIS was released, enabled us to really jump into this plan. There is no way we are going to diminish or cheapen that commitment by offering a discounted rate.
If you have any comments about the Club/Organization/Business level, or ideas that would help BRC fully fund our Moab effort, please let me or Ric Foster know.

A BIT ON WHAT KIND OF COMMENTS NEED TO BE MADE:
I noted a couple of OHV Internet bulletin board posts that suggested a "vote" for Alternative D. I want to caution about that sort of comment. DON'T DO IT!
The Moab BLM has (way too) cleverly formulated Alt B (green) and alt D (not as green) so that neither is a viable alternative. Add to that the Moab BLM's preferred Alt C contains many serious problems and one or two fatal flaws. This makes public comments that ONLY express a preference for an Alternative totally ineffective.
I will also add that this DEIS is actually two plans; an RMP and a Travel Plan. There is no doubt that Alt D's Travel Plan is preferable, but the Alt D's RMP is totally unworkable. Thus the need to avoid the "I vote for Alternative X" type of comment.

STILL MORE UPDATE INFO:
Many folks have emailed wanting to know if there is anything they can do now to help BRC with this effort.
YES!
If you recreate in Moab, we would ask you to take a look at just a few sections of the DEIS and let us know your reaction. Below is a section from BRC's previous alert that will help you find the important parts of the BLM's documents.
If you have time, it would be great if you could take a few minutes and review the information and then send Ric and Brian your thoughts/concerns/ideas.
Thanks again for you involvement and your generous financial support. As always, please call or email with questions or concerns.
Brian Hawthorne
Ric Foster
BlueRibbon Coalition
Office Number (208) 237-1008 EXT 107
Brian's email brbrian@sharetrails.org
Ric's email brrichard@sharetrails.org
Moab BLM'S Draft Resource Management Plan
and Draft Environmental Impact Statement
AT A GLANCE:
Moab BLM's website is pretty easy to navigate. Check http://www.blm.gov/ut/st/en/fo/moab/planning.html (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2449&MID=730&LID=41)for the complete Draft RMP and Draft EIS as well as all the background documents.
Comments may be submitted electronically at: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to: Moab Field Office RMP Comments, Bureau of Land Management, Moab Field Office, 82 East Dogwood, Moab, Utah 84532. To facilitate analysis of comments and information submitted, we strongly encourage you to submit comments in an electronic format.
Brief Description of an EIS
Chapter 1 is the Purpose and Need, where BLM is supposed to define specific areas where management needs to be changed. Chapter 1 also describes the Planning Issues and Planning Criteria.
Chapter 2 is a detailed description of the Alternatives.
Chapter 3 is the Affected Environment section where the agency described the current condition and existing management.
Chapter 4 is the environmental analysis.
Chapter 5 describes the public involvement, consultation and coordination.
Key Sections of the Document:
It will be helpful to review the Dear Reader (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2450&MID=730&LID=41) letter and the Executive Summary (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2451&MID=730&LID=41). The Executive Summary is worth review and gives a brief description of the "theme" of the Alternatives, but it won't give you much detail.
Chapter 2 (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2452&MID=730&LID=41) describes the Alternatives and includes the "matrix" (pages 2-7 through 2-56). The matrix is a comparison of how each Alternative addresses the key issues. Important sections include "Recreation" (pages 2-17 through 2-20) and "Travel Management" (pages 2-48 through 2-50). This will be a lot easier to understand if you print and reference maps 2-8 A through D as well as 2-9 B through D. (Don't miss the description of how BLM addressed SUWA's "Red Rock Heritage Travel Plan Alternative" on page 2-107.)
Also important are the Recreation Rules in Appendix E (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2453&MID=730&LID=41), where you will find the Moab BLM's policy on Dispersed Camping and other activities.
Appendix G (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2454&MID=730&LID=41) is the explanation of how the Moab BLM developed the Travel Plan. It will help if you can print and reference the following maps:
Maps 2-10 A through D
Maps 2-11 B through E
Maps 2-11-F B through D
The very brave will want to view Appendix F (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2455&MID=730&LID=41), the Special Recreation Management Areas (SRMA). But making sense of all of the various "overlays" isn't for the faint of heart!
Appendix F is a critical section. But the way the BLM is managing the SRMAs is unnecessarily confusing. Pay close attention! You'll need to fully understand the difference between Physical and Administrative management zones (Primitive, Back Country, Middle Country, Front County and Rural), Goals, Settings and Outcomes. The final step is to overlay all of that with the travel management program and see if it makes any sense at all. Again, you'll need maps 2-8 A through D.
Advanced level Access Advocates may want to review the "lands with wilderness character" and Areas of Critical Environmental Concern sections. (Chapter 2, pages 2-16 through 2-17, Appendix P and Maps 2-24 B and C for lands with wilderness character. ACECs are on pages 2-33 through 2-39. Reference maps 2-14 A through C.)
IMPORTANT INFO ABOUT MAKING COMMENTS:
Comments will be most helpful if you can state specifically what you like and what you don't like about each of the Alternatives. Suggest changes and be specific. Include information, sources, or methodologies if possible. Also, it is good if you can reference a section or page number.
BLM is also encouraging feedback concerning the adequacy and accuracy of the four proposed alternatives, the analysis of their respective management decisions, and any new information that would help the BLM produce a Proposed Plan.
Comments may be submitted electronically to: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to: Moab Field Office RMP Comments, Bureau of Land Management, Moab Field Office, 82 East Dogwood, Moab, Utah 84532. To facilitate analysis of comments and information submitted, we strongly encourage you to submit comments in an electronic format.

Red_Chili
11-02-2007, 01:05 PM
Here is an important summary of information so far, with analysis, and a request for more information:
http://www.sharetrails.org/uploads/PL/BLM/MOAB/Comment_Survey.pdf

Of course, this was sent to any who donated as Moab Partners by giving just a bit of pocket change to the effort via the Blue Ribbon Coalition, so most of you already know about it... RIGHT??

If you don't, please visit www.sharetrails.org to donate!

I frankly don't feel 'expert' enough about the issues raised to advise. So your input is requested!

Red_Chili
11-06-2007, 08:37 AM
PLEASE take the time to read this and compose a letter. Form letters are useless in this sort of comment. So compose one based on this info!
I know, I know... I don't have time either!
_______________________________________________
Dear BRC Action Alert Subscriber,

There are exactly 25 days left to comment on the Moab BLM RMP and Travel Plan.

The clock is ticking. There will be no comment extension on this one.

This Action Alert is designed to help you formulate your comment letter on this important plan. We are asking our members who have enjoyed the spectacular trails in Moab, or think they might sometime in the future, to read this alert and begin today to write your comment letter.

There will be no "click and send" action alert from BRC on this one. That's because the BLM has "rigged" the process and the Alternatives so that a comment that says something like "I vote for Alternative D" will not work.

But we've taken a lot of time to look hard at what the Moab BLM is proposing so you don't have to wade through thousands of pages to figure out what they are proposing and how to comment.

In order to help you write your comment, we've taken all the important parts of the DEIS and compiled them in summaries available via hyperlinks below. There are several key issues that folks need to be aware of and comment on, so we also have formulated some specific comment suggestions on the most important issues (see below).

If you find yourself lacking motivation here, just take a second to look at the effort those anti-recreation zealots over at SUWA have put into this Moab plan. (http://www.suwa.org/) SUWA's Executive Director has moved to the Moab area and their staff of attorneys is making a very strong push to eliminate most of the OHV use in the region. Their effort is professional and it is strategically designed to supplement SUWA's foundation-funded legal and political efforts.

Hey, that's what you get when you have 2 million samoleans-per-anum to work with!!

Trust us on this: this effort by SUWA is a serious problem for you, if you use a vehicle for recreation in Moab. Like our ad says: "These guys want to rub you out!"

Please read this Alert, click the links and check out the maps and other materials. Bookmark the important sites, as updates will be added right up to the comment deadline. Forward this Alert to your friends, family, club land-use officers and your ridding buddies.

We put a lot of effort into making the Moab BLM's plans easy to understand. Once you click the links and check out our comment suggestions, you'll know what to do. It won't be difficult.

But if you have any questions, concerns, or just need some help writing a comment letter -- please call.

Brian Hawthorne
208-237-1008 ext 102
Ric Foster
208-237-1008 ext 107

SITUATION:

The Draft Resource Management Plan (DRMP) and Draft Environmental Impact Statement (DEIS) for the Utah Bureau of Land Management (BLM) Moab Field Office has been released for public review and comment.

In addition to a new RMP, Moab BLM will be formulating a Travel Plan for motorized vehicles and mountain bikes. Travel will be limited to designated roads, trails and areas.

The BLM has set a deadline of November 30, 2007, for receiving information and comments pertaining to the Alternatives and the analysis presented in the DEIS. Feedback regarding the four proposed alternatives will be used to formulate a Proposed Resource Management Plan, and ultimately, a Final Resource Management Plan and Travel Plan.

Comments and other information may be submitted electronically at: UT_Moab_Comments@blm.gov.

Comments and other information may also be submitted by mail to:
Moab Field Office RMP Comments
Bureau of Land Management
Moab Field Office
82 East Dogwood
Moab, UT 84532


INFORMATION ON THE WEB:

BLM information and documents:
The Moab DRMP/DEIS and supporting information is available on the project web site at: http://www.blm.gov/ut/st/en/fo/moab/planning.html.

BlueRibbon Coalition Resources:
http://www.sharetrails.org/alertlist/subscribeform.cfm
http://www.sharetrails.org/public_lands/
http://www.sharetrails.org/public_lands/?section=MoabUpdate

What the anti-access groups are doing:
http://www.suwa.org/site/PageServer?pagename=work_moabrmp


WHAT YOU NEED TO DO:

For maximum effectiveness:
1) Using the information provided from BLM and BRC's websites, as well as the info and the comment suggestions below, write a comment letter addressing Issues and Alternatives presented in the DEIS.

2) Copy your letter to your political representatives. Snail mail works best. Pen a quick personal note to your politico's staff and make sure they know you are PRO access, that you visit the area and that you oppose both the rhetoric and the proposals of the so-called "environmental groups." Find the address of your politico's here: Rapid Response Center (just enter your zip code)

3) 'CC' your comments to BRC
CC your comments to BRC at brlandsinfo@sharetrails.org. In the Subject line please put Moab RMP Comments.

Extra Credit:
Comments will be most helpful if you can state very specifically what you like and what you don't like about each of the Alternatives. Suggest changes. Also, it is good if you can reference a section or page number.

IMPORTANT NOTE:

Yes, this IS worth the time and effort to write a good comment letter. Public comment is extremely important and will help to move the Final Plan toward something that's good for the recreating public. Individual comments like yours will also serve as a foundation for groups like BRC to challenge any arbitrary or unfair closures, as well as defend the inevitable attack from SUWA's lawyers.

If at all possible, your letter should address these issues (please see comment suggestions below):

* Comments regarding the Alternatives -- (please note that Alternative A (no action) is not an "action alternative." So the "I vote for Alternative A" comment will be a waste of time and effort.
* Comments about specific roads, trails and areas to be designated for motorized and mountain bike use, and responses to specific questions associated with BLM's #1 formal Planning Issue: "How can increased recreation use, especially motorized vehicle access, be managed while protecting natural resource values?"
* Comments on Special Recreation Management Areas (SRMA)
* Comments on Dispersed Camping
* Comments on White Wash Sand Dunes
* Comments on ATV Trails
* Comments on Mountain bike trails/areas
* Comments regarding special designations such as ACECs, Wild and Scenic Rivers and "Lands with Wilderness Character"

COMMENT SUGGESTIONS:

Comments may be submitted electronically to: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to:
Moab Field Office RMP Comments
Bureau of Land Management, Moab Field Office
82 East Dogwood
Moab, Utah 84532.

Note:
A good comment letter starts with a brief paragraph about yourself and a bit, about what you like to do when you visit the Moab field office.

____________________________________________________________________________

Issue: Comments about specific roads, trails and areas to be designated for motorized and mountain bike use.

Comment Suggestions:

BRC has several detailed maps for download that, for us anyway, are a lot easier to read. Click here, download the maps and talk amongst your friends, family and riding buddies.

NOTE:
Any specific comment on any road or trail, whether proposed as open or closed, is useful and we believe taking the time and effort to do so will be very worthwhile.

____________________________________________________________________________

Issue: There is not a true range of management options in the Alternatives

Simply stated, there just isn't much difference between the "Action Alternatives." And, both Alt. B and Alt. D are completely unworkable as written, which naturally makes BLM's Preferred Alternative the only "reasonable choice." The motorheads in the BRC Public Lands Department will forgive you if you think the BLM did that on purpose.

Finally, there are actually a bunch of alternatives here that the public should be commenting on. There are the three action alternatives for the RMP, then there are three action Alternatives for the Travel Plan, and there are an additional two alternatives for motorcycle (and ATV) trails.

Sheesh, BLM... how is the general public supposed to be able to figure all this out, especially when you give only a cursory discussion of the difference between the RMP and the Travel Plan in your own document?

Comment Suggestions:

* The fact that comments are needed on Alternatives for the RMP and the Alternatives for the Travel Plan is not made clear in the document.
* The difference between an RMP (general guidance) and the Travel Plan (implementation decision) is not clearly described in the DEIS. The FEIS should clearly articulate the difference.
* None of the Alternatives presented are acceptable as they stand, including the Preferred Alternative C, which mandates unworkable and impractical management of camping and motorized travel. In addition, in all of the Alternatives, management for the White Wash Sand Dunes is fatally flawed and must be reconsidered (see comment below).
* Alternative D fails to provide a true motorized focus.
* Tell the BLM that you are concerned that many of the restrictions in all of the Action Alternatives are simply not justified. Tell the BLM that the FEIS should clearly draw a connection between the facts on the ground and the decision made.

____________________________________________________________________________

Issue: White Wash Sand Dunes management plan is totally unacceptable and unworkable (BRC details here)

Months ago, when we blasted our Moab Update information to our members and supporters, we made fun of the BLM's management proposal for the White Wash Sand Dunes.
Months ago, when we blasted our Moab Update information to our members and supporters, we made fun of the BLM's management proposal for the White Wash Sand Dunes.

BLM's draft plan bans nearly all camping until (if) they get around to constructing a developed campground and would also implement a "fee system using individual Special Recreation Permits." The Draft Plan also requires fencing around all of the Cottonwood trees and "water sources" around the Dunes.

After meeting with the planning team and learning they are absolutely serious about that, I guess we aren't laughing anymore.

Comment Suggestions:

* BLM's open area in Alternative C and D must be expanded. The current proposal is unworkable because it confines a huge amount of vehicle use into a very small area and the area's boundaries are not well defined and cannot be easily identified on the ground.
* Requiring fences around the cottonwood trees and "water sources" is both impractical and unnecessary. We strongly oppose this provision of the Draft Plan.
* BLM's open area at White Wash Sand Dunes should include the popular and challenging hill-climb on the Northwest of the Sand Dunes.
* BLM's open area should be located along easily identified geologic features, or preferably along boundary roads of Ruby Ranch Road on the West, Blue Hills Road on the North, and Duma Point/Ruby Ranch (back way) on the East.
* You oppose the fee system contemplated in Alternatives C and D. Fee systems are inherently controversial and often unpopular with the recreating public. The Final RMP should not require a fee system. However, if funding for infrastructure needs cannot be met with existing funding and grant programs, then a fee system should be implemented only with the full involvement of the Recreational Fee Advisory Council and the affected user group.
* Because the open area boundary will not be easily identifiable on the ground, and also because of easy access to the proposed "fee area" from all directions, it will make this proposal extremely difficult to enforce. We suggest the BLM consider other funding mechanisms to pay for needed management infrastructure.

____________________________________________________________________________

Issue: Is BLM propsing a "close first - mitigate last" approach to OHV use?
In BLM's #1 Issue they ask: *Where should adaptive management practices be applied in response to unacceptable resource impacts?

Given the popularity of Moab for recreation, and the fact that large areas are proposed to be off limits to most recreational users, considering NOT applying adaptive management practices to mitigate impacts is, well, not logical.

Comment Suggestions:

* The Final RMP should mandate that adaptive management practices be used across the Field Office
* The Final RMP should direct that mitigation efforts will be exhausted prior to closure
* The Final RMP should direct land managers to work with the affected public to ensure all available mitigation efforts have been exhausted before closure.
* When using adaptive management principles, The RMP should mandate the mitigation of closing routes and areas to recreational use by designating a more sustainable, but similar recreational opportunity elsewhere.

____________________________________________________________________________

Issue: BLM states the 'user conflict' issue as a question: How should recreational uses be managed to limit conflicts among recreational users? (Read BRC's favorite statement on conflict by Art Seaman)

Contrasting the SRMA and Focus Areas with the Travel Plan indicates that Moab BLM's preferred answer is to create "exclusive use zones."

Providing opportunity for a non-motorized recreation experience is great, but by imposing a near categorical exclusion of other uses it removes the ability to designate key motorized uses that are needed in a well managed road and trail system.

Comment Suggestions:

* When addressing "user conflict," the Final RMP should avoid "exclusive use zones" where, based on perceived or potential "user conflict," one or more "conflicting uses" is categorically prohibited.
* Most of the non-motorized focus areas have designated routes open to motorized vehicles within them. If implemented as written in Alternatives B, C and D, many visitors will perceive these focus areas as establishing blanket restrictions on motorized use. The unintended consequences will likely result in increasing, not reducing actual or perceived "user conflict."
* In order to address the "user conflict" issue, the Final RMP should direct land managers to educate the non-motorized visitors (who may perceive conflict with motorized uses) where they may encounter vehicle traffic in certain areas as well as informing them of areas where they may avoid such encounters.
* The Final RMP should direct land managers to educate vehicle-assisted visitors of where a road or trail might be shared with non-motorized visitors, and if appropriate, direct slower speeds.
* The Final RMP should direct land managers to re-route either use so as to avoid sections of roads or trails that are extremely popular with both groups. For example, a hiking trail can be constructed to avoid a section of popular OHV route. Or an equestrian trail may be constructed to avoid a section of popular mountain bike route, etc.

____________________________________________________________________________

Issue: Moab BLM is closing a huge number of dispersed campsites. (See BRC's details on BLM's proposal)

Because vehicles are not permitted to travel off designated routes - for any reason - the Moab BLM is proposing a "vehicle camping only in designated campsites" in the entire Field Office. Such a restrictive policy would be appropriate for National Parks or National Monuments, but for Public Lands this is truly unheard of.

Moab BLM staff argues that the impacts from dispersed camping warrant such restrictions, and claim that their Travel Plan kept open the route to nearly every existing vehicle campsite. They say that most every campsite that did not have a "resource problem" remained open. Our review says different, and we believe hundreds of campsites currently being used could be closed.

Comment Suggestions:

* Tell the BLM that you oppose the camping policy as outlined in Appendix E.
* The Final EIS should disclose how many campsites would be closed under each Alternative.
* Tell the BLM that you support a policy where existing campsites are open unless determined closure was necessary via lawful public planning process.
* Tell the BLM that it is very important that the Final RMP mandate full public involvement in any establishment and management of "restricted camping areas" or "controlled camping areas."
* Finally, and perhaps more importantly, check the BLM's maps (http://www.blm.gov/ut/st/en/fo/moab/planning/draft_rmp_eia.html) to see if YOUR favorite campsite will be closed (see if a road is designated right up to the campsite). If you can't tell from BLM's maps, you need to tell them that!

____________________________________________________________________________

Issue: Special Recreation Management Areas

There are some "Action Alert" type comments below, but if you have the time we think it would be well worth the effort to review the BLM's proposal and give them your input.

Frankly, a lot of what they propose makes a creepy sort of sense. But there are "poison pills" that (unnecessarily) make future management uncertain. In other words, if BLM doesn't write this plan right, SUWA will be litigating them (and us) to death.

Check our info as well as BLM's proposals. Quick links and page numbers are provided to make it easy.

Comment Suggestions:

*
The Travel Plan and the Administrative Setting must be consistent in all SRMAs!
*
All SRMAs with a motorized focus should include direction regarding when and how additional or expanded routes/areas would be provided should there be a need.
*
SRMAs and their "focus areas" should avoid excluding other uses categorically. The Preferred Alternative clearly shows Moab BLM recognizes the importance of providing some motorized routes in non-motorized "zones."
*
The Utah Rims SRMA is necessary to properly manage this popular area. It should have a motorized and mountain bike focus, and include the ability to designate or construct routes should they be needed in the future. In addition, limiting camping to one small designated area, in the RMP, is not wise. The RMP should provide general direction and not limit camping in such a way.
*
The Utah Rims SRMA should extend further southwest to encompass Mel's Loop and beyond. Increased visitation there warrants the more active management of a SRMA. This larger area would also provide enough room for a full-day's motorcycle ride, and the establishment of a mountain bike focus area.
*
Yellowcat is increasingly popular for four wheeling and ATV riding. Designating a SRMA there would utilize the dense network of mine roads that already exist.

____________________________________________________________________________

Issue: Although many popular ATV routes are classified as roads in Moab BLM's Travel Plan, some ATV trails are not proposed as open and some of the Motorcycle routes should be designated as ATV/Motorcycle trails as well.

Staff at the Moab office seem to realize the error in their so-called "motorcycle maps" (e.g. no ATV trails). Thankfully, "Action Alert" type comments are relatively easy on this issue because Clif Koontz, with Ride with Respect, has been working with key ATV leaders and identified what we think is a really good proposal. Clif will have specifics soon, and we'll update you on those as soon as possible.

Comment Suggestions:

*
Some of the "motorcycle trails" are very popular with ATV users. The Final Travel Plan should designate a mix of single track and ATV trails.
*
The FEIS should consider designating more ATV trails, especially between White Wash and Red Wash. We strongly suggest looking closely at the proposal developed by Ride with Respect.

____________________________________________________________________________

Issue: In the Moab Field Office, true mountain bike single track trails are in short supply.

Comment Suggestions:

*
The Mill Canyon - Sevenmile Rim biking focus area should be redrawn as Mill Canyon -Tusher Rims in order to provide better terrain for pedaling.
*
The Final Plan should extend the South Spanish Valley biking area further south toward Black Ridge.

____________________________________________________________________________

Issue: Though 'stay on the trail' is a critical policy for most places, recreationists need a few distinct areas for open-riding.

In 1.8 million acres, White Wash is not quite enough.

Comment Suggestions:

*
An open area in addition to White Wash could provide different terrain for everything from bicycle free riding, to trials motorcycling, to hardcore rock crawling. As 99% of the Moab Field Office becomes limited to designated routes, open areas play an even more critical role for accommodating specialized sports. Perhaps parts of Black Ridge could remain unrestricted for this purpose.
*
The Sand Flats Recreation Area could adopt special policies to permit slickrock exploration. We support Ride with Respect's recommendation that mountain bike travel be allowed on any barren rock surface. Slickrock within one hundred yards of a designated route could be open to motorized travel. This two-hundred yard corridor would accommodate the ways that people currently enjoy Sand Flats.

____________________________________________________________________________

Issue: Some important motorcycle trails are missing from all alternatives.

The preferred alternative includes about 100 miles of true motorized single-track. Alternative D adds another 100 miles. But in total, the final plan should spare roughly 300 miles of non-road motorcycle routes from being closed.

Comment Suggestions:

*
Alternative D falls just short of providing sufficient motorcycling opportunities. Since no single-track inventory was performed, the BLM should continue accepting data on existing routes, and consider them for implementation.
*
The Utah Rims single-track network should include at least 25 miles of additional routes, in order to be as complete as the Dee Pass network.
*
In particular, long-distance single-tracks and rugged roads that connect SRMAs offer a unique experience. The Copper Ridge Motorcycle Loop should be combined with Thompson Trail in the final plan.
*
A few more non-riparian washes should be left open, especially in the Cisco Desert. These travel-ways provide ATV and motorcycle riders an unconfined challenge that roads cannot.

____________________________________________________________________________

Issue: In an incredible show of chutzpah, the Moab BLM has included the White Wash Sand Dunes as a proposed Area of Critical Environmental Concern (ACEC) in Alternative B.

Alternative B seems to be the; "give SUWA whatever they want, despite the existing, traditional uses that have existed for decades" alternative. Sheesh, I wish we got the same treatment in Alternative D!!

Comment Suggestions:

*
I strongly oppose the ACEC proposals in Alternative B. The White Wash ACEC is especially inappropriate.

____________________________________________________________________________

Issue: Comments regarding "Lands with Wilderness Character"

Decisions on this issue are being made at the highest levels. OHV users must begin now to pressure their elected representatives on this issue or many hundreds of miles of roads and trails will be closed throughout the West. (You can find the contact info for your political representatives on BRC's Rapid Response Center. Simply Click Here, http://www.sharetrails.org/rapid_response/ and enter your zip code)

Comment Suggestions:

*
Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. Congress instructed the agency to inventory all of their lands, identify which were definitely not of wilderness quality and then to begin an intensive inventory and analysis to determine which of the remaining lands would be recommended for inclusion into the National Wilderness Preservation System.
The process was completed in 1991. All stakeholders (including Wilderness Advocacy Groups) have exhausted the protest and appeal options. After 10 years the "603 Process" left Utah with approximately 3.2 million acres designated as Wilderness Study Areas. Of those, approximately 1.9 million acres were deemed "suitable and manageable" and were recommended to Congress for Wilderness designation. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for inclusion in the National Wilderness Preservation System, subject to existing uses.
*
There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
*
When formulating land use plans and considering opportunities for solitude and unconfined recreation, the BLM must consider all other resource values and uses and attempt to balance the competing uses and values using the Multiple Use/Sustained Yield paradigm.

Hulk
11-06-2007, 11:05 AM
I have no idea what to do here. I can't spend all day drafting a letter. Even reading all of the above closely enough to understand it will take an hour at minimum, probably two hours. Some of the claims in the information above raises questions and seems open to interpretation. How extreme are these positions?

I am willing to follow your lead, Bill. I'm fully capable of customizing a sample letter. Do you have one?

Red_Chili
11-06-2007, 11:20 AM
No. I am in the same boat you are. Note the end of the alert for ideas.

Red_Chili
11-08-2007, 09:34 AM
I think this is the most salient part of the whole action alert:
But if you have any questions, concerns, or just need some help writing a comment letter -- please call.
Brian Hawthorne
208-237-1008 ext 102
Ric Foster
208-237-1008 ext 107

Don't wait for me to call, go ahead. The more the merrier. There are only 22 days left to comment!

RockRunner
11-08-2007, 09:46 AM
Bill,

If we get a "form Letter" put together we can email it to all our friends outside the club for a larger volume. I have several co-workers who wheel but do not belong to a club nor know about this proposal.

If you have anything drafted or ready to go forward it to me and I will get it out to them.

Red_Chili
11-08-2007, 09:56 AM
The action alert is long, because it covers all comments. Pick the ones of concern to you and note the recommendation to include personal experience!

Comments may be submitted electronically to: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to:
Moab Field Office RMP Comments
Bureau of Land Management, Moab Field Office
82 East Dogwood
Moab, Utah 84532.

Note:
A good comment letter starts with a brief paragraph about yourself and a bit, about what you like to do when you visit the Moab field office.

Issue: Comments about specific roads, trails and areas to be designated for motorized and mountain bike use.

Comment Suggestions:
BRC has several detailed maps for download that, for us anyway, are a lot easier to read. Click here, download the maps and talk amongst your friends, family and riding buddies.

NOTE:
Any specific comment on any road or trail, whether proposed as open or closed, is useful and we believe taking the time and effort to do so will be very worthwhile.


Comment Suggestions (two plans in one comment request by the BLM):

* The fact that comments are needed on Alternatives for the RMP and the Alternatives for the Travel Plan is not made clear in the document.
* The difference between an RMP (general guidance) and the Travel Plan (implementation decision) is not clearly described in the DEIS. The FEIS should clearly articulate the difference.
* None of the Alternatives presented are acceptable as they stand, including the Preferred Alternative C, which mandates unworkable and impractical management of camping and motorized travel. In addition, in all of the Alternatives, management for the White Wash Sand Dunes is fatally flawed and must be reconsidered (see comment below).
* Alternative D fails to provide a true motorized focus.
* Tell the BLM that you are concerned that many of the restrictions in all of the Action Alternatives are simply not justified. Tell the BLM that the FEIS should clearly draw a connection between the facts on the ground and the decision made.


Comment Suggestions (loss of open areas):
* BLM's open area in Alternative C and D must be expanded. The current proposal is unworkable because it confines a huge amount of vehicle use into a very small area and the area's boundaries are not well defined and cannot be easily identified on the ground.
* Requiring fences around the cottonwood trees and "water sources" is both impractical and unnecessary. We strongly oppose this provision of the Draft Plan.
* BLM's open area at White Wash Sand Dunes should include the popular and challenging hill-climb on the Northwest of the Sand Dunes.
* BLM's open area should be located along easily identified geologic features, or preferably along boundary roads of Ruby Ranch Road on the West, Blue Hills Road on the North, and Duma Point/Ruby Ranch (back way) on the East.
* You oppose the fee system contemplated in Alternatives C and D. Fee systems are inherently controversial and often unpopular with the recreating public. The Final RMP should not require a fee system. However, if funding for infrastructure needs cannot be met with existing funding and grant programs, then a fee system should be implemented only with the full involvement of the Recreational Fee Advisory Council and the affected user group.
* Because the open area boundary will not be easily identifiable on the ground, and also because of easy access to the proposed "fee area" from all directions, it will make this proposal extremely difficult to enforce. We suggest the BLM consider other funding mechanisms to pay for needed management infrastructure.


Comment Suggestions (consistency of management):

* The Final RMP should mandate that adaptive management practices be used across the Field Office
* The Final RMP should direct that mitigation efforts will be exhausted prior to closure
* The Final RMP should direct land managers to work with the affected public to ensure all available mitigation efforts have been exhausted before closure.
* When using adaptive management principles, The RMP should mandate the mitigation of closing routes and areas to recreational use by designating a more sustainable, but similar recreational opportunity elsewhere.


Comment Suggestions (user conflict, which is used to CLOSE OUR ACCESS because others whine - STRATEGICALLY, I might add! Favorite tactic!):

* When addressing "user conflict," the Final RMP should avoid "exclusive use zones" where, based on perceived or potential "user conflict," one or more "conflicting uses" is categorically prohibited.
* Most of the non-motorized focus areas have designated routes open to motorized vehicles within them. If implemented as written in Alternatives B, C and D, many visitors will perceive these focus areas as establishing blanket restrictions on motorized use. The unintended consequences will likely result in increasing, not reducing actual or perceived "user conflict."
* In order to address the "user conflict" issue, the Final RMP should direct land managers to educate the non-motorized visitors (who may perceive conflict with motorized uses) where they may encounter vehicle traffic in certain areas as well as informing them of areas where they may avoid such encounters.
* The Final RMP should direct land managers to educate vehicle-assisted visitors of where a road or trail might be shared with non-motorized visitors, and if appropriate, direct slower speeds.
* The Final RMP should direct land managers to re-route either use so as to avoid sections of roads or trails that are extremely popular with both groups. For example, a hiking trail can be constructed to avoid a section of popular OHV route. Or an equestrian trail may be constructed to avoid a section of popular mountain bike route, etc.


Comment Suggestions (loss of dispersed camping):

* Tell the BLM that you oppose the camping policy as outlined in Appendix E.
* The Final EIS should disclose how many campsites would be closed under each Alternative.
* Tell the BLM that you support a policy where existing campsites are open unless determined closure was necessary via lawful public planning process.
* Tell the BLM that it is very important that the Final RMP mandate full public involvement in any establishment and management of "restricted camping areas" or "controlled camping areas."
* Finally, and perhaps more importantly, check the BLM's maps (http://www.blm.gov/ut/st/en/fo/moab/...t_rmp_eia.html) to see if YOUR favorite campsite will be closed (see if a road is designated right up to the campsite). If you can't tell from BLM's maps, you need to tell them that!



Comment Suggestions (special recreation managed areas, inconsistently managed and again, overly segregated use):

*The Travel Plan and the Administrative Setting must be consistent in all SRMAs!
*All SRMAs with a motorized focus should include direction regarding when and how additional or expanded routes/areas would be provided should there be a need.
*SRMAs and their "focus areas" should avoid excluding other uses categorically. The Preferred Alternative clearly shows Moab BLM recognizes the importance of providing some motorized routes in non-motorized "zones."
*The Utah Rims SRMA is necessary to properly manage this popular area. It should have a motorized and mountain bike focus, and include the ability to designate or construct routes should they be needed in the future. In addition, limiting camping to one small designated area, in the RMP, is not wise. The RMP should provide general direction and not limit camping in such a way.
*The Utah Rims SRMA should extend further southwest to encompass Mel's Loop and beyond. Increased visitation there warrants the more active management of a SRMA. This larger area would also provide enough room for a full-day's motorcycle ride, and the establishment of a mountain bike focus area.
*Yellowcat is increasingly popular for four wheeling and ATV riding. Designating a SRMA there would utilize the dense network of mine roads that already exist.


Comment Suggestions (motorcycle/ATV):

*Some of the "motorcycle trails" are very popular with ATV users. The Final Travel Plan should designate a mix of single track and ATV trails.
*The FEIS should consider designating more ATV trails, especially between White Wash and Red Wash. We strongly suggest looking closely at the proposal developed by Ride with Respect.


Comment Suggestions (bicycles):

*The Mill Canyon - Sevenmile Rim biking focus area should be redrawn as Mill Canyon -Tusher Rims in order to provide better terrain for pedaling.
*The Final Plan should extend the South Spanish Valley biking area further south toward Black Ridge.


Comment Suggestions (multiple uses):

*An open area in addition to White Wash could provide different terrain for everything from bicycle free riding, to trials motorcycling, to hardcore rock crawling. As 99% of the Moab Field Office becomes limited to designated routes, open areas play an even more critical role for accommodating specialized sports. Perhaps parts of Black Ridge could remain unrestricted for this purpose.
*The Sand Flats Recreation Area could adopt special policies to permit slickrock exploration. We support Ride with Respect's recommendation that mountain bike travel be allowed on any barren rock surface. Slickrock within one hundred yards of a designated route could be open to motorized travel. This two-hundred yard corridor would accommodate the ways that people currently enjoy Sand Flats.


Comment Suggestions (motorcycles):

*Alternative D falls just short of providing sufficient motorcycling opportunities. Since no single-track inventory was performed, the BLM should continue accepting data on existing routes, and consider them for implementation.
*The Utah Rims single-track network should include at least 25 miles of additional routes, in order to be as complete as the Dee Pass network.
*In particular, long-distance single-tracks and rugged roads that connect SRMAs offer a unique experience. The Copper Ridge Motorcycle Loop should be combined with Thompson Trail in the final plan.
*A few more non-riparian washes should be left open, especially in the Cisco Desert. These travel-ways provide ATV and motorcycle riders an unconfined challenge that roads cannot.


Comment Suggestions (giving SUWA what they want by making White Wash an area of critical env. concern):

*I strongly oppose the ACEC proposals in Alternative B. The White Wash ACEC is especially inappropriate.



Comment Suggestions ("Lands with Wilderness Character", this SETS DANGEROUS PRECEDENT for losing access even though it is NOT Wilderness per se):

*Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. Congress instructed the agency to inventory all of their lands, identify which were definitely not of wilderness quality and then to begin an intensive inventory and analysis to determine which of the remaining lands would be recommended for inclusion into the National Wilderness Preservation System.
The process was completed in 1991. All stakeholders (including Wilderness Advocacy Groups) have exhausted the protest and appeal options. After 10 years the "603 Process" left Utah with approximately 3.2 million acres designated as Wilderness Study Areas. Of those, approximately 1.9 million acres were deemed "suitable and manageable" and were recommended to Congress for Wilderness designation. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for inclusion in the National Wilderness Preservation System, subject to existing uses.
*There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
*When formulating land use plans and considering opportunities for solitude and unconfined recreation, the BLM must consider all other resource values and uses and attempt to balance the competing uses and values using the Multiple Use/Sustained Yield paradigm.

Hope that helps. Write a long letter and include personal info.

Red_Chili
11-08-2007, 09:57 AM
Bill,

If we get a "form Letter" put together we can email it to all our friends outside the club for a larger volume. I have several co-workers who wheel but do not belong to a club nor know about this proposal.

If you have anything drafted or ready to go forward it to me and I will get it out to them.
Unfortunately, as discussed in the meeting, 5,000 form letters count as ONE comment and are a waste of time.

Sorry, gotta compose your individual letter, but hopefully the 'talking points' above (from which you can pick) should help.

Even copy/paste is not a good idea. Take the time to reword, to add personal experience, the work is worth the reward.

Red_Chili
11-08-2007, 10:41 AM
Based on phone conversations, we WILL be writing a club letter as well as personal comments. PLEASE do NOT let this take the place of your own letter! This is important!

Red_Chili
11-13-2007, 11:37 AM
MOAB ACTION ALERT 17 DAYS LEFT TO COMMENT ON MOAB RMP AND TRAVEL PLAN
Dear BRC Action Alert Subscriber,
In response to complaints that our earlier Action Alert (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2724&MID=788&LID=44) was way-too-long, below is a shortened up version.
The information below is designed to help you write a personal comment letter on the important Moab RMP and Travel Plan. BRC will not do a "click-and-send" alert.
Please try to understand, the Moab BLM crafted their process deliberately so that they can "round file" that "click-and-send" malarkey.
SUWA is spending hundreds of thousands of dollars trying to close White Wash Sand Dunes. I wonder... what will we tell our kids? That we can't ride the Dunes anymore because we were too busy to spend a few minutes writing a letter?
Think about it...
Please read the step-by-step instructions below. We've made it very easy for you.
As always, if you have any questions or need any help, please call or email.
Brian Hawthorne
208-237-1008 ext 102
Ric Foster
208-237-1008 ext 107

INSTRUCTIONS:
1) Read the SITUATION statement below and use the addresses provided there to prepare a draft email on your computer. Once you get your draft email started, go to the COMMENT SUGGESTIONS section.
2) In the COMMENT SUGGESTIONS section, first read the "Issue" statement. YOU DO NOT HAVE TO COMMENT ON EVERY ISSUE! And you don't need to use every bullet point comment in your letter. The idea is to mix and match your comments on the issues that are important to you. Savvy?
3) Next, use the "Comment Suggestions" below each Issue as materials to help you write your comment letter (each suggested comment has a bullet). Again, you don't need to use every comment bullet point. Mix and match, and add some personal info if you want.
IMPORTANT NOTE:
A good comment letter starts with a brief paragraph about yourself and a bit about what you like to do when you visit the Moab field office. Also, anonymous comments are often discarded, so be sure to include your name and address in your email.
SITUATION:
The Draft Resource Management Plan (DRMP) and Draft Environmental Impact Statement (DEIS) for the Utah Bureau of Land Management (BLM) Moab Field Office has been released for public review and comment. The Moab DRMP/DEIS and supporting information is available on the project web site at: http://www.blm.gov/ut/st/en/fo/moab/planning.html (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2725&MID=788&LID=44).
In addition to a new RMP, Moab BLM will be formulating a Travel Plan for motorized vehicles and mountain bikes. Motorized and mountain bike travel will be limited to designated roads, trails and areas.
The BLM has set a deadline of November 30, 2007, for receiving information and comments pertaining to the Alternatives and the analysis presented in the DEIS.
Feedback regarding the four proposed alternatives will be used to formulate a Proposed Resource Management Plan, and ultimately, a Final Resource Management Plan and Travel Plan.
Comments and other information may be submitted electronically at: UT_Moab_Comments@blm.gov.
Comments and other information may also be submitted by mail to:
Moab Field Office RMP Comments, Bureau of Land Management, Moab Field Office, 82 East Dogwood, Moab, UT 84532.

COMMENT SUGGESTIONS:
Issue: The "Park-ification" of BLM lands
Sadly, today's BLM seems to have all but abandoned the time-honored and proven principles of Multiple Use/Sustained Yield.
BLM lands are meant to be different than National Parks or Wilderness. The BLM has a Congressional mandate to manage these lands pursuant to the Multiple Use/Sustained Yield paradigm described in law. We believe under multiple use/sustained yield, OHV enthusiasts, mountain bikers, hikers, energy developers, equestrians and the like can share public lands and use them wisely.
Comment Suggestions:
Not all uses are mutually exclusive. There are multiple uses that can and should occur parallel to one another.
I believe that recreational, agricultural and industrial uses of public lands can and should coexist and share our public lands.
Management objectives that use such things as primitive recreation zones, Areas of Critical Environmental Concern, and so-called "areas with wilderness character" to create a de-facto Wilderness management are unlawful.
Congress put a deadline on inventory and study for Wilderness. The BLM should no longer be allowed to manage solely for "wilderness character."
I strongly oppose SUWA's proposal. __________________________________________________________________________________

Issue: BLM formulated three Alternatives, but there isn't much difference between them and worse, the "pro-motorized" Alternative is LESS friendly to motors than the Preferred Alternative!
Alternative D is supposed to emphasize motorized use, but puts the popular Rabbit Valley/Westwater trails area into "custodial management" with a hiking and equestrian emphasis! Honestly, BLM, what in the world are you thinking?!?!
Comment Suggestions:

Alternative D fails to provide a true motorized focus.
Tell the BLM that you are concerned that many of the restrictions in all of the Action Alternatives are simply not justified. Tell the BLM that the FEIS should clearly draw a connection between the facts on the ground and the decision made.
I strongly support designating the Utah Rims Special Recreation Management Area with a motorized and mountain bike emphasis. __________________________________________________________________________________

Issue: White Wash Sand Dunes management plan is totally unacceptable and unworkable (BRC details here (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2726&MID=788&LID=44))
Comment Suggestions:

Tell the BLM that you oppose the fee system contemplated in Alternatives C and D. Fee systems are inherently controversial and often unpopular with the recreating public. The Final RMP should not require a fee system.
If funding for infrastructure needs cannot be met with existing funding and grant programs, then any fee system should require the full involvement of the Recreational Fee Advisory Council, BLM's Resource Advisory Council and the affected user group.
BLM's open area in Alternative C and D must be expanded. The current proposal is unworkable because it confines a huge amount of vehicle use into a very small area and the area's boundaries are not well defined and cannot be easily identified on the ground.
Requiring fences around the cottonwood trees and "water sources" is both impractical and unnecessary. We strongly oppose this provision of the Draft Plan.
BLM's open area at White Wash Sand Dunes should include the popular and challenging hill-climb on the West of the Sand Dunes.
BLM's open area should be located along easily identified geologic features, or preferably along boundary roads of Ruby Ranch Road on the West, Blue Hills Road on the North, and Duma Point/Ruby Ranch (back way) on the East. __________________________________________________________________________________

Issue: BLM states the 'user conflict' issue as a question: How should recreational uses be managed to limit conflicts among recreational users? A quick read of BLM's draft plan indicates that their answer is to create "exclusive use zones."
Comment Suggestions:

When addressing "user conflict," the final plan should avoid "exclusive use zones" where, based on perceived or potential "user conflict," one or more "conflicting uses" is prohibited.
In order to address the "user conflict" issue, the final plan should direct land managers to educate the non-motorized visitors where they may encounter vehicle traffic in certain areas as well as informing them of areas where they may avoid such encounters.
The final plan should direct land managers to educate vehicle-assisted visitors of where a road or trail might be shared with non-motorized visitors, and if appropriate, direct slower speeds.
If "user conflict" can be documented, the BLM should simply re-route one of the uses. For example, a hiking trail can be constructed to avoid a section of popular OHV route. Or an equestrian trail may be constructed to avoid a section of popular mountain bike route, etc. __________________________________________________________________________________

Issue: Moab BLM is closing a huge number of dispersed campsites. (See BRC's details on BLM's proposal (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2727&MID=788&LID=44))
Because vehicles are not permitted to travel off designated routes - for any reason - the Moab BLM is proposing a "vehicle camping only in designated campsites" in the entire Field Office. Such a restrictive policy would be appropriate for National Parks or National Monuments, but for Public Lands this is truly unheard of.
Comment Suggestions:

Tell the BLM that you oppose the camping policy as outlined in Appendix E (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2728&MID=788&LID=44).
The analysis does not tell us how many campsites would be closed under each Alternative.
Tell the BLM that you support a policy where existing campsites are open unless determined closure was necessary via lawful public planning process.
Tell the BLM that it is very important that the final plan must mandate full public involvement in any establishment and management of "restricted camping areas" or "controlled camping areas." __________________________________________________________________________________

Issue: Special Recreation Management Areas
BLM uses something called a "Special Recreation Management Area" to manage recreation. Each SRMA is supposed to have its focus clearly described in the RMP.
Comment Suggestions:

All SRMAs with a motorized focus should include direction regarding when and how additional or expanded routes/areas would be provided should there be a need.
SRMAs and their "focus areas" should avoid excluding other uses categorically. The Preferred Alternative clearly shows Moab BLM recognizes the importance of providing some motorized routes in non-motorized "zones."
The Utah Rims SRMA is necessary to properly manage this popular area. It should have a motorized and mountain bike focus, and include the ability to designate or construct routes should they be needed in the future. In addition, limiting camping to one small designated area, in the RMP, is not wise. The RMP should provide general direction and not limit camping in such a way.
The Utah Rims SRMA should extend further southwest to encompass Mel's Loop and beyond. Increased visitation there warrants the more active management of a SRMA. This larger area would also provide enough room for a full-day's motorcycle ride, and the establishment of a mountain bike focus area.
BLM should consider a SRMA in the Yellowcat area. Yellowcat is increasingly popular for four wheeling and ATV riding. Designating a SRMA there could utilize the dense network of mine roads that already exist. __________________________________________________________________________________

Issue: Although many popular ATV routes are open roads in Moab BLM's Travel Plan, some ATV trails are not proposed as open and some of the Motorcycle routes should be designated as ATV/Motorcycle trails as well.
Comment Suggestions:

Some of the "motorcycle trails" are very popular with ATV users. The Final Travel Plan should designate a mix of single track and ATV trails.
The FEIS should consider designating more ATV trails, especially between White Wash and Red Wash. We strongly suggest looking closely at the proposal developed by Ride with Respect. __________________________________________________________________________________

Issue: In the Moab Field Office, true mountain bike single track trails are in short supply.
Comment Suggestions:

The Mill Canyon - Sevenmile Rim biking focus area should be expanded as Mill Canyon -Tusher Rims in order to provide better terrain for pedaling.
The Final Plan should extend the South Spanish Valley biking area further south toward Black Ridge. __________________________________________________________________________________

Issue: The OHV community generally supports the "travel limited to designated roads trails, and areas. The Moab field office is home to several popular "open areas" but BLM's plan is not quite enough.
Comment Suggestions:

The White Wash open area is much too small. This area should be expanded.
An open area in addition to White Wash could provide different terrain for everything from bicycle free riding, to trials motorcycling, to hardcore rock crawling. As 99% of the Moab Field Office becomes limited to designated routes, open areas play an even more critical role for accommodating specialized sports. Perhaps parts of Black Ridge could remain unrestricted for this purpose.
The Sand Flats Recreation Area could adopt special policies to permit slickrock exploration. We support Ride with Respect's recommendation that mountain bike travel be allowed on any barren rock surface. Slickrock within one hundred yards of a designated route could be open to motorized travel. This two-hundred yard corridor would accommodate the ways that people currently enjoy Sand Flats. __________________________________________________________________________________

Issue: Some important motorcycle trails are missing from all alternatives.
The preferred alternative includes about 100 miles of true motorized single-track. Alternative D adds another 100 miles. But in total, the final plan should keep roughly 300 miles of non-road motorcycle routes from being closed.
Comment Suggestions:

Travel Plan Alternative D falls short of providing sufficient motorcycling opportunities. Since no single-track inventory was performed, the BLM should continue accepting data on existing routes and consider them for implementation.
The Utah Rims single-track network should include at least 25 miles of additional routes, in order to be as complete as the Dee Pass network.
In particular, long-distance single-tracks and rugged roads that connect SRMAs offer a unique experience. The Copper Ridge Motorcycle Loop should be combined with Thompson Trail in the final plan.
A few more non-riparian washes should be left open, especially in the Cisco Desert. Wash riding is very popular. These travel-ways provide ATV and motorcycle riders an unconfined challenge that roads cannot. __________________________________________________________________________________

Issue: Keep White Wash Sand Dunes Open!
In an incredible show of chutzpah, the Moab BLM has proposed closing White Wash Sand Dunes to motors and making it a "hiking and equestrian" area (in Alternative B).
Comment Suggestions:

I strongly oppose the ACEC proposals in Alternative B. The White Wash ACEC is especially inappropriate. __________________________________________________________________________________

Issue: There is a need for additional mountain bike, trials motorcycle and rock crawling focus areas.
The BLM is drastically reducing the "open" areas which will concentrate a lot of use currently dispersed all over the field office. To properly manage recreation, the final plan needs to include additional focus areas.
Comment Suggestions:

Tell the BLM you support the proposal by Ride with Respect for additional mountain bike, trials motorcycle and rockcrawling focus areas. __________________________________________________________________________________

Issue: Route specific comments:
It is important to understand that SUWA is spending hundreds of thousands of dollars on photos and "environmental analysis" designed specifically to close individual routes.
Any specific comment on any road or trail, whether proposed as open or closed, is useful and we believe taking the time and effort to do so will be very worthwhile. Use BRC's maps (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2729&MID=788&LID=44) to help you identify the routes. Below are just a few suggestions:

Please keep the following routes open:

The last bit of Gemini Bridges road. There are very few natural stone bridges that can be driven across. This thrill has been available for decades. Please keep this open.
The Thompson Trail and the Copper Ridge loop as proposed by Ride with Respect.
Ten Mile Wash has been a popular OHV route for several decades now. Many riparian washes are being proposed for closure. Popular washes that have had vehicle use for many years should remain open. __________________________________________________________________________________

For maximum effectiveness:
1) Copy your letter to your political representatives. Snail mail works best. Pen a quick personal note to your politico's staff and make sure they know you are PRO access, that you visit the area and that you oppose both the rhetoric and the proposals of the so-called "environmental groups." Find the address of your politico's here: Rapid Response Center (http://www.sharetrails.org/alertlist/redirect.cfm?ID=2730&MID=788&LID=44) (just enter your zip code)
2) 'CC' your comments to BRC at brlandsinfo@sharetrails.org. In the Subject line please put Moab RMP Comments.

Uncle Ben
11-13-2007, 05:29 PM
Wow! I actually got a real e-mail from Mark Udall instead of his usual form letter....wonder whats up wit dat? :cool: I am soooooo special! :lmao: :thumb:

nakman
11-14-2007, 09:01 PM
Well, I am lame because I still haven't run Behind the Rocks. Was hoping to in May.. but can I ask a naive question? why is that area being singled out? Flip down to page 43 of the explanations of alternatives for what I'm talking about... http://www.blm.gov/content/etc/medialib/blm/ut/moab_fo/rmp/draft_eis.Par.82643.File.dat/CHAPTER%202.pdf


Naive question #2: So is it fair to say that the best alternative for someone who likes to occasionally wheel in, camp in, mountain bike in, and hike in the Moab area is Alternative D? Even though it too has some flaws.. but A is do nothing (won't happen), B is shut it all down, and C is somewhere between B & D? sorry for the over-simplification here...

cruiseroutfit
11-14-2007, 09:52 PM
...Naive question #2: So is it fair to say that the best alternative for someone who likes to occasionally wheel in, camp in, mountain bike in, and hike in the Moab area is Alternative D? Even though it too has some flaws.. but A is do nothing (won't happen), B is shut it all down, and C is somewhere between B & D? sorry for the over-simplification here...

Jumping in here... here is a great explanation we have prepared just for your questions:

http://www.u4wda.org/documents/U4WDA_Moab_DRMP_Fact_Sheet.pdf

Hope that sheds some light. It is VERY important that everyone take a minute and comment!!!

nakman
11-14-2007, 10:37 PM
Jumping in here... here is a great explanation we have prepared just for your questions:

http://www.u4wda.org/documents/U4WDA_Moab_DRMP_Fact_Sheet.pdf

Hope that sheds some light. It is VERY important that everyone take a minute and comment!!!

Exactly what I needed, thanks Kurt! :thumb:

Red_Chili
11-15-2007, 08:29 AM
One thing to keep in mind, Tim, is that not one of the alternatives as written is acceptable. You do not have to choose between them; the BLM and USFS often consider comments and modify alternatives. You can pick alternative D if you like, but be sure to stridently argue for less draconian management and use specifics. Even the 'motorized friendly' alternative D is not so friendly.

cruiseroutfit
11-21-2007, 02:14 AM
More updated info on our website:
http://www.u4wda.org/documents/U4WDA.Moab.Official.pdf

Take a couple of minutes to read through this document, there are several key items that you need to address in your comment letter!

Red_Chili
11-28-2007, 07:52 AM
This is the letter that will be sent on behalf of the club:
________________________________________________

UT_Moab_Comments@blm.gov

William H. Morgan, Jr.
Rising Sun 4x4 Club
Land Use Coordinator
[address]

Moab Field Office
RMP Comments
Bureau of Land Management, Moab Field Office
82 East Dogwood
Moab, UT 84532

To Whom It May Concern:
I am the Land Use Coordinator with Rising Sun 4x4 Club, a four wheel drive Toyota enthusiasts’ club headquartered in Denver<, Colorado. Every year we sponsor, organize, and host the Cruise Moab 4x4 event in the first week of May. This event draws participants from all over the US and Canada, and generates many thousands of dollars in revenue for us (as well as direct revenue for the BLM) which in turn we use for land use concerns including 4x4 route maintenance, restoration, and donations to the Moab community as well as our own. It is a popular event because the Moab area has recreational opportunities unlike any other in the US.

Now a little about myself, personally: I am a 4x4 enthusiast of course, but also enjoy trail motorcycling, mountain biking, hiking and camping in the Moab area. I am a hunter and strong conservationist as well. I am a one-person multiuse recreationalist, in other words; so I understand the concerns of potential user conflict quite well in an area that sees as many visitors as the Moab area. My family shares in these pursuits as well, and enjoying them together is an extremely important value to us and has been rewarding through the years. I am passionate about sustainable land use and advocate minimum impact practices to the club and to all trail/road users I encounter. I am not alone in this; in fact, these passions are representative of our club and we hope they help you understand the values that drive our comments herein.

Primitive recreation zones, Areas of Critical Environmental Concern, and so-called "areas with wilderness character". BLM lands are unique in their value, and are meant to be managed differently than National Parks or Wilderness. The BLM has a Congressional mandate to manage these lands pursuant to the Multiple Use/Sustained Yield paradigm described in law. We believe under multiple use/sustained yield, OHV enthusiasts, mountain bikers, hikers, energy developers, equestrians and the like can share public lands and use them wisely. There simply is not enough land to segregate different users so that multiple uses never encounter a different use of the land. Yet, there is sufficient Wilderness land for ‘quiet use’ advocates to enjoy solitude and silence and likely never encounter another human.

Management objectives that use such things as primitive recreation zones, Areas of Critical Environmental Concern, and so-called "areas with wilderness character" to create a de-facto Wilderness management are unlawful. Managing increasing acreage of BLM land as ‘wilderness-like’ not only is a violation of the BLM’s mandate, but marginalizes legitimate motorized users into a smaller ‘piece of the pie’ with increasing per-mile impact. Ironically, this degrades the remaining OHV areas even more. For these reasons we strongly oppose SUWA’s management proposal.

Alternatives. Alternative D is described as emphasizing motorized use, yet it puts the popular Rabbit Valley/Westwater trails area into "custodial management" with a hiking and equestrian emphasis. Just this year I had the pleasure of riding the Kokopelli Trail on my 650 motorcycle, and it was unlike anything I have experienced before. I encountered ATVs, mountain bikes, and other motorcyclists along with the odd 4x4 vehicle, and all these encounters were pleasant and all users exhibited the utmost courtesy and helpfulness.

I encountered NOT ONE horseback rider, and NOT ONE hiker, but quite a number of motorized and mechanized users. To manage this popular OHV and mountain biking area with an equestrian and hiking emphasis boggles the mind and, with all due respect, makes me wonder what you must be thinking with this proposal. Please do NOT put the Rabbit Valley/Westwater area under custodial management with a hiking and equestrian emphasis. Alternative D, by our experience, does not provide a motorized focus that reflects the on-the-ground current usage.

We are concerned that many of the restrictions in all of the Action Alternatives are simply not justified. The FEIS should clearly draw a connection between the facts on the ground and the decision made. We strongly support designating the Utah Rims Special Recreation Management Area with a motorized and mountain bike emphasis.

Closed Route in Westwater WSA. An existing and documented route exists on the southern side of the Colorado River within the boundaries of the Westwater WSA. The route begins outside the WSA and terminates near Star Canyon. This route has been open for decades, and it appears on USGS topographical maps from the 1970’s. Alternative D proposes that this route
remain open, and we would like to see that recommendation implemented in the Final RMP and Travel Plan.

Missing Route Segments. Several short route segments associated with permitted Easter Jeep Safari routes are missing from the proposed Travel Plan maps. The segments are located on Flat Iron Mesa, Strike Ravine, and 3-D. We understand that the Utah Four Wheel Drive Association has been informed this is merely an accidental omission, but we would like to formally request that these segments be included on the final maps.

White Wash Sand Dunes management plan. We oppose the fee system proposed in Alternatives C and D. Fee systems are inherently controversial and often unpopular with the recreating public. The Final RMP should not require a fee system. If funding for infrastructure needs cannot be met with existing funding and grant programs, then any fee system should require the full involvement of the Recreational Fee Advisory Council, BLM's Resource Advisory Council and the affected user group.

The open area in Alternative C and D must be expanded to ‘spread use’ on a larger footprint, thereby lowering the per-mile impact of current use. The current proposal is unworkable because it confines a huge amount of vehicle use into a very small area and the area's boundaries are not well defined and cannot be easily identified on the ground. This will have the ironic effect of increasing environmental impact mentioned earlier, as well as creating user confusion.

BLM's open area at White Wash Sand Dunes should include the popular and challenging hill-climb on the West of the Sand Dunes. It should also be located along easily identified geologic features, or preferably along boundary roads of Ruby Ranch Road on the West, Blue Hills Road on the North, and Duma Point/Ruby Ranch (back way) on the East.

User Conflict. How should recreational uses be managed to limit conflicts among recreational users? BLM's draft plan indicates that your answer is to create “exclusive use zones”. This is not the only answer to user conflict, and is, in fact, unworkable. Currently there is a large amount of Wilderness land appropriate for ‘quiet use’ advocates, but creating “exclusive use” zones in areas currently open for OHV use will concentrate increasing use on a smaller footprint, increasing impact.

When addressing user conflict, the final plan should avoid “exclusive use zones” where, based on perceived or potential user conflict, one or more conflicting uses is prohibited.

In order to address the "user conflict" issue, the final plan should direct land managers to educate the non-motorized visitors where they may encounter vehicle traffic in certain areas as well as informing them of areas where they may avoid such encounters. This should include signage where necessary to direct slower speeds.

If "user conflict" can be documented, the BLM should take the more incremental approach of simply re-routing one of the uses. For example, a hiking trail can be constructed to avoid a section of popular OHV route. Likewise, an equestrian trail may be constructed to avoid a section of popular mountain bike route, and so forth.

It actually appears that the DEIS/RMP plan will worsen user conflict. This will be precipitated by creating non-mechanized zones in the Behind The Rocks area, for instance. There are OHV trails through it (Pritchett Canyon). Also near Golden Spike/Gold Bar Rim, Rusty Nail 4x4 trail is routed through the non-mechanized Goldbar/Corona Arch hiking zone. This will create user confusion: is the area non-mechanized or not? And if so, are existing trails grandfathered in? It would seem that the whole point of making these areas non-mechanized is to create quiet and solitude for hikers, so the trails would become a nuisance, while they are existing routes where motorized traffic is expected today. This will make the BLM vulnerable to user complaints, and even to lawsuits from environmental and other anti-OHV groups. This is very shortsighted.

The BLM does not have to have all these targeted hiker uses because Colorado NM, Canyonlands and Arches NP all have exclusive non-mechanized trail policies in place and are nearby. It is redundant to have included additional Wilderness or wilderness-character areas beyond what already exists, and to negatively impact existing OHV recreation by so doing.

Dispersed Camping. Moab BLM is closing a huge number of dispersed campsites. Because vehicles are not permitted to travel off designated routes - for any reason - the Moab BLM is proposing a "vehicle camping only in designated campsites" in the entire Field Office. Such a restrictive policy would be appropriate for National Parks or National Monuments, but for Public Lands this is truly unheard of. We therefore stridently oppose the camping policy as outlined in Appendix E.

Also at issue is the lack of information about campsite closures; the analysis does not tell us how many campsites would be closed under each Alternative. This makes it very difficult to gauge the impact of the alternatives on dispersed camping. For instance, it appears that the Appendix E rule change would effectively eliminate all camping in the in Bartlett Wash area, at least in the interim, until and if it is developed. We support a policy where existing campsites are open unless determined closure was necessary via lawful public planning process including specific impact analysis. This should include full public involvement with adequate information specific to each area.

Special Recreation Management Areas. As a general idea, this strategy makes some sense to guide users to areas where their use is encouraged and properly managed. We do believe that all SRMAs with a motorized focus should include direction regarding when and how additional or expanded routes/areas would be provided should there be a need.

We also stress for reasons discussed above that SRMAs and their "focus areas" should avoid excluding other uses categorically. The Preferred Alternative clearly shows Moab BLM recognizes the importance of providing some motorized routes in non-motorized zones. We are deeply concerned however that designating an SRMA as a non-motorized area will create user confusion and actually instigate user conflict where OHV use is actually still legal. We have experienced this before in prior Cruise Moab events, even though our travel on a specific route was entirely legal. Please clarify, up front, via signage or other on-the-ground means, that an SRMA may emphasize a particular use without excluding other uses. This is critical to reduce user confusion and resulting user conflict (see comments above, under User Conflict).

The BLM should also consider a SRMA in the Yellowcat area. Yellowcat is increasingly popular for four wheeling and ATV riding. Designating a SRMA there could utilize the dense network of mine roads that already exist. This will have the added benefit of drawing users away from more densely used areas.

Special Recreation Permits. Under Alternative C, the maximum number of vehicles allowed on a run or event without a permit would be 24. Currently, that number is 49. This would make it difficult or impossible for many clubs and social groups to have informal runs and outings in the Moab area. Many social groups are not organized as clubs, and are merely collections of friends and acquaintances with a common interest. They do not have the resources to assemble a permit process, and this is an unnecessary infringement on their access rights. The vehicle limit for non-permitted events should remain at 49.

Open areas. Our club is a strong advocate of the “travel limited to designated roads, trails, and areas” management ethic. The Moab field office is home to several popular “open areas” but BLM's plan is not quite enough. The White Wash open area is much too small. This area should be expanded. An open area in addition to White Wash could provide different terrain for everything from bicycle free riding, to trials motorcycling, to hardcore rock crawling. As 99% of the Moab Field Office becomes limited to designated routes, open areas play an even more critical role for accommodating specialized sports. Perhaps parts of Black Ridge could remain unrestricted for this purpose.

Gemini Bridges Closure. The Gemini Bridges natural arch is one of the few natural bridges in the entire country that can still be driven, and it presents a very unique recreation opportunity. We feel strongly that this route offers a unique driving opportunity that will be lost if the proposed closure is enacted. Please include this route in the Final RMP and Travel Plan.

Conclusion. We are committed to the ethic of sustainable use in the Moab/Rabbit Valley area, and have put our money where our collective mouth is for years. We feel the BLM DEIS and RMP have gone too far in marginalizing OHV use, however. OHV users enjoy public lands in a sustainable way, and are important partners with the BLM to make sure these lands are passed down to future generations in their current – or better – condition. A small minority of users are responsible for resource damage, and the majority should not be restricted as a result; more intelligent and strategic interventions are called for rather than trail & route closure affecting all OHV users. To that end, we have and will continue to politely confront those who misuse the OHV opportunities at Moab. We look forward to continuing to partner with the Moab BLM office in furthering education and advocating a sustainable use ethic in future years.

Please include us in your decision making and keep us advised as to your progress.
Sincerely,

William H. Morgan, Jr.
Land Use Coordinator
On behalf of the Rising Sun 4x4 Club

Uncle Ben
11-28-2007, 08:54 AM
Outstanding letter Bill! Make mine look like generic :blah:. Thank you sir, so very much! :bowdown::bill:

Red_Chili
11-28-2007, 09:25 AM
Here's a sample letter written by Ride With Respect (a motorcycle group out of Moab). Find a few points in there and add them into your own letter, and change the words to read like your own.

Emails (preferred) can be sent as late as Friday, to UT_Moab_Comments@blm.gov

________________________________________
To: BLM Moab Field Office
From: NAME .
ADDRESS .
CONTACT (OPTIONAL)
Date: November 27, 2007
Re: RMP Comments

I have visited Moab for _#_ days over the past _#_ years. When there, I participate in _i.e. motorcycling_. I particularly enjoy _i.e. challenging, singletrack trails_. I ask your agency to provide opportunities for this kind of quality experience.

In Chapter 1 of the draft RMP, the first issue asks "How can increased recreation use, especially motorized vehicle access, be managed while protecting natural resource values?" I believe the solution is to provide diverse recreational opportunities with sufficient quantity and quality. To this end, I support the area and route designations proposed by Ride with Respect, nonprofit.

Section 4.3.10 (pages 4-191&2) generalizes the interests of recreationists based on their types of travel. It correctly states that non-mechanized users prefer non-mechanized trails, and that mechanized-users prefer mechanized trails. Just as non-motorized uses are dissected, motorized uses should be considered distinctly. Most motorcyclists prefer singletrack trails, ATV riders prefer ATV trails, and four-wheeling drivers prefer doubletrack more than improved roads. All recreation groups seek variety, including a range of terrain, route width, and difficulty. Trials bicyclists and motorcyclists depend on small, unrestricted areas. Freeride bicycling and 4WD rock crawling rely on challenging routes, usually in high density.

Section 3.11.2.6 (page 3-85&6) addresses use conflict and displacement, but not adequately so. Indeed, conflicts typically begin when a more dominant use compromises the experience of a less dominant use. Next, it states that less dominant uses become displaced. Then it recognizes that "The multi-use concept becomes strained when use levels reach a threshold." The plan should more explicitly state that conflict is exacerbated by crowding. Additionally, the plan should better address the scope of conflicts. They occur at society, group, and individual levels. They occur between management, user groups, and within user groups. Although conflicts generally begin asymmetrically, the direction is not always consistent. Finally, the plan should acknowledge that conflicts become symmetrical when management actions unduly restrict the more dominant uses.

In many forms, conflicts exist. The question becomes "What is the appropriate management response?" Ride with Respect supports many mitigation measures that can happen during implementation. I am pleased to read Table 2.1 Recreation (page 2-17), which plans to provide visitor information and outreach programs that foster a land ethic. For planning, I suggest highlighting one more critical item. Noise is the most common complaint against OHVs. Thus for all vehicles across the entire field office I recommend implementing and enforcing and 96-decibel limit based on the "20-inch" test (SAE J1287).

In response to recreation conflict, a common trap is for agencies to fall into the "ignore and restrict" pattern. To some extent, the Moab BLM has ignored recreation conflicts to date. The pattern goes that the agency will eventually restrict the uses it has partly ignored. Of course with more people doing more activities, some restrictions are necessary. But restrictions alone would lead to conflict symmetry and crowding. Rather, the solution involves a combination of trail-sharing and zoning across the field office. For example, the BLM could identify choice areas that are less-valuable among motorized recreationists in order to create non-motorized opportunities. In areas more important to motorized users, the agency should instead develop sustainable, non-motorized opportunities to resolve conflicts.

It is sensible to limit motorized travel to designated routes, plus inventoried roads for mechanized travel. Such an extensive restriction requires careful consideration of its impacts. Sections 3.11.1.2.16 and 3.17.2 (pages 3-79 and 3-158) estimate road mileage based on county inventories. They mention that "motorcycle routes" exist around White Wash. The document should specify that this includes motorcycle singletrack and ATV trails. Additionally, off-highway vehicle trails exist in high concentration from "Utah Rims" to Cottonwood Wash. Isolated OHV routes exist throughout the Moab field office, such as the Thompson Trail. Mountain bike trails also exist beyond those mapped in Alternative D.

The 2006 BLM technical reference on Planning and Conducting Route Inventories proclaims that "Route inventories are an integral part of Land Use Plans (LUPs)/Resource Management Plans (RMPs)" (page 5). Likewise, the 2001 BLM National Management Strategy for Motorized OHV Use asserts that "Successful resource management depends on gathering quality data using the best science available" (page 15).In the Moab field office, non-road mountain bike, motorcycle, and ATV trails were never inventoried. The only exceptions are roughly 15 square-miles around Bitter Creek and 100 square-miles around White Wash, which together comprise less than 5% of the field office. Grand County's Trail Mix Master Plan highlighted many popular bicycle trails, but was not intended as an inventory. Beyond the county roads, several hundred miles of trail exist, if not thousands.

Short of performing an inventory of trails, Moab BLM plans should at least acknowledge that they cannot fully measure the impacts to bicycling, motorcycling, and ATV riding in the absence of a trail inventory. To compensate for this, the agency should consider designating trail data provided during the planning process. Once the travel plan is implemented, BLM should practice adaptive management by testing mitigation techniques such as visitor education, signage, trail maintenance, and/or rerouting before prohibiting access. Further, the agency should prioritize the development of new bicycle, motorcycle, and ATV trails, with preference to SRMAs, and especially to the appropriate focus areas. Trail expansion would avoid pitting recreationists against one another on a rigid system of roads. By the same token, wide wash bottoms should remain open to all vehicles, instead of unduly restricting them to smaller vehicles.

To proactively manage recreation, Special Recreation Management Areas should be designated in anticipation of increasing visitation, not in reaction to it. SRMA boundaries and focus areas should be large enough to "grow into," as trends emerge. Focus areas should provide for a wide range of specialized sports.

Likewise, trails should not be ruled out simply by virtue of their low use levels. Low-use trails represent an opportunity to get 'ahead of the curve,' and prevent them from deteriorating. Some trails only appear to experience low use because they are durable, or have not been abused. Even if they never become popular, low-use trails often provide a unique experience for those seeking solitude.

Designating campsites should be done with public participation. Camping should not be confined to one mass site for any given. Most public-land users prefer dispersed camping. The Ruby Ranch Road and Utah Rims should each provide a dozen sites. In areas where camping is not restricted to designated sites, the travel plan should be adjusted to access campsites.

The Moab Extensive Recreation Management Area should provide primitive roads, singletrack trails, and dry washes to connect SRMAs and towns. Such routes offer opportunities for long-distance tours, which are increasingly popular among motorized and mechanized enthusiasts. Additionally, such links boost rural economies and disperse use, thereby alleviating conflicts.

Now let's apply these principles to the draft area and route designations in Alternative C. Broadly speaking, the road plan provides sufficient road-based opportunities. More of the existing roads surrounding Interstate 70 should be designated for long-distance touring. Compared to the road plan, motorized and mechanized trail designations are scarce. So the final plan should designate trails in Alternative D, plus others submitted by recreationists during this entire planning process. For all of the recreation conflict that the draft RMP purports, the travel plan in Alternative C does little to expand non-motorized opportunities. Several areas could provide substantial primitive opportunities by closing a few less-valuable roads. Homogeneity of the road plan would intensify conflicts and hurt all user groups in the long term. Alternatively, a few steps to diversify the travel plan could benefit recreationists across the activity spectrum.

For the following site-specific comments, please refer to maps provided by Ride with Respect, nonprofit.

In the ERMA, Thompson Trail is unique by virtue of its sheer length and remoteness. Trail adoption by volunteers could preserve its singletrack character. Together with Thompson Wash and Copper Ridge Motorcycle Loop, Thompson Trail creates a unique route from the Sovereign Trail to Colorado. The Green River Gap and Browns Wash tie Colorado to the town of Green River. These singletracks should be preserved, along with adjacent doubletracks. Together such remote, rugged routes offer a chance to experience the desert like neither SRMAs nor graded roads can do.

Likewise, Kokopelli's Trail could be enhanced to create higher quality opportunities for motorized and non-motorized travel. The RMP should pledge to construct a Kokopelli Singletrack and mark a Kokopelli Doubletrack that would roughly parallel one another. Through Utah Rims, the Singletrack should be open to motorcycles. Through Yellowjacket, the Singletrack should actually be ATV trail. Everywhere else, the Singletrack should be non-motorized. The Doubletrack would generally follow the current trail, with revisions to achieve a rugged, backcountry opportunity.

Northeast of Green River, the non-WSA lands surrounding Tusher Canyon have great potential for mountain bike trails. This northwest corner of the Bookcliffs has access roads, rims with sweeping views including Desolation Canyon, and relatively good soil development. Similar to bicycle trails in Fruita, a Tusher Canyon trail system would boost the economy of Green River, and dedicate quality trails for mountain biking.

I generally support establishment of Labyrinth Rims SRMA in Alternative C. However, the Dee Pass Motorized Trail focus area should be expanded beyond Alternative D eastward to the powerlines. The White Wash Sand Dunes OHV Open Area should be expanded by two square-miles beyond Alternative D (northward to Ruby Ranch Road and southward toward Red Wash Road). Fee programs should be determined with public involvement through a Resource Advisory Council . Approximately twenty-five miles of the surrounding OHV trails are popular among ATV riders, and should be designated as such. The Dead Cow Loop could be designated with the exception of the "low-water" alternate, to reduce riparian impacts. The Tenmile Point area from Dripping Spring to Levi Well has relatively few routes and could be designated for non-mechanized focus. Tenmile Wash should be designated without speed limits, since speed has little influence on the biophysical impacts of travel.

The southwest corner of Labyrinth Rims is a relatively primitive area, and should be managed to preserve this quality. Spring Canyon, Hellroaring Canyon, Spring Canyon Point, Deadman Point, and south Horsethief Point are best allocated as a non-mechanized focus. Motorized use there can be adequately accommodated by the Jeep Safari routes, plus a few choice spurs to overlooks. Closing the river road downstream from Spring Canyon would reduce recreation conflicts, while retaining access to Hey Joe Mine. Dubinky Wash is valuable for all vehicle use, and the singletrack near Jug Rock should remain available for motorcycles.

North of Highway 313, the singletrack which drops off Hidden Canyon Rims is a key link for motorcyclists and bicyclists, alike. The Mill Canyon - Sevenmile Rim mountain bike area should be rotated to become Mill Canyon - Tusher Rims. Tusher has better bicycling potential than Sevenmile due to less sand, more slickrock, and fewer roads. Then Sevenmile - Upper Courthouse motorized backcountry touring area could be created to recognize the high-value roads that extend through Monitor & Merrimac to Big Mesa campground. Upper Sevenmile Equestrian Area should be expanded by four square-miles to include some terrain above the rim.

South of Highway 313, an additional bicycle focus area west of South Fork Sevenmile Canyon could provide cross-country and vehicle-assisted rides from the upper Gemini trailhead down to the switchbacks on Highway 313. The Gemini Bridges motorized backcountry touring area could be shifted to include all of Little Canyon Rim. The spur to Gemini Bridges should remain open to allow the unique experience of driving the bridge. Mountain bike alternates to the roads could be developed in this area, as proposed by Trail Mix. The Goldbar hiking area could be expanded further up Day Canyon, while only closing one spur road.

The Klondike Mountain Bike focus area is a great foundation to develop mechanized singletrack. Most spur roads could be closed east of Bar M and Sovereign Trail areas. Still, the Sovereign ATV Loop should be permitted in its current location. Spur roads should also be closed north of the Copper Ridge Sauropod Trackway. Copper Ridge Motorcycle Loop is highly valuable to motorcyclists. Trail adoption could help to ensure enjoyment for mountain bikers, like the Sovereign Trail. And like the Sovereign ATV Loop, the Copper Ridge Motorcycle Loop could actually protect any non-mechanized trails that it surrounds by steering motorcyclists toward a legal alternative.

Yellow Cat, Yellow Jacket, and Dome Plateau are worthy of SRMA designation. Yellow Cat and Yellow Jacket are densely roaded and increasingly popular among four-wheeled visitors, so they should have a motorized backcountry touring focus. Few adjustments are needed to the travel plan, except around Owl Canyon where road access should be preserved. A non-mechanized focus area could buffer the entire boundary of Arches National Park, wrap around Dome Plateau, and terminate near Dewey Bridge. Only a couple overlooks of Lost Spring Canyon and Dome Plateau are needed, but they should remain open all the way to the rim.

Utah Rims SRMA ought to extend further southwest to the Cisco Road. From the Cisco Road to Cottonwood Wash, a mountain bike focus could lay the groundwork for bicycle trails. From Cottonwood Wash to the Westwater Road, a motorcycle focus would help preserve Guy's Trail and associated singletracks. From Westwater Road to the state line, several existing singletracks should be recognized in the travel plan, plus one ATV loop in the northeast corner of May Flat. A non-mechanized focus area could be expanded from the Westwater WSA further southwest all the water to private property. The entire spur road to Big Hole could be closed to enhance primitive characteristics. None the less, the Westwater Canyon overlook road should not be closed. Mechanized visitors should be granted at least one viewpoint of the place that their activities are prohibited from.

The Dolores Triangle includes a few remote areas where primitive character should be preserved. By closing two less-valuable spurs, Big Triangle substantially expands the Westwater roadless area to the north. Further south toward Buckhorn Draw, a few roads could be added to ensure that quality motorized opportunities exist in the Dolores Triangle as well. From Steamboat Mesa to South Beaver Mesa, another focus area should be designated for primitive recreation. Half of the Dolores River overlooks could be preserved as cherry stems. Also, a road on the southeast ridge of South Beaver Mesa lies outside of this focus area, and should remain open.

The Sand Flats Road traditionally connected trails such as Hells Revenge, Slickrock, and Fins 'N Things. Paving the road, and prohibiting OHVs from pavement, has fragmented the trail system. Thus OHVs should be permitted to use Sand Flats Road from Hells Revenge exit to the end of the pavement. The new, reduced speed limit of 25mph should be preserved. A non-motorized lane should be constructed to parallel the road and reduce congestion. Additionally, the 1/4-mile slickrock route connecting Slickrock Trail with Fins 'N Things should be designated for two-wheeled use to alleviate traffic along the main road. All of these measures would make Sand Flats more user-friendly and manageable, without further impacts to the environment.

Special policies should continue permitting slickrock exploration. The Moab Field Office Off-Highway Vehicle Travel Map states that "Two-wheel motorcycles are allowed on established slickrock riding areas in the Slickrock Trail, Bartlett Wash and Tusher Canyon areas and on slickrock areas along the Monitor and Merrimac and Lower Monitor and Merrimac trails where such use does not further disturb vegetation or soils" (dated March 8, 2001 as part of emergency restrictions). In these areas, travel could be further restricted, but not so drastically as the draft RMP intends. Mechanized travel should still be allowed on any barren rock surface. Slickrock within one hundred yards of a designated route could remain open to motorized travel, except for Tusher Slickrock , which would be reserved for non-motorized use. This two-hundred yard corridor would accommodate the ways that people currently enjoy slickrock areas.

The Black Ridge area presents many potential recreation opportunities nearby Moab. The South Spanish Valley Mountain bike area could be extended to include part of Pole Canyon. This augments the variety of terrain, and provides enough room for a full-day's ride. Sweeping travel restrictions associated with the draft RMP warrant designating an area for specialized sports which depend on unrestricted areas. Durable and irregular terrain that is suitable for motorcycle and bicycle trials riding exists in Pole Canyon from the powerlines to Area BFE. In the same vein, a rock crawling area could be established on Black Ridge east of the powerlines. This area is littered with old mine roads, and is currently open to cross-country travel. The site could be limited to designated rock crawling routes, and adopted by local clubs. West of the powerline, the north flank of Black Ridge could be designated for equestrian use, as the backdrop to a residential area. The south flank could be a bicycle freeride area, since it provides one thousand feet of vertical relief, and graded roads for shuttling. Kane Creek is a dry wash from Highway 191 up to the Black Ridge Road. It should be open for OHVs to create a loop with Behind-The-Rocks while avoiding the highway.

Hatch Wash backpacking focus area could be expanded for better backpacking. Alternative C proposes to designate roughly twenty spur roads to the rim of Hatch Wash. However, only five are necessary to view most stretches of the Canyon.

Cameo Cliffs SRMA should also be expanded for better OHV riding. The current boundary offers a meager half-day for the skilled rider. Extending the SRMA east to Big Indian Valley could still avoid mining activity. Shifting the boundary north to the Brown's Hole Road could still skirt the nearby residential area.

Revising the draft plan will be a significant undertaking. Yet implementing the current plan would demand more from the BLM as use conflicts, recreation impacts, and non-compliance intensify. In the long run, I strongly believe the above ideas are better for land managers, recreationists, and conservationists alike. Thank you for your consideration.

Hulk
11-28-2007, 01:46 PM
Great letter, Bill! You're welcome to add my name as well. I can e-mail you an image of my signature if you need it.

Red_Chili
11-28-2007, 02:21 PM
I just emailed it, and sent them a hardcopy to boot. My sig should be enough on behalf of the club, no?

Hulk
11-28-2007, 03:26 PM
Sure, fine by me.