April 5th (THIS FRIDAY) is the deadline for comments on the Resource Management Plan Amendment/Environmental Assessment
(RMPA/EA) for the Glade Run Recreation Area (GRRA).
This area is also called Chokecherry Canyon. It's a very important area for the four corners. The trails here are awesome, 3800 acres of Open OHV with abundant sandstone slick rock much like Moab. It has hosted several ARCA organized events in the past.
The local CliffHangers Four Wheel Drive Club has hired a consultant to help them with this EA. And what they have found is that the EA is seriously flawed.
I attended the public meeting they had and I learned that they couldn't answer my questions with anything intelligent.
What the club is asking is you to help tell the BLM to go with the No Action Alternative which will default to the 2003 RMP and the 2006 La Plata TMP.
Email your comments to BLM_NM_FFO_comments@blm.gov
(Please include GRRA R&TMP in the subject line)
Specific flaws in the EA are:
- There are so many problems with the maps they produced. They are misleading and incomplete. They have not adequately mapped the existing roads and have not inventoried all of the Cliffhanger trails. Without knowledge of the trails someone reading the draft EA would not know what the impacts are to the existing trails in the current Open OHV area. And with Alt A there are impacts but they are not described.
- They have created an additional Quite Zone RMZ to segregate users. But there is no way this area will be quite with oil and gas compressors running and oil and gas traffic. The GRRA is an urban interface zone and a "quiet use zone" is not possible. It is also not possible to even know that you're in this area.
- They discuss conflicts 31 times in the EA. However, they do not quantify these conflicts and they have not done an analysis of this conflict because we find no definition nor any attempt to work with county and state law enforcement on the matter of "conflict." But most alarming, there is no legal standard to guide any management action.
- They state that "...routes with higher levels of motorized use cause more sedimentation and require more maintenance to control erosion than routes with lower levels of non-motorized use." This description is irrational in light of the EA's own description of the soils. "water erosion hazard is slight to none"
- Throughout the EA the impacts of Alt B are stated as worse than Alt A, however there are very little differences in the OHV use in the two Alternatives. Alt A and B have same management prescription but only B will somehow have negative impacts on non motorized visitors and adjacent land owners.
- The cumulative impacts of all of the alternatives entail some fairly complex law enforcement requirements. The EA has not discussed this difficult aspect. They can't enforce anything now, people still use firearms and discard trash by the truckload. How will they enforce more stringent use segregation?
- Section 3.8.3 Impacts from Alternative A (Preferred Alternative) Direct and Indirect Impacts is entirely plagiarized from an EA in Colorado. The names of the highways, trails, canyons, etc. where not even changed.
- Section 3.9.1 states the "the Bakersfield FO has issued..." Bakersfield FO is in California. More plagiarism.
In summary rather than pursue this flawed analysis we recommend that the FFO implement the 2006 La Plata TMP. It already has a signed FONSI and needs no further NEPA work. It is very similar in management prescriptions as this new plan. The La Plata Plan was never implemented, has options for additional routes and a realistic approach to signing and education.