Utah BLM released the San Rafael Route Designation Seriously Plan for public comment and review. The seriously flawed travel plan closes at least 40% of existing roads and trails. More importantly, the Implementation and Monitoring section requires BLM to impose more restrictive standards upon the request of any Wilderness Advocacy Group.

DETAILS:

The San Rafael Route Designation Plan is so filled with anti-OHV bias that it becomes appropriate to question the suitability of the author(s) to manage any public land resource other than wilderness. In the analysis of OHV effects, the document refers to impacts of OHV's on wildlife as "harassment" and alleges that OHV users are "running over fauns". Nowhere in the document does it discuss the fact that the entire San Rafael Swell (including existing Wilderness Study Areas) was "trammeled" by mineral search activities culminating with the Vanadium and Uranium boom of the 50's. The document concludes that, other than OHV activity, these lands are pristine, devoid of any human use or activity whatsoever.

This is not the case. The roads left by the miners and prospectors are national treasures to be cherished and preserved. These roads need to be conserved for future generations so that they might also experience the delights and joys of the natural beauty that has been so abundantly afforded us. Since the EA is so preoccupied with the many negative effects of RV use in this area, it becomes important to gain some grasp of just how much surface area we're dealing with.

FACT:

Alternative 1, the so-called "no action" alternative and the most liberal of all, would designate 1,074 miles. From this we can calculate the total surface area of roads and trails to be 2.034 square miles or 1302 acres. This is equal to just 0.126 percent of the land in question or 1 out of every 792 acres. Is this too much to ask for the majority of Swell patrons who prefer the use of vehicles? Certainly not!

More importantly, the Implementation and Monitoring Plan gives authority to manage OHV use over to any Wilderness Advocacy Group by stating: "All routes open for motorized travel in WSAs and wilderness inventory areas, and citizen's wilderness proposal areas would remain under a "conditionally open" status. These routes would remain open only if motorized travel does not impair the unit for designation. These routes would be scrutinized more intensely by BLM monitoring than public lands with no wilderness values. Based on monitoring or any of the above, restrictions on travel may be adjusted if anticipated impacts or expected results are not occurring." Read that carefully. It says that a popular and legal recreational activity, occurring on legal travelways, is going to be designated as "conditionally open", subject to intense scrutiny and future restrictions simply because it happens to occur on lands alleged to have "wilderness character" by any radical Wilderness Advocacy Group that decides to put together a "citizens proposal".

Do not let this outrage stand. Our Utah partners, the Utah Shared Access Alliance (USA-ALL) (http://www.usa-all.com/) has asked the BlueRibbon (http://www.sharetrails.org/) for help. We need you, your friends and your family to TAKE ACTION TODAY!

HERE IS WHAT YOU NEED TO DO:
Fax a letter to Utah BLM State Director Sally Wisely.

*Tell her just a bit about yourself and be sure to let her know if you have visited the Swell, or even plan to visit the Swell in the future.

*Inform her of the anti-OHV bias contained in the San Rafael Route Designation Plan. Let her know that you do not HARASS wildlife or RUN OVER FAWNS! Tell her how outraged you are and ask her to read the San Rafael Route Designation Plan to see if she can find one positive statement about you or your family within the text.

*Inform her that any management policy or other specific management actions based solely upon a "citizens wilderness proposal" is inappropriate, contrary to established BLM policy and illegal. Ask her if she agrees with the assertion made by the author(s) that all lands within the "citizens" proposal have "wilderness values". Ask her to inquire how this criteria got into the San Rafael route designation Plan.

*Finally, and most importantly, tell her that OHV users should not be punished for the BLM's failure to manage OHV use in the past. Ask her to instruct the Price Field Office to immediately implement positive OHV management solutions within the current management plan. Ask her to adopt Alternative 1, sign the existing roads and trails, provide maps, engage in cooperative management efforts with ALL public land users and revise the Implementation and Monitoring plan so that SUWA does not have authority to manage OHV use. Remind her of the past mining history and the many closures OHV users have suffered in the past.

Be polite and be sure to include your name and address. Ask her to keep you informed of this and any planning activity in the Price Field Office.

PLEASE FOLLOW THESE INSTRUCTIONS:

(Sorry, no form letter this time. Please cut and paste from the above to make your comments unique)

Address your letter to:
Sally Wisely, Utah BLM State Director, P.O. Box 45155, SLC, UT 84145
Put "Comments on San Rafael Route Designation Plan" on the letter.

Fax one copy to Director Wisely at: 801-539-4013
Fax one copy to the Price Field Office at: 435-636-3657

*** END ALERT *** END ALERT *** END ALERT *** END ALERT ***

Heres a sample letter, courtesy of Terry Rust and Bob Norton:

March 14, 2002



Bureau of Land Management

Price Field Office

125 South 600 West

Price, UT 84501



Reference: Environmental Assessment San Rafael Route Designation Plan EA# BLM/UT-067-94-010



Dear Planning Team,



I appreciate this opportunity to share in the management of our public lands by offering the following few comments on the EA San Rafael Route Designation Plan. I am a long time and frequent visitor to Utah and the San Rafael Swell and have many cherished memories of visiting the incredibly scenic and remote back-country places on the myriad historical roads that still exist. The "jeep" trails and other historically used mining, ranching and exploration routes provide limitless opportunity for high quality back country solitude and an opportunity for my family and I to enjoy our public lands. It is very disappointing to me that so many of our favorite routes have become closed in recent years and troubling that so many more are targeted in this “plan”.



I would like to offer the few following comments regarding this plan and encourage you to seriously consider them as you move through the planning process.



There needs to be, in my opinion, a major paradigm shift in the agency view of roads, trails, ways, and other transportation routes. That shift is to recognize that these in place, often historically used and culturally valued, and in many cases user maintained features are recreational and cultural infrastructure to be valued rather than viewed as a burden to be maintained. I believe that once this shift takes place many of the difficult issues before the agency can be alleviated if not eliminated.



The agency MUST move away from the litigation inspired trend toward concentrating visitors, this management prescription is doomed to failure if the agency still subscribes to the multiple use mandate set forth as part of the enabling legislation. The reality is that the public is enjoying our public lands more now than ever before and the preferred method is via some form of OHV, motorized or non. The agency must plan for that increasing demand and not simply manage to the shrillest, mot litigious voice in the crowd. Dispersed recreation through multiple opportunities is the best way to minimize the inevitable resource degradation inherent to focusing an increasing number of visitors on a decreasing area. You well know that to cave into the pressure of litigation is only temporary, more demands will simply follow until there are no truly public lands left.



There should be no more loss of routes available for OHV use in the area covered by this Plan. As mentioned above, the demand for this resource is increasing and shows no sign of decreasing, meet that demand responsibly and with foresight. All existing roads and historically used routes should remain open. Many of the previously closed roads/routes should be re-opened, among these in the San Rafael Reef: Iron Wash, Ernie Canyon, and the road to the copper prospects at Old Woman Wash.



Roads and routes in the San Rafael Swell area and specific trails that I believe to be vitally important OHV routes and therefore particularly important for keeping open including (but not limited to) the following:



Segers Hole

Hidden Splendor/Muddy Canyon

Eagle Canyon

Roads to the Swasey Cabin

North Fork Coal Wash

Devil's Racetrack

Secret Mesa

Eva Conover Road

Cane Wash

Behind the Reef Road

Little Wild Horse Canyon

Dick Brass Trail System

Cistern Canyon

Three Fingers Canyon

Bull Bottom

Trin Alcove/Entrada Gap

Junes Bottom



Most of these routes have great historical value as well as great scenic and other appeal not to mention that they predate the 1976 RS2477 date for BLM consideration. To close them opens the agency to future unnecessary expense, conflict, and erosion of public trust when assertions are made and proven. Not to mention the undue cost and aggravation to the public and wasted agency resources. Why not simply acknowledge that status in the panning process and avoid the headaches of undoing a shortsighted plan. I work in a large environmental restoration project under the Resourse Conservation and Recovery Act (RCRA), one of our key points in planning any project is to fully consider all “Applicable or Relevant and Appropriate Requirements” (ARARs), I would strongly encourage BLM to take this approach in the planning process for our public lands and ensure that all routes that are targeted for closure do not fall under RS2477 or other protections before they are closed.



I, personally, do not endorse cross-country OHV travel. I would, however, like to see increased BLM enforcement to catch and heavily fine those few offenders. Such abuse gives a "black eye" to the vast majority of OHV recreationists that enjoy our public lands in a responsible manner.



There should be NO new WSA designations in the area until Congress acts on all of those that currently exist in numerous areas of Utah. This Congressional action should also include the release of those WSAs that were studied and found not suitable for Wilderness designation and should, therefore, be released back to multiple use. Any access restrictions on existing WSA's should be lifted or significantly revised. It was not the intent of Congress to allow Federal agencies the power to create such "defacto wilderness" designations. Congressionally designated Wilderness already exists in adequate quantity to satisfy those two percent (USDA Forest Service statistics) of visitors who utilize the designated areas. There already exists substantial opportunities in these previously designated Wilderness areas in the region for those that seek a recreational experience apart from mechanized users. Closing a route such as Behind the Reef Road due to claims of user conflicts is beyond ridiculous. I am willing to share the Public lands with all recreational users and there is plenty of room for all users to share the short section of motorized roadway that hikers include on a loop hike. I, personally, have always been friendly and courteous to any hikers encountered and have even “rescued” ill prepared hikers and bicyclists with water and/or rides back to their automobiles (that pesky motorized access again). Similarly, most of the hikers I have encountered have been friendly in return, recognizing that all of us are enjoying the spectacular back-country that Utah offers. The whining by the, generally non-resident and always extremely shrill, "closurist" minority is generally without merit.



Alternatives 2, 3, & 4 contain far to much “caving in” to those same closurists in the name of “compromise” to be acceptable to me as they are presented in the EA San Rafael Route Designation Plan. Junes Bottom, for example, is a special place which makes a nearly perfect motorized experience that would be left open only in Alternative One. Likewise, Segers Hole and many others. Therefore, unless significant modifications are made to the other alternatives, I can only support Alternative 1.



Although Alternative 2 allows use of 819 miles of the 1074 total, it is unacceptable to me. All routes adjacent to the Green River would be closed, as would Segers Hole and Behind the Reef Road, amongst others. As such clearly high quality back-country experiences would be unnecessarily eliminated by such closures, this alternative is wholly unacceptable.



Alternative 3, which would close nearly half of all existing routes is totally preposterous and insulting to have been considered. It is totally unacceptable as it caters to an extreme minority who desire to simply eliminate all access to public lands.



Alternative 4 includes some good and bad proposals. An example of a good idea is the inclusion of loop routes for OHV use on several popular roads/trails. The bad, however, includes the closure of Segers Hole (another near perfect motorized backcountry experience) and all routes adjacent to the Green River. Likewise, several of the routes such as Eva Conover Road, North Fork Coal Wash, & Devil's Racetrack are designated as temporarily open routes. If this Alternative is adopted and subsequently these routes are closed by the BLM, then the public will have been dealt a major, and unscrupulous, blow to their access. This alternative as presented is, therefore, unacceptable.



The OHV community in Utah has repeatedly demonstrated that they can work with the BLM on specific projects. This is directly counter to the continual barrage of litigation from the closurist lobby. I would, therefore, urge that the BLM continue in this cooperation with those groups who have proven to prefer cooperation and shared success to confrontation and litigation. There is the potential for more and better signage, coupled with better education on legal and conscientious OHV use of these public lands. The management alternatives should provide for volunteer mitigation instead of closure. In fact, I view closure of existing roads and trails to be a failure in proper management rather than a legitimate management solution and would suggest the agency adopt that perspective.



I would also ask that your BLM office continue to allow and encourage opportunities for special events and organized trail rides. These can be a wonderful opportunity to further educate your most loyal visitors.



And you simply must continue to allow traditional uses and ways of life to continue. After many decades of this use the anti recreation lobby continues to find additional “wilderness” for designation and “protection”, clearly these uses must not only not degrade the resource but must, in fact, enhance the condition of these lands to allow for the presence of man to be “largely unnoticeable” after all these many years. Maintain the multiple use mandate in your enabling legislation.



Thank you for your kind attention to my comments, I would appreciate careful consideration to my comments and concerns. I do wish to be included on all future mailings related to this planning process. Thank you very much.



Sincerely,





Terry Rust

Rafael plan a tough sell in rural Utah
By Jennifer Toomer-Cook
Deseret News staff writer

CASTLE DALE — Turning the San Rafael Swell into a national monument has the backing of state and local leaders and the attention of the federal government, but it's looking like a tough sell with residents of this central Utah town.

Most of the some 150 residents attending a town meeting with Gov. Mike Leavitt Wednesday disagreed with creating a 620,000-acre San Rafael Western Heritage National Monument, a concept Leavitt announced in this year's State of the State and forwarded in a letter to President Bush two weeks ago.
"This is not from the community," Ferron resident Wade Allinson told Leavitt. "You said if it's the will of the people, we'll do it. Well, this is not the will of the people."
Leavitt, however, views monument designation as a way to give locals, rather than the federal government, more say on the land's future use. And he stresses that nothing is set in stone.
"This is an idea, not a proposal," Leavitt said. "Whether a monument happens or not, we can set a standard for the way public discussion ought to take place."
In fact, he told residents the real "gorilla in the room" is not the monument. It's the Bureau of Land Management's environmental assessment of some 1,000 miles of roads within the swell. One transportation proposal could restrict 300 miles of those roads. Public input time runs out next week.
Leavitt urged residents to chime in on that imminent "gorilla" — emphasized by a staffer dressed in an ape suit — rather than worry right now about a monument that may not be.
Leavitt and his Cabinet traveled to central Utah to bring the Capitol to Emery County's 11,000 residents for a day, anticipating an emotional reaction to the monument proposal and highway safety.
Residents decried the safety of Highway 6, where auto collisions have killed and injured their family members.
Leavitt told them the state was spending $80 million over the next decade to widen and improve the road and offered a moment of silence for those who had died on the highway.
The administration visited the San Rafael Swell, a huge and scenic geological formation cut by canyons and bisected by I-70 west of Green River. They paused at the scenic Wedge Overlook and drove the winding, red cliff-lined road to Buckhorn Wash Pictograph Panel. They learned of the area's history, which included visits from Wild West outlaw Butch Cassidy.
The draw of the land is indisputable. Managing it, however, is not.
Groups, from wilderness advocates to ranchers to all-terrain vehicle advocates, have fought for years over land use, County Commissioner Randy Johnson said. Visitors are drawn to the area but don't have many tourism checkpoints to show them where to go. Some venture out unaware of dangers, and search and rescue missions whittle away at local budgets.
The commission created the Emery County Public Lands Council to help resolve such matters. Four years ago, it drafted a proposal, which made its way to Congress.
A bill sponsored by Rep. Chris Cannon, R-Utah, would have declared the area a national conservation area, but it died under lobbying from environmentalists who wanted to limit off-road vehicles.
Undaunted, the group looked at creating a monument as another means to the end. Leavitt announced the concept in January in his State of the State address.
But the governor's speech blindsided locals. And several were infuriated by his April 4 letter that tells Bush a monument "has the full support of Utah's congressional delegation" and follows "seven years of public debate, public meetings and input from a broad spectrum of the local community and other interested groups."
"This monument proposal was a shock," said Wade Jensen, who herds sheep within the would-be monument area. "I have a grazing permit in the middle of that swell my livelihood depends on."
"You want to know what the people think? Take a vote before you dump it on us," said Kim Orndorff, who lives in Utah County but recreates in and plans to move to the San Rafael area.
Leavitt said the community will have a year or more to help flesh out a proposal in the area, about 40 percent of which includes wilderness study areas.
"I feel by the time action is taken, there will be broad support for this," he said.
Meanwhile, people want a well-defined process for gleaning input, said Paul Conover, who gathered "several hundred" signatures so stating from Carbon, Emery and Sanpete county residents.
Johnson was a bit surprised by the outcry.
"No question we misread the politics of this," he said. "But I don't know if there's any other way to launch this kind of idea . . . and not have them react in this manner."

http://deseretnews.com/dn/view/0,1249,380013559,00.html
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The deadline for postmarking your comments on the San Rafael Route Designation Plan is TODAY.

USA-ALL DESPERATELY NEEDS YOUR HELP!
WHAT YOU NEED TO DO:
Comment letters from OHV users are way behind the WAGs. Your letter need to be postmarked by TODAY (Monday, April 22, 2002) or Faxed to the Price Field Office by 4:30 p.m. (Mt. daylight time). Use the information below to help you write your letter.
OR
You can take advantage of the letter writer feature on USA-ALL's website by clicking here:
http://www.usa-all.com/wc.dll?wwusaall~LISTACTION

Thank you all so very much for your involvement. Ensuring the continued legacy of vehicle access and recreation to this unique region is worth the few minutes it will take to write a letter to the BLM. If everyone receiving this message would do so, our standing to challenge any unreasonable or unfair final decision would be set in concrete.
Brian Hawthorne Utah Shared Access Alliance

COMMENT SUGGESTIONS:
Comment letters must be postmarked by Monday, April 22. Faxes must be received by close of business today.
Address letters to: Price Field Office, Bureau of Land Management, 125 S. 600 W. Price, Utah 84501. Fax: 435-636-3657 or 801-539-4013 Address your letter to Tom Rasmussen.

* Tell the BLM just a bit about yourself and be sure to let her know if you have visited the Swell, or even plan to visit the Swell in the future.
*Ask them to adopt Alternative 1, sign the existing roads and trails, provide maps, engage in cooperative management efforts with ALL public land users.
*Ask that Junes Bottom, Entrada Gap, & Trin Alcove Bend overlook, Iron Wash as it passes through the reef, “The Purple
Trail” and the road through the reef along the Muddy River be left open. Insist that motorized access to overlooks of the Green River on existing routes be preserved.
* Inform them that any management policy or other specific management actions based solely upon a "citizens wilderness
proposal" is inappropriate, contrary to established BLM policy and illegal.
*Tell them that OHV users should not be punished for the BLM's failure to manage OHV use in the past. Ask her to instruct
the Price Field Office to immediately implement Alternative 1 and engage in positive OHV management solutions.
* Tell them you are offended at the anti-OHV bias contained in the San Rafael Route Designation Plan. Let them know that
you do not HARASS wildlife or RUN OVER FAWNS! Tell them how outraged you are and ask Tom to read the San Rafael
Route Designation Plan for himself to see if he can find one positive statement about you or your family within the text.

Be polite and be sure to include your name and address. Ask her to keep you informed of this and any planning activity in the
Price Field Office.

BACKGROUND INFO:
The San Rafael Swell is home to many wonderful roads and trails. The BLM has issued a draft travel plan for public comment and review. Today is the deadline. (Monday April 22, 2002) The plan and maps of the 4 alternative are available here: http://www.priceblmtravelplan.com/
It's a typical travel plan with the usual comment on alternatives. You know… “ I support alternative 1 and opposed the total closure alternative 2” kind of comments.

Brief run-down on the Alternatives:
Alternative 1 is the standard no action alternative. If implemented, it keeps open nearly all (many roads and trails didn't make it
on the inventory) the existing roads and trails open. It's not really a no action alternative because the BLM would actually sign
the roads and trails on the ground, provide maps, information Kiosks and enforcement. The BLM would also enter into several
cooperative management agreements with user groups. It is OUR preferred alternative.

The objective of Alternative Two is to close all of the good trails down in order to “provide maximum protection to natural,
scenic and wilderness-related values.” And Alternative 3 is pitched as the “balanced” alternative.

Here is what's different: The BLMs “Proposed Alternative”, (Alternative 4) is supposed to “provide additional motorized
opportunities… [but only when compared to alternative 3] …in the form of loop riding opportunities, access within certain
washes, and access to specific points of geological interest, while sustaining critical soils, scenic resources, crucial wildlife
habitat, and provide special management for certain vegetation, cultural, and historic mining resources, among others.”

Problems:
Many key roads and trails that provide important loop riding opportunities, access to specific points of historical interests and
provides a unique and valuable recreational experience are NOT included in Preferred Alternative. These routes DO NOT
damage critical soils, scenic resources, crucial wildlife habitat or other resources. It is VITAL that the BLM be informed of this
oversight and include the routes in the BLM’s Final Plan. (see list of routes below)

Additionally,
The Monitoring and Implementation plan, hidden at the back of the document, includes a provision that essentially gives
authority to manage OHV use over to any Wilderness Advocacy Group by stating: "All routes open for motorized travel in
WSAs and wilderness inventory areas, and citizen's wilderness proposal areas would remain under a "conditionally open"
status. These routes would remain open only if motorized travel does not impair the unit for designation. These routes would be
scrutinized more intensely by BLM monitoring than public lands with no wilderness values. Based on monitoring or any of the
above, restrictions on travel may be adjusted if anticipated impacts or expected results are not occurring."

Read that again. It says that a popular and legal recreational activity, occurring on legal travelways, is going to be designated as
"conditionally open", subject to intense scrutiny and future restrictions simply because it happens to occur on lands alleged to
have "wilderness character" by SUWA, or any other radical Wilderness Advocacy Group .

More Problems:
The Anti-OHV Bias is thick throughout the entire document. Nowhere in the text of the document is found one single positive
reference to OHV use, or those who engage in it. So blatant is the pervasiveness of anti-OHV bias in the document, that it
becomes appropriate to question the suitability of the author(s) to manage any public land resource other than wilderness. The
document is pregnant with examples illustrating this assertion. Consider just these two selected statements taken from the text
of the document:

When analyzing the effects of OHV use on Bighorn sheep the document states: "Because these routes would be open on a
year round basis, this alternative allows for the greatest amount of OHV harassment to bighorn ewes during the lambing
period." (page 47)

And when analyzing the effects of cross-country travel on Pronghorn Antelope it states: "This [eliminating cross-country
travel] would reduce the potential for fawns being run over by OHVs." (page 48)

We get more insight about the biased view of the author(s) of this document in the analysis of "cumulative effects" of vehicle
assisted recreational travel. The author describes the history of the area:

"In the past (more than 25 years ago), OHVs were typically considered to be trucks and motorcycles. Use of these
vehicles on public land was primarily to access range projects, grazing operations, and mining operations. Minimal
rock-hounding and recreational exploration occurred." The document concludes: "Publics that ventured into the San
Rafael Swell years ago were enveloped in a sense of isolation, rarely encountering another vehicle or person." (page 77)

Nowhere in the document does it discuss the fact that the entire San Rafael Swell (including existing Wilderness Study Areas)
was "trammeled" by mineral search activities culminating with the Vanadium and Uranium boom of the 50's. An uninformed
reader would easily conclude that, other than OHV activity, these lands are pristine, devoid of any human use or activity
whatsoever.

USA-ALL considers the roads left by the miners and prospectors to be national treasures to be cherished and preserved, not
be relegated to oblivion by biased and agenda driven persons who have no business managing OHV use. These roads need to
be conserved for future generations so that they might also experience the delights and joys of the natural beauty that has been so abundantly afforded us.