It doesn't look like there's much on here yet about it, so I figured I'd help enlighten everyone.


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.

This document will determine how recreation is permitted in the Moab area for the next 20+ years.

There will also be 4 meetings, and I hope we can get hundreds of OHV (and especially 4x4) users at each meeting.

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

Moab: 9/25
Monticello: 9/26
Grand Junction: 9/27
Salt Lake City 10/3

Anti recreation groups such as the Southern Utah Wilderness Alliance (SUWA) have staff to review the environmental analysis to find flaws that will nudge the final decision their way. Indeed, many stakeholders are paying for professional review of these documents in order to protect their interests. The OHV community must do this as well.

As always, funds for such an effort are limited. In order to raise funds for this important effort, BRC is initiating the "Moab Partnership" program.

Partners make a pledge of $10.00 per month or make a one-time Partnership donation of $120.00 to enroll for one year. Your donation is placed in a restricted account to be used for efforts related to the BLM's Moab and Monticello Field Office planning processes.

BRC's Moab Partners will receive the Moab Update, a special quarterly newsletter dedicated to the latest news on BLM's planning process. The Moab Update will keep you informed about how your donation is being used and is the best way to keep informed about potential changes in the Moab area. In addition, BRC's Moab Partners receive a limited edition "Moab Partner" T-Shirt and sticker combo. Check the details on BRC's Moab Partnership page: http://www.sharetrails.org/public_la...?section=Moab2

We are going to need a full team of legal professionals, NEPA experts and even biologists if we are going to stop the unfair and arbitrary closures. That will require a commitment from the very people who enjoy this wonderful area. This is why joining our Moab Partnership is so important.

I want to thank you in advance for your help. Together, we can keep this spectacular recreation destination open.

David Adams
Red Rock 4-Wheelers Land Use Officer

Here is a very good summary of the alternatives for those of you who don't want to read all 1300+ page!

From Jeff Stevens, a friend and local trail advocate,

"The Draft RMP has just been released, and it is already causing a major uproar from both the OHV'ers and the SUWA-types. But before everyone starts flooding the BLM offices with hate mail (that will just get round-filed), we need to understand the alternatives so we can make meaningfull comments, comments that might actually make a difference!

Now, I haven't had time to thouroughly analyze anything yet, so what I am going to say is preliminary and very abbreviated, and some facts may certainly be wrong, but that just proves that we need to take our time and understand this thing.

Alternate A (No change). This will never happen. Do you really think that BLM spent the last 5 years or so working on this thing, just to stay with what is currently in place?

Alternate B (Most restrictive for OHV's and commodity extraction). We need to let BLM know that this alternative is not acceptable, but we need to give them specific reasons why. (More on that later.) Also, it is important to note that as currently written, it appears that no jeep safari trails would be closed under this alternative, although I did read where someone said that Potato Salad Hill would be closed.

Alternate C (Prefered by BLM). It is very likely that this Alternative (likely with some revisions) will be the one chosen. No Jeep Safari routes would be lost. There would be a relatively small "open" area (White Wash Sand Dunes), but it would be much smaller that is now open. Most (if not all) trails and roads would be "designated" as opposed to "existing", meaning they are closed unless shown as open on BLM's map. According to my source at BLM, most of the roads that will be closed (yes, there are lots) are old siesmograph lines that Grand County has abolished in thier travel plan. There are also several areas called "Areas of Critical Environmental Concern" (ACEC's). These areas have different management goals, which potentially could affect trails within the areas at some point.

Alternate D (Least restictive for OHV and commodity extraction). Same as C, except fewer roads would be closed, and a somewhat larger open area is provided at White Wash sand Dunes. All routes would still be "designated". Also, if I remember correctly, there would be no ACEC's.

So, what do we do? In my opinion, we need to support Alternate C or D, and give specific information as to what we want changed. For example, we need to say "such and such trail has historically been used as a jeep route, and is important for blah blah blah, and should therefore remain open in the travel plan". This type of info carries more weight, and is more usefull to BLM.

Now, this document is huge, and most people will understandably not be able to read and analyze the whole thing. If you can, that's great... please post to let everyone know what you found. For the rest, this is where we need to trust organizations like BRC and U4WDA for specific comments. Be patient, they will let us know what they find out in time for us to comment.

Moab Friends-For-Wheelin' is in the process right now of going through the DRMP. Ber Knight (member of MFFW and RR4W) is comparing every trail on the BLM's maps to his own trail maps. (Believe me, he has been on all of them.) He reports a few omisions so far, but also some surprises that we didn't think we would get. From a jeeper's standpoint, this may be the single most important thing we can do, identify specific trails that are or are not on the maps. When we finish, I will post the results, but it will probably take a few weeks.

Sorry for the long post, but this is extremely important. Please try to attend the public meetings if you can, and please send in your comments. But also please try and make those comments count, with accurate and specific information."

I'll post more in the coming weeks when I get more info.

OK, last one for now.

From Steve Jackson, President - Utah 4 Wheel Drive Association

"For anyone playing along at home:

http://www.u4wda.org/moab/

Just made a quick comparison of designated routes for Alt B (SUWA) vs Alt D (OHV/Extraction). Move your mouse over the image to see the difference. It's only a small section of the map, but it gives an idea of what will be lost. The one that jumps out at me is the loss of the Cache Valley Road that heads east out of Arches NP.

Keep in mind that this is only the comparison of the designated routes. Existing routes could 2x as much, and those routes will be lost once the area is changed to designated routes only."

We are literally talking about 1000s of miles of roads which can/will be closed!!

Does nobody care about Moab, or are you all too busy reading the draft and writing comments?

I care....

I still need to download that DEIS and go over it.

I would also like to forward all the info, notes, handouts, ideas we brainstormed etc. that we have done in ELDO to someone that could use them in MOAB.

OMG!!

Of COURSE they would have an online form and a way to organize your comments.

Didn't I suggest that for ELDO?

http://www.blm.gov/rmp/ut/Moab/comments.php

Holy crap I thought our DEIS was bad at 789 pages, yours is 954!

Get people to attend those meetings, that is the most important first step.
the more people that are involved, the more comments will be submitted.

I was cruizin that DEIS,

There is stuff just BEGGING for comments!

What the hell do abandonded mines have to do with WHEELED access? A hiker could reach the same mine...

illegal dumping? Closing routes would make it easier NOT to get caught and harder to get stuff out...

Gas and Oil exploration?

I was cruizin that DEIS,

There is stuff just BEGGING for comments!

What the hell do abandonded mines have to do with WHEELED access? A hiker could reach the same mine...

Abandoned mines are critical habitat for bats. While there are many bat species that are not at risk, there are a few that are considered "species of concern" and are being proposed for ESA listing. Also, the BLM is on a kick to ensure public health and safety from 2 aspects:

1. Seems there are several instances when people have been injured or killed by driving into an open mine shaft.

2. There mine tailings are often a place where significant hazardous elements exist. While some California sites have their arsenic concentrations, many of the Utah mines are former uranium mines.

illegal dumping? Closing routes would make it easier NOT to get caught and harder to get stuff out...

This is hot-button issue with me. When the local cities/counties increase dump fees or make it more difficult to dump, public lands tend to receive the "stuff". I have come across some illegal dump sites that are very evident to be toxic in composition. Electronic, large appliances, mattresses, construction materials, and various liquids are becoming more common items dumped on public lands.

Gas and Oil exploration?

You need to look into the other energy components: wind, solar, and geothermal are becoming big issues WRT access to public lands.

See my article about "Geothermal development, a thousand little gates?" in the September issue of the BlueRibbon Coalition magazine.....

John, I understand Kurt's question, and your answers, but for the most part, with no disrespect intended, your answers are not specific to his question, which is the subject these DEIS documents should really be addressing as part of the Route Designation / Travel Management process: WHEELED ACCESS. The health of the bugs and bears and bunnies and bats is important, but unless clear linkage exists to motorized recreation, the discussion is not germaine to Route Dez and should be left out of this DEIS.

Unless there's established, documented proof that OHVs interfere with bats in mines, this DEIS needs a comment. "Please remove this section or add a summary statement to the bottom that no relationship has been proven to exist between the health of bat population and trail-based OHV recreation." It is lovely that they are a 'species of concern' and all, but we can't let threatened, listed, or endangered species knee-jerk us into limited access unless good science indicates a relationship between OHV and bats. Besides, the bats near Gotham seem to THRIVE in a cave/tunnel system frequented by OHVs. :p

It would be simple to write similar comments about trail-based OHV recreation and these claimed public health and safety concerns. If OHVs are on the trail, mine shafts shouldn't be a problem; if they are off the trail, then THAT is the problem, not the mineshafts or tailings that they might encounter. The agency should be encouraged to fix the primary problem, not the secondary what-if scenario.

As for gas and oil exploration, IMHO, those should be excluded from discussion in the DEIS unless a clear plan exists for extraction of mineral resources against which Route Designation can be evaluated. Basically, there's no place for speculation in an EIS, and if the oil/mineral plans aren't available yet, this Route Dez DEIS needs to move forward without them, and the subsequent oil/mineral DEIS needs to be considered against the resulting Route Dez EIS. If the oil/mineral plans ARE available, then certainly consider them in Route Dez, but make damn sure that the economics of both are considered. In the Eldorado National Forest, the DEIS specifically excludes OHV economic impacts from scope, but has an extensive discussion of the economics impacts of grazing permits... I've got a letter prepped which nails them on this: they can't use economic impacts in one place to argue against OHV use and fail to consider the far greater economic impact to the area counties due to the loss of OHV recreation.

In summary, I recognize that there are MANY issues relevant to an EIS document -- the trick is to keep the agency folks honest, and make sure they use legitimate, well-considered arguments. Every EIS document that I have seen thus far includes everything the agency can think up to support whatever point they are trying to make, but far too few of them have been commented to point out the many red herrings and non sequiturs as what they are.

Randii

Wow, look what they even POST:

How to Comment on this Draft RMP/EIS

Your comments are important to us, as public comments play an integral role in the planning process. All comments on the Draft RMP/EIS are welcome. Comments may include those on inaccuracies and discrepancies within the Draft EIS. Comments may discuss the adequacy of the analysis presented; interpretations of analyses should be based on professional expertise. Comments may identify new impacts, recommend reasonable alternatives, or disagree with the determination of significance. Expressions of personal preferences, while not requiring a response, will be summarized. Please include a reference to the page number and/or section number of the document when commenting.

I read a little more of the DEIS today...

It is SO full of holes it's not funny. Most if not all of the stuff in it has NOTHING to do with motorized recreation.


Thier is NO decription of motorized recreation or studies of motorized recreation in it. The document just ASSUMES OHV's do damage. They also do not take into consideration which types of OHV etc...

John, I understand Kurt's question, and your answers, but for the most part, with no disrespect intended, your answers are not specific to his question, which is the subject these DEIS documents should really be addressing as part of the Route Designation / Travel Management process: WHEELED ACCESS. The health of the bugs and bears and bunnies and bats is important, but unless clear linkage exists to motorized recreation, the discussion is not germaine to Route Dez and should be left out of this DEIS.

Unless there's established, documented proof that OHVs interfere with bats in mines, this DEIS needs a comment. "Please remove this section or add a summary statement to the bottom that no relationship has been proven to exist between the health of bat population and trail-based OHV recreation." It is lovely that they are a 'species of concern' and all, but we can't let threatened, listed, or endangered species knee-jerk us into limited access unless good science indicates a relationship between OHV and bats. Besides, the bats near Gotham seem to THRIVE in a cave/tunnel system frequented by OHVs. :p

It would be simple to write similar comments about trail-based OHV recreation and these claimed public health and safety concerns. If OHVs are on the trail, mine shafts shouldn't be a problem; if they are off the trail, then THAT is the problem, not the mineshafts or tailings that they might encounter. The agency should be encouraged to fix the primary problem, not the secondary what-if scenario.

As for gas and oil exploration, IMHO, those should be excluded from discussion in the DEIS unless a clear plan exists for extraction of mineral resources against which Route Designation can be evaluated. Basically, there's no place for speculation in an EIS, and if the oil/mineral plans aren't available yet, this Route Dez DEIS needs to move forward without them, and the subsequent oil/mineral DEIS needs to be considered against the resulting Route Dez EIS. If the oil/mineral plans ARE available, then certainly consider them in Route Dez, but make damn sure that the economics of both are considered. In the Eldorado National Forest, the DEIS specifically excludes OHV economic impacts from scope, but has an extensive discussion of the economics impacts of grazing permits... I've got a letter prepped which nails them on this: they can't use economic impacts in one place to argue against OHV use and fail to consider the far greater economic impact to the area counties due to the loss of OHV recreation.

In summary, I recognize that there are MANY issues relevant to an EIS document -- the trick is to keep the agency folks honest, and make sure they use legitimate, well-considered arguments. Every EIS document that I have seen thus far includes everything the agency can think up to support whatever point they are trying to make, but far too few of them have been commented to point out the many red herrings and non sequiturs as what they are.

Randii

Randii:

I am working with a number of different projects and should spend more time on some responses.

The point I was trying to make is that within the context of a DEIS, the agencies are putting everything into the discussion bucket.

Part of me wants to say that you are correct that discussion of anything not related to motorized access is not part of the discussion and should be droped.

HOWEVER, keep in mind that it is important to understand the context that issues are put into a plan.

As your current frame of reference is the Eldorado plan, there are numerous subtle differences between a "forest" plan and a "BLM" plan. Key element is the BLM will pull in the fringe issues of mines and access to them as BLM is tasked with dealing with active and abandoned mine issues. In general, a forest plan will not address those types of issues.

And, BLM is mandated to discuss "multiple use" aspects. Within that context, mining issues (oil and gas exploration) are important issues that you will not generally find in a forest plan.

Overall, route designation from a Forest Service perspective is different that route designation from a BLM perspective.

Both are similar in they restrict access. However, the FS has fewer issues to address in their access plans.

Yes, the trick is to keep the agencies honest. To do that, you need to address the issues that are within the agency responsibility.

If the RMP (BLM speak for Resource Management Plan which is equivalent to Forest Service LRMP - Land and Resource Management Plan) brings in an issue, it has been deemed appropriate within the scoping phase. As such, it does need to be addressed within context of its impact on the overall plan.

To say that is a "red herring" and should not be part of the discussion is not a substantive comment.

The agencies take an everything-but-the-kitchen-sink approach, and that a substantive comment *can* be a request for removal... or a request that they specifically note that there is no proven correlation between *whatever* and trail-based OHV travel. My post above contains a sample of what I' suggesting -- I know it isn't substantive to say yank it because it is a red herring on non sequitur -- you have to spell it out.

Context is important, but we have to make sure their context doesn't imply something their data fails to back up... (mining seems like this to me, but I need to read more in the Moab DEIS after I finish working on the ENF).

Certainly many of the topics in the DEIS are germaine to discuss, but just because it is in there is not sufficient to assume that it NEEDS to be in there, IMHO. The flip side is true, as well: just because it is NOT in there does not necessarily mean that it SHOULDN'T be in there, IMHO... basically, the whole thing is fair game -- if you can make a coherent case, then don't be afraid to comment it!

I'm no expert on BLM plans (hell, I'm no expert!), but I'm game to comment anything with a reasonable basis... EIS docs are fairly well-regulated, and have to fit CEQ requirements, regardless of agency, right?

Randii

The agencies take an everything-but-the-kitchen-sink approach, and that a substantive comment *can* be a request for removal... or a request that they specifically note that there is no proven correlation between *whatever* and trail-based OHV travel. My post above contains a sample of what I' suggesting -- I know it isn't substantive to say yank it because it is a red herring on non sequitur -- you have to spell it out.

The agency is required to assess the impacts of actions on the physical, biological, and human environment. In reality, "everything-including-the-kitchen-sink" approach is used as it provides a potential path to litigation free actions. The agency can be sued for not assessing an impact.

Context is important, but we have to make sure their context doesn't imply something their data fails to back up... (mining seems like this to me, but I need to read more in the Moab DEIS after I finish working on the ENF).

The context is described in the introducing or "scope" section. The ENF DEIS is a "travel management plan" which limits its scope to factors related to travel management on the forest. The Moab DEIS is an RMP which is more inclusive than a limited travel management plan. Agencies are required to address travel management. While they are not required to address them in separate documents, they are often separate documents.

Certainly many of the topics in the DEIS are germaine to discuss, but just because it is in there is not sufficient to assume that it NEEDS to be in there, IMHO. The flip side is true, as well: just because it is NOT in there does not necessarily mean that it SHOULDN'T be in there, IMHO... basically, the whole thing is fair game -- if you can make a coherent case, then don't be afraid to comment it!

An EIS (environmental impact statement) is a generic term for the document produced. There are other labels that will define the purpose of the document as established by specific agency rules. When an EIS is referred to as "programatic", it does not contain a detailed analysis of specific actions and their effects on the environment. It will provide a general outline for site specific action analysis on subsequent documents.

A good analogy is a programatic EIS is a "zoning plan". Site specific actions are variances from the general zoning plan. Three or four years ago, the Forest Service implemented planning rules that states their LRMPs would be "programatic" in nature with the intent of streamlining the process. BLM has yet to move in that direction.

I'm no expert on BLM plans (hell, I'm no expert!), but I'm game to comment anything with a reasonable basis... EIS docs are fairly well-regulated, and have to fit CEQ requirements, regardless of agency, right?

Randii

NEPA establishes a process that outlines federal agency responsibilities and guides public involvement in developing an EIS. NEPA carries no enforcement mechanism. The courts are the ones to enforce the NEPA process.

CEQA (California Environmental Quality Act) applies only to the state actions and carries a requirement to "disclose" the impacts of actions when the state is involved.

For example, if a project is carried out on federal lands with federal funds, CEQA is not an issue. However, if a project on federal lands is funded total or in part by the state, the project is subject to CEQA review.

CEQA does carry a "functional equivalent" clause under which a public meeting can be used in lieu of a formal document. The Dept of Fish and Game and the DFG Commission use that tactic.

Under that clause, a NEPA developed EIS "should be" a "functional equivalent" of a CEQA document. To my knowledge, that has yet to be tested in the courts.

I do know that it is easier to file a lawsuit under CEQA than NEPA. CEQA requires disclosure of actions; not assessment of impacts.

The agency is required to assess the impacts of actions on the physical, biological, and human environment.

Ok, taking this sentence and boiling it down simply (becuase you guys are losing me here a little)

Moab's EIS reports on all these differnet factors like mines, bats, birds, rocks, bushes etc... They way I read it, it's just reporting on the current status of those factors.

I do not see any description of wheeled motorized activity and how it MAY effect these factors. How can you assess the impact of an action if you do not descibe what you are trying to remove. Don't they need to PROVE wheeled access hurts the little bats in the cave?

If this RMP IS NOT a "travel management plan" then WHAT does it do other than restrict access to wheeled vehicles? All of the alternatives are maps with less and less access right? Is this not just the same thing packaged differently?

What else can the BLM office have control of OTHER than recreation?

Ok, taking this sentence and boiling it down simply (becuase you guys are losing me here a little)

Moab's EIS reports on all these differnet factors like mines, bats, birds, rocks, bushes etc... They way I read it, it's just reporting on the current status of those factors.

I do not see any description of wheeled motorized activity and how it MAY effect these factors.

If this RMP IS NOT a "travel management plan" then WHAT does it do other than restrict access to wheeled vehicles? All of the alternatives are maps with less and less access right? Is this not just the same thing packaged differently?

What else can the BLM office have control of OTHER than recreation?

Correct, it is reporting on the current status of the factors.

The RMP is a total resource management plan which includes a "travel management" component. As such, it is looking at the impacts of man and the effect on the natural environment.

As such, the major impacts are defined as motorized access and the alternatives are structured to reduce access to protect the natural environment.

To an extent it is a travel management plan in a different "package". However, it does deal with more that just motorized recreation.

BLM has several other programs that will tier off of this document: grazing, mining and energy development.

In California, grazing is not a big issue in national forests as it has been radically reduced in recent years. Inyo NF still has some grazing allotments. I am not sure which other CA forests still maintain grazing allotments. Grazing allotments are major component of BLM plans as is mining.

Energy development is becoming a big issue with public lands; especially BLM lands.

In general, access to public lands was initially established for the "extraction" industries: mining, grazing, and logging. Recreation is replacing "extraction" as the use of access routes on public lands.

The simple answer to Kurt's question is that the BLM's Resource Management Plans (RMP) addresses all of the programs in the Field Office including, minerals, forestry, grazing, recreation, wildlife, and many others. It is the guiding document the BLM will use for the next 20 years or so for that area for all programs, not just motorized travel.

Look in the recreation or travel managment sections if you are intersted in motorized access.

While travel managment is addressed this BLM RMP revision is not the same as the Forest Service Route Designation Process.

However, please make comments, on any program you have an issue with. They are considered and recorded in the final document. Many comments are incorporated and changes to the draft are made.

Hope this helps.

Here's the problem, no matter WHAT type of EIS it is....

All these EIS's state the status quo and propose an "alternative" or plan HOWEVER:

1. They do not show or prove in anyway, that wheeled motorized access hurts the enviroment. There are NO studies of how much damage OHV's have done to the enviroment

2. They do not SHOW that any percieved harm by wheeled access is signifcant enough to demand a change. I realise that they are MANDATED to draft a policy, but they should have to show WHY they are enacting a new alternative. There are MANY more things that damage the enviroment than OHV's, Logging, mining, cattle, mother nature etc.... it's just that recreation is the ONLY thing they can close down.

3. Thier only plan is CLOSURE not MANAGEMENT. :shaking: Instead of fixing repairing routes trails and damage, they CLOSE routes...

4. There is no proof or studies in the EIS that the closures will FIX the problems. In fact, by funneling all the OHV use (which by theri admission is GROWING) into a smaller area will create MORE damage.

5. There are no studies on the effects of the perferred alternative. ESPECIALLY when it comes to the economy of the surrounding area...


It's basic policy debate stuff...

If you are going to propose a new policy:

1. You must show that there are HARMS in the staus Quo.

2. You have to show that those harms are significant enough to demand a change.

3. You must develop a plan/policy that will FIX those harms in the Status Quo

4. You have to show that your plan/poicy (Alternative) will FIX the problems in the status quo.

If we just argue for specific routes to be included on the maps, we are being re-active.

LET'S BE PROACTIVE!

I am proposing directing comments AT the DEIS. Attack the wording and the content in it. Attack the PROCESS. They HAVE to address every comment. If we slam them with thosands of comments about the wording and the process, we not only help set up legal standing for later, we become a MAJOR pain in their ass. WE should dictate what the EIS says and/or includes....

Kurt just said this better and simpler, IMHO, but I am adding in what I was typing elsewhere, nontheless.

In reality, "everything-including-the-kitchen-sink" approach is used as it provides a potential path to litigation free actions. The agency can be sued for not assessing an impact.
...but some agencies specifically exclude OHV economic impact from comment. This will be a huge impact to Moab -- let's make sure that it gets as many pages as the other issues!

BTW, I meant CEQ (the Council on Environmental Quality), and not CEQA (California Environmental Quality Act). I do understand the differences between NEPA and CEQA process. :p

We're talking around in circles, and I'd like to have this conversation more fully, but lack the time today. I see no problem in commenting the Moab DEIS to keep them honest with respect to Travel Management (or any other name). I believe it will be advantageous to ask them to do one of the following things:
* exclude MANY sections
* document them better to prove a direct relationship between whatever they document concern for and OHV
* ask them to include a specific sentence that states that no direct relationship has been proven This is a simple thing, and it frustrates me how complex they (and we) are making it...
Be sure they aren't using suspicion and assumption to close OHV trails. Call them on that each and every time you see it -- if they are using a bug, bunny, or bat to limit recreation MAKE THEM STATE THE RELATIONSHIP BETWEEN TRAIL-BASED OHV RECREATION AND THE CRITTER.. Since the BLM EIS documents have a broader scope than Forest Route Dez EIS docs, I suggest that we focuse our efforts on the Travel Management section, and make sure the relationships between OHV use and other resources are made clear.

Randii

Holy crap I thought our DEIS was bad at 789 pages, yours is 954!

It's not "yours" or "ours" because it is ALL "ours." We need to stop the idea that closures 1000 miles away don't affect public land close to home. I'm glad to see so much activity related to the ELDO RDP situation, and I hope the enthusiasm carries over to all the other public land closures the motorized community faces across the country.

I read a little more of the DEIS today...

It is SO full of holes it's not funny. Most if not all of the stuff in it has NOTHING to do with motorized recreation.

It's a DRMP/DEIS for management of a huge area covering multiple forms of recreation and other uses.


If this RMP IS NOT a "travel management plan" then WHAT does it do other than restrict access to wheeled vehicles? All of the alternatives are maps with less and less access right? Is this not just the same thing packaged differently?


As others mention, there's a huge difference between management objectives and implementation of travel routes.


What else can the BLM office have control of OTHER than recreation?

Livestock grazing, timber production, extractive industry, development, and on and on. There's a LOT more to public land management than OHVs or any other form of recreation.

Here's the problem, no matter WHAT type of EIS it is....

All these EIS's state the status quo and propose an "alternative" or plan HOWEVER:

1. They do not show or prove in anyway, that wheeled motorized access hurts the enviroment. There are NO studies of how much damage OHV's have done to the enviroment

Unfortunately, there are many.


2. They do not SHOW that any percieved harm by wheeled access is signifcant enough to demand a change. I realise that they are MANDATED to draft a policy, but they should have to show WHY they are enacting a new alternative. There are MANY more things that damage the enviroment than OHV's, Logging, mining, cattle, mother nature etc.... it's just that recreation is the ONLY thing they can close down.


Not true. BLM FO's (and FS units) restrict all forms of use to varying degrees to support their primary mission: managing the land as an asset for continued use by the USA.


3. Thier only plan is CLOSURE not MANAGEMENT. :shaking: Instead of fixing repairing routes trails and damage, they CLOSE routes...


Please see my "rant" on the purpose of land management below. Closure is a form of management. If they don't have the resources to manage OHV recreation the right way, then usually damage is the result. With no enforcement, maintenance or education (due to lack of resources), the users will literally "run wild."


4. There is no proof or studies in the EIS that the closures will FIX the problems. In fact, by funneling all the OHV use (which by theri admission is GROWING) into a smaller area will create MORE damage.


It's not ideal, but this is what we're faced with until we as a community (with partners in the private sector) can fill the gap.


5. There are no studies on the effects of the perferred alternative. ESPECIALLY when it comes to the economy of the surrounding area...


Chapter 4, Environmental Consequences of Alternatives:

http://www.blm.gov/style/medialib/blm/ut/moab_fo/rmp/draft_eis.Par.27508.File.dat/CHAPTER4.pdf

"Rant:"
People need to understand these processes from the perspective of the land managers. Realistically, there is no secret plan within the BLM or FS to remove OHV access from public lands. These agencies are charged with managing the land in their care as an asset for the beneficial use of the United States of America. Recreation, mining, grazing, timber, and all the other uses are subject to the primary mission: protect the viability of the land. There is no desire to remove OHV access. In fact, there would be support for more access to alleviate strain on smaller and smaller areas. In fact, most land managers would welcome the opportunity to increase budgets and staff to properly manage OHV and other forms of recreation. The reality is that budgets continue to shrink. Therefore, sacrifices have to be made. When there isn't money for enforcement and maintenance, unmanaged OHV recreation literally runs wild. The BLM and FS are not managing these lands for our recreational use. They are managing these lands to be assets for the next 100, 200, 500 years. Closure becomes a tool to protect a resource when unmanaged recreation becomes a problem.

How do we solve this?

We can fight for legislation to increase budgets and mandate that X% of the increase must go towards management of OHV recreation.

We as a community (along with private sector partners) can fill the gap left by shrinking budgets. Peer enforcement activities, volunteer maintenance projects, education initiatives, joint grant proposals, and other activities initiated by our groups can help stem the trend of OHV closure. It's happening, but the pace is FAR too slow, and the general community is FAR too uninterested. How many members on Pirate? How many reads on posts in the land use section? 'Nuff said.

I hope that most won't attack how it should be, and rather seek to understand how it actually is. Understanding the system and its parameters is the first step to acheiving our goal of protecting access.

Back to the Moab RMP. We should hopefully have some more information available soon regarding specific route closures, and other specific issues that can be commented on.

For now, I hope every is planning on participating in a National Public Lands Day activity.

For Utah folks:

http://www.u4wda.org/npld

http://www.u4wda.org/af

Read the sig.

Closure is a form of management. If they don't have the resources to manage OHV recreation the right way, then usually damage is the result. With no enforcement, maintenance or education (due to lack of resources), the users will literally "run wild."
Yes, but with significant education, representative monitoring, and passive forms of enforcement, combined with Adopt-A-Trail maintenance, fewer resources are required. Let's make closure the LAST management option... not the first one. Decreasing budgets are reality, but let's get creative about doing more with less, with new ideas and volunteer involvement.

"Rant:" People need to understand these processes from the perspective of the land managers. Realistically, there is no secret plan within the BLM or FS to remove OHV access from public lands.
I'll agree that there's no secret -- these agencies are lobbied openly by anti-access activists to remove OHV access. Even *if* you do have a responsible, even-handed land manager, his staff is significantly stacked with anti-access professionals from PEER and the like.

I'm all for responsible management -- but we need to spend at least as much time and money swaying land management professionals are way as is spent swaying them against us. Protecting the resource is important, as is managing it for MULTIPLE uses -- Chief Bosworth specifically called out OHVs as a "legitimate use," but the part of the speech that gets press is the part where the Chief listed unregulated use as a significant threat.

Randii

I have to respectfully disagree... Closure is not management.

I will admit, I have NEVER been to MOAB, but in ELDO, I have NEVER seen the FS work on ANY OHV routes or dirt roads (other than putting up gates and boulders to block them off) They are getting $$ to fix them, so where is that $$ going? I would suspect it's mis-managment of funds. The only people that I have seen work on routes in ELDO are groups such as FOTR.


With the OHV effects in MOAB, what I am trying to point out is that IN THIS EIS, there are no studies or evidence that OHV travel effects the enviroment IN MOAB. It is just taken as a given. While there are many studies out there, where is a study specific to MOAB? I could not see anywhere where they cite a source. What percentage of the actual land in MOAB has been damaged by OHV use and how? What TYPES of OHV use does what type of damage? Is the yellow-bellied grounghog REALLY being damaged when the majority of OHV use is limited to routes? What percentage of the total land is OHV travel allowed on? I would bank on a very small percentage since cross-country travel is limited....

It says that in the no-action alternative, cross country travel is limited to game retrieval, antler collection and commercial/group events that are organized. (All this will end in the perferred alternative by the way) I cannot see THOUSANDS of people on ATV'S out collecting antlers.....

I went back thru that entire link you posted....

Here is about ALL they have on the economic effects of closing recreational routes:

With the trend toward increased recreation within the MPA, user conflicts are likely to remain an
issue regardless of the alternative selected. User groups, as defined in Section 4.3.10, include
motorized (on-road), motorized (off-road), non-motorized, non-mechanized, river floating, and
specialized recreation. Increases in conflicts among user groups have the potential to adversely
impact visitor experience to the area. The adverse impact to visitors regarding their recreation
experiences would likely be short-term. However, long-term adverse impacts to the county's
economy could be possible, as users might choose to recreate in other areas where they feel they
are more likely to have a positive recreation experience. This would contribute to a loss in
traveler spending in the area.

They admit there will be a loss, but how much and how bad? It COULD be possible???

I apologize, I am just pissed off and I do not want to just bend over and take this.

Kurt:

Your observation about lack of solid economic data is noted as a major issue. There is a basic lack of good (comprehensive/inclusive) economic data in ALL management plans.

I have been scouring the internet for economic data/studies and have found a few. I am getting them organized and will be posting what I have within the next week.

When I say "economic data/studies", there are two points that need to be clarified.

Demographics - describes the individuals and the type of activities.
Economic - describes the financial impact associated with the "demographic".

I have a lot of "demographic" information already available at:

http://www.muirnet.net/NoteTaker/FS-Stats-Trends.ntweb/?1

I am working on the "economic" component.....

These discussions go right back to the purpose of this original forum post -- the Moab Partnership initiated by the BlueRibbon Coalition to get us all on the same page, supporting this important area for our recreation, and saying the right things so we are on the same page.

There is a lot to learn as we all work our way thru these processes and new terms:
BLM, USDA Forest Service, EIS, DEIS, ROD, CEQA, EIR, etc.etc.

This is the time for education and research on the part of each of us from my epxerience. Find the experts and experienced folks and learn the lingo from them. John Stewart is a pretty darn good NEPA and process guy. Visit his site and do some homework: www.muirnet.net
My site is the one stop for getting involved in general and if you want more of that and NEPA, you can sign up for my Leadership course.

BlueRibbon has some great web pages as well (Public Lands button).
Cal4 and other state associations have land use and get involved pages.

My point is, that after doing this land use and access stuff for 25 years, I can tell you that you will be an EXPERT when you know what you don't know and what questions to ask.

Del

Yes, but with significant education, representative monitoring, and passive forms of enforcement, combined with Adopt-A-Trail maintenance, fewer resources are required. Let's make closure the LAST management option... not the first one.

I never said closure is a preferrable option. That's why I volunteer 20+ hours/week with U4WDA and other groups. We can stop it, but we're not doing it fast enough.

Decreasing budgets are reality, but let's get creative about doing more with less, with new ideas and volunteer involvement.

We've got more ideas than we could ever implement. "Volunteer involvement" is what we need. There is no lack of ideas. There is a lack of manpower to implement those ideas.

I'm all for responsible management -- but we need to spend at least as much time and money swaying land management professionals are way as is spent swaying them against us.

No doubt. Where is the money to do this? How can we get more than 1.5% of users to donate so we'd have the money to do this? We're slowly building the ranks, let me know to increase the pace.

Protecting the resource is important, as is managing it for MULTIPLE uses

Protecting the resource trumps everything else, and that's what I'm trying to get across.

Chief Bosworth specifically called out OHVs as a "legitimate use," but the part of the speech that gets press is the part where the Chief listed unregulated use as a significant threat.

It's even worse than that. Most references to the "4 threats" quote it as "OHV use" rather than "unmanaged OHV recreation" as it was actually said.

I have to respectfully disagree... Closure is not management.

Well, I respectfully disagree also. It is a form of management. Certainly not a form that I would prefer or encourage, but it is a valid method for acheiving a goal of protecting resources. My objective is to remove the excuses that validate closures such as illegal user-created routes, trash, resource damage, etc.

I will admit, I have NEVER been to MOAB, but in ELDO, I have NEVER seen the FS work on ANY OHV routes or dirt roads (other than putting up gates and boulders to block them off) They are getting $$ to fix them, so where is that $$ going? I would suspect it's mis-managment of funds. The only people that I have seen work on routes in ELDO are groups such as FOTR.

I'm sure you'll admit that you aren't fully aware of EVERYTHING going on in the forest at any given time. How many contacts in the affected districts do you have? How often do you speak with them. While they may not be doing as much as we'd like, they are doing something (however minimal it might be). I suspect a big part of their budget will be for enforcement (even though it might only represent 3-4 FPO's for such a large area).


With the OHV effects in MOAB, what I am trying to point out is that IN THIS EIS, there are no studies or evidence that OHV travel effects the enviroment IN MOAB. It is just taken as a given. While there are many studies out there, where is a study specific to MOAB? I could not see anywhere where they cite a source. What percentage of the actual land in MOAB has been damaged by OHV use and how? What TYPES of OHV use does what type of damage? Is the yellow-bellied grounghog REALLY being damaged when the majority of OHV use is limited to routes? What percentage of the total land is OHV travel allowed on? I would bank on a very small percentage since cross-country travel is limited....

Some of that is here, although it might not be as detailed as you are requesting:

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


I apologize, I am just pissed off and I do not want to just bend over and take this.

Well don't think any of us are sitting around getting lubed up. :D

We're doing as much as we can with the resources we've got. I'm trying to dispell some of the misconceptions out there. People need to look at this from the land manager's perspective. They don't necessarily WANT to close OHV access. They MUST close OHV access because of damage, lack of management resources, and jackass users (no matter how small the percentage is). If we remove (educate) the jackass users and resource problems then we remove their excuses for closure.

Just saying "we want recreation opportunities" isn't enough. We need to help the land managers solve the problems they are facing that lead towards closure.

Donate to the BRC Moab Partner program to review and fight the DRMP/DEIS:

http://www.sharetrails.org/public_lands/index.cfm?section=Moab2