Today is the deadline for comments on what can be a huge, precedent setting RMP. The plan is to virtually eliminate the "open" designation, taking 1.2 million acres down to 4600!!! Below are my comments, use them as you see fit. BTW, from talking with Bill Papich at the BLM he said that there are so many comments on this that it has shut down the BLM mailbox dedicated to this, and most of those comments, in fact mountains of them, are the typical GAG duplications repeated a zillion times.

Here's mine:

Farmington RMP and DEIS comments

I would like to direct my comments to one specific area of the RMP, that of OHV use. On page 2-23 of the draft it is pointed out that 43 CFR 8340 provides for OHV use as a legitimate use of public land. OHV designations are divided into three categories, and I would like to address the category “open”. Per the draft on page 2-23 “open” may be designated if there are “no compelling resource protection needs, use conflicts, or public safety issues that would warrant limiting OHV use.”

The preferred alternative for the RMP proposes limiting the open designation to approximately 4600 acres, the present amount of open acreage is in the area of 1.2 million. The alarming reduction of open acreage per the plan will coincide with designating many SMAs that would limit OHV to existing roads and trails. It is my contention that this huge reduction in the open designation is unnecessary, and the designation of SMAs is unnecessary as well, if the BLM wants to spend money wisely it would be better spent on OHV education and a complete scientific study of the FFO.

The draft is full of assumptions about OHVs and their use, but as far as I can tell there is little or no factual information to back these assumptions up. For example, on page 4-14 the draft says: “The primary concern regarding OHV impacts on water resources is the potential for increased runoff and resulting erosion…Other concerns include the potential for small fuel spills from OHVs…” The word potential is used twice, yet no proof is provided that these problems actually exist, and in actuality it is very rare that these things do occur.

On page 4-24: “Due to the large amount of land (over 1.2 million acres) where cross-country OHV travel would be permitted, it is possible that OHV access could affect special status species…” Again, an assumption is made, and the draft proposes virtually eliminating the open designation due to an assumption, not facts. The law provides for species protection on critical habitat, but it does not provide for a mass change in usage designation based upon assumptions and not fact. This reason to eliminate the open designation is invalid, in fact it is illegal.

On page 4-31: “OHV use also occasionally results in direct wildlife mortality, harassment of wildlife, and wildlife abandonment of an area due to human intrusion. The degree of the effect of OHV use on wildlife on FFO land has not been determined…” Again an assumption is being used to eliminate the open designation, an assumption which is not backed up by any facts at all, in fact it even says that there are no facts. There is absolutely no mention of where this assumption came from or how it was arrived at.

On page 4-33: “Open OHV access would continue to generate conflicts between permittees and other land users because it has been shown to result in vandalism of rangeland improvements, cut fences, and harassment of livestock.” This is an out and out lie, there is absolutely no proof that this is so in anything other than isolated cases, the limited number of which provide no basis for elimination of the open designation.

On page 4-36: “Conflicts among OHV users, private property owners, and ranchers arising from unlimited cross-country vehicular access would continue under ongoing OHV policy.” This assumption is virtually identical to the one mentioned above, and it is just that, an assumption with absolutely no basis in fact.

The examples cited above are just representative samples from what I believe to be a very biased draft RMP/EIS. It is apparent that it is the intention of the writers to virtually eliminate the open designation in the FFO. If it is necessary to eliminate the open designation then the reasons must be based in fact, not assumptions. I am sure that there are areas that should be protected from open OHV use, but it is total nonsense to put forth the assumption that the open designation must be virtually eliminated to protect a limited number of acres. If it is the intent of the BLM to protect areas, then these areas must be identified, and the appropriate protections placed on those areas only. I have no idea how many acres in the FFO actually deserve and require protection, but I know it is not 1.2 million acres. Before any change is made to the OHV use designations in the FFO I am requesting that a complete study of FFO lands be made with specific areas that should be protected, and until then there should be absolutely no change in the current OHV management policy in the FFO. To make any changes at this point would be presumptuous, and possibly illegal without the proper scientific backing to justify such a major change.

I am requesting that the FFO continue with its current management policies until a fact based RMP/EIS can be accomplished. This will probably have to be a fairly long term and expensive project, but there is no other way to fairly, and in my opinion legally, to make such a large scale change in policy.

Thank you,

Brad Ullrich
XXXXXXXXXXX
Aztec, NM 87410
(505) XXX-XXXX

Short and to the point, they will be read, not just scanned over.