USA-ALL ACTION ALERT
LAKE POWELL PWC COMMENT PERIOD SET FOR NOVEMBER 27
THE TIME FOR ACTION IS NOW
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Dear Friends,
USA-ALL's first and best mission in life is to educate you, the
recreationist, so you can become active participants in the land use
battle. That's why our ACTION ALERTS always contain detailed background
information, and this is why our members and supporters are the most
active and effective Access Advocates anywhere. We're proud of that.

But sometimes folks don't have the time for all the details and just
need the quick and dirty. If that's you, scroll down to "USA-ALL's TWO
STEP PROGRAM TO BEAT THE ANTI-ACCESS ZEALOTS" below.

This information will be posted on our website soon. Please forward this
alert to all friends and family who own PWCs.
Thanks,
Brian Hawthorne
Utah Shared Access Alliance
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PWC Ban at Lake Powell: A great travesty is about to repeat itself.

Personal Watercraft (PWC, a.k.a. "Jet Ski's") are now banned from Lake
Powell. This is a part of the "legacy" of the Clinton/Gore
Administration that spared no effort in catering to radical special
interest groups over the legitimate needs of the majority of users of
the American public lands, National Parks, and Recreation Areas.

The Bluewater Network ( http://www.bluewaternetwork.org ) makes no
secret about its goal of eliminating all motorized recreation and access
from public lands and facilities. One of their first targets was
Yellowstone National Park, where they nearly succeeded in banning
snowmobiles. If not for a lawsuit brought by the Snowmobile
manufacturers ( http://www.snowmobile.org ) and the BlueRibbon Coalition
( http://www.sharetrails.org ), they would have succeeded.

Bluewater Network followed the template used in Yellowstone exactly.
They first implemented a multi-million dollar PR campaign that sought to
indoctrinate the general public with lies and misinformation about the
people who use PWCs. Predictably, they used flawed and out-of-date
studies to vastly overstate the environmental impacts of this popular
and legitimate family oriented sport. The press ate it up.

The next step included a very clever lawsuit. Bluewater learned from
their efforts in Yellowstone and crafted a piece of legal genius.
Leveraging their cozy relationship with policy makers in the
Clinton/Gore administration, they reached a friendly, contrived
settlement to a lawsuit that provided the mechanism to end PWC use on
Lake Powell. We're certain they were very proud of themselves.

Prior to Bluewater's campaign, 87 out of 379 units in the National Park
Service (NPS) system had allowed motorized boating. Even without
Bluewaters efforts, of the 87 units allowing PWC use 66 promulgated
regulations that permanently banned PWC's as of April 22, 2000. However,
that wasn't enough for Bluewater, and as a result of their lawsuit, half
of the remaining 21 units, including Lake Powell, were forced to
complete an Environmental Impact Statement (EIS) that essentially
required the NPS to justify continued PWC use.

This is where Bluewater's special relationship with high-level officials
in the Clinton/Gore Administration paid off. The lawsuit was settled,
quietly, with an agreement requiring the NPS to completely ban PWC use
if, for any reason, the EIS was not completed by a certain date. The
Glen Canyon National Recreation Area (Lake Powell) unit of the Park
Service had until September 15 to produce their EIS. We weren't a bit
surprised when the NPS managed to miss the deadline, resulting in the
current ban.

So by entering into a bad faith settlement and then just by doing
nothing, the NPS has succeeded in extinguishing the recreational rights
of a substantial portion of its constituents!

The Yellowstone Snowmobile study and the PWC study have a few things in
common. Both studies revealed very few, if any, impacts on the
environment and on wildlife. Both studies proved the claims of the
Bluewater network to be false, or vastly overstated. Both studies showed
a clear bias against motorized use in the quantification and analysis of
environmental effects. Finally, both EIS's ignored empirical evidence
and imposed discriminatory reduction on public's enjoyment of their
natural resources.

USA-ALL encourages you to TAKE ACTION TODAY in order to prevent this
travesty.
Yes, you can make a difference. And yes, we can beat these anti-access
zealots. USA-ALL has formulated a quick and easy 2-step program to help.

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USAALL's TWO STEP PROGRAM TO BEAT THE ANTI-ACCESS ZEALOTS:
STEP ONE: Submit comments to the Park Service. See our analysis below to
help you with this step. It won't take more than a couple of minutes. Do
it now.
STEP TWO: The second step is probably more important. It doesn't take a
Doctorate from MIT to predict that if the Park Service allowed PWC use
on one square inch of Lake Powell the Bluewater Network will sue. It
would be a miracle if they didn't! You know what? We can beat them. We
have shown that with a fraction of the funding recreationists can beat
these anti-access zealots in court. But we still need the funding. No
war chest exists to fight this battle. We need you to step up and
contribute today, so when the foundation-funded "Bilge-Water Nutwerk"
lawyers file their suit, the judge will be able to hear the other side
of the story. USA-ALL has been in contact with BlueRibbon's legal team
and we believe they are up to the challenge. That is why we recommend
your donation be directed to BlueRibbon's PWC Defense Fund. Just do
this: Scratch out a check for $25, $50 or $100 and make it payable to
BlueRibbon Coalition. Put "PWC Defense Fund" on the check. Then mail it
to: 4555 Burley Drive, Suite A, Pocatello ID 83202. If you want to use
your credit card click on: https://www.sharetrails.org/index.cfm?page=3
select the "I want it to go to the Legal Access Fund" and at the bottom
where it says "Where did you hear about the BlueRibbon Coalition" type
"For PWC Defense Fund". Oh yea, tell them Brian over at USA-ALL sent you
;-)

ACTION ITEM: COMMENT ON LAKE POWELL PWC EIS NOW

SITUATION:
The National Park Service, in response to a lawsuit from the
ultra-extreme anti-access zealots at the Bluewater network, has released
a Draft Environmental Impact Statement (DIES) on Personal Watercraft for
the Glen Canyon National Recreation Area (Lake Powell). The document can
be viewed online at: http://www.nps.gov/glca/pwceis/pwchome.htm

COMMENTS ARE NEEDED BY NOVEMBER 27, 2002 All comments must be received
by close of business on that day.
Comments should be sent in writing to:
Kitty L. Roberts, Superintendent
Glen Canyon National Recreation Area
P.O. Box 1507
Page, Arizona 86040

Or via e-mail to: GLCA@den.nps.gov

Comment suggestions are below.

CRITICAL INFO:
The Draft EIS offers three alternatives for managing the use of PWC's at
Lake Powell. Alternatives A and B would allow personal watercraft use
under defined conditions. Alternative C would eliminate personal
watercraft use on Lake Powell.

Alternative A would allow use as currently existed before. Personal
watercraft use would be authorized for all areas of the recreation area
above Glen Canyon Dam except where prohibited by the 2002
Superintendent's Compendium.

Alternative B would allow personal but impose additional management
restrictions. PWC use would be prohibited in portions of the Colorado,
Escalante, Dirty Devil, and San Juan Rivers. Speed restrictions would be
imposed in additional areas of the Escalante and Dirty Devil Rivers.
This alternative also includes the development of a monitoring program
and Lake Management plan that would allow for further, unspecified
restrictions in the future.

Under Alternative C, the no action alternative, the current ban will
remain in effect and all personal watercraft use within the recreation
area would be prohibited.

COMMENT SUGGESTIONS:
USA-ALL supports Alternative A
There is nothing in the DEIS that indicates PWC's are the source of any
substantial problems in any of the areas studied. Quite to the contrary,
in some areas their impacts are significantly under represented compared
to other watercraft. Thus there can be no question that Alternative A is
the only rational choice. The selection of Alternative B would be
arbitrary and capricious. Alternative C, a total ban, is so extreme as
to be beyond any serious consideration.

ISSUE: Water Quality
The DEIS thus found no impact on water quality under the worst scenario
of current use levels. In addition, any impacts are that may exist will
dwindle each subsequent year as the fleet of PWC become more
fuel-efficient and less polluting.
It is clear from the DIES that no impetus or justification for
restricting PWC use can be found related to the issue of water quality.

ISSUE:Air Quality
The same comments as above can be made in regard to air quality.
It is clear from the DIES that no impetus or justification for
restricting PWC use can be found related to the issue of air quality.

ISSUE: Soundscape
The claim is made that many recreationists who do not use PWC's find the
noise from these vessels to be "annoying". It should be noted that
discriminatory special interest groups have taught non-motorized
recreationists that any noise from motorized recreation is unacceptable.
The sound standard at the Glen Canyon National Recreation Area is 82
decibels at 82 feet at full acceleration, a standard that is met by
every unmodified PWC. If particular modified PWC's exceed this limit,
then they should be cited and/or removed from the waters of Lake Powell.
This standard can, and should be met under Alternative A.
It is clear from the DIES that no impetus or justification for
restricting PWC use can be found related to the issue of "soundscape".

ISSUE: Wildlife and Wildlife Habitat
The DEIS tell us, on page 17: "Few studies have examined personal
watercraft effects on wildlife". Also: "However, the extent,
duration, and magnitude of biological impacts because of personal
watercraft operations versus other motorboats remain unknown". And on
Page 120: "Under current condition there are no documented reports of
known conflicts of federally endangered fish or other species with
watercraft or personal watercraft users." And on Page 232:
"Conclusion. Alternative A would not adversely affect any ecological,
biological, or physical processes associated with endangered fish
critical habitats."
It is clear from the DIES that no impetus or justification for
restricting PWC use can be found related to the issue of wildlife and
wildlife habitat.

ISSUE: Shoreline Vegetation
No evidence is presented that PWC use harms shoreline vegetation. The
EIS speculates that PWC's "may crush or uproot grasses or other
submerged aquatic vegetation that occurs in shallow water" (pg ix).
This speculation is totally specious and misleading. The dominate
shoreline vegetation species is the alien Tamarisk, which, since its
introduction to our shores nearly 100 year ago, has succeeded in
devastating native vegetation colonies and now dominates and degrades
the beaches of the entire Colorado river system. If PWC use could in
some way negatively impact the Tamarisk, it would be beneficial to all.
It is clear from the DIES that no impetus or justification for
restricting PWC use can be found related to the issue of shoreline
vegetation.

ISSUE: Visitor Conflict and Safety
Of great importance and significance are the data presented in Table 23
( pg 138) describing Lake Powell specific accident statistics. It
concludes that PWC's are involved in 14% of all accidents. This is a
remarkably low rate! As the DEIS admits on page 139: "Personal
watercraft represented about 14 percent of all accidents, or just over
half of the number that would be expected from their level of use (26
percent of all boat days). In other words, PWC accidents occur at only
one-half the expected rate! In addition, the DIES states: "Personal
watercraft were involved in only 5% of the property damage accidents".

With respect to conflict, Table 20 on page 133 presents data relating to
"perception of conflict by users of personal watercraft and other
watercraft". These data show only a slight elevation of "perception
of conflict" in "other watercraft operators" compared to "PWC
operators". This is to be expected since some members of any group
will always be opposed to the activities of other groups, in the absence
of any objective basis. Quantitatively, the elevation is insignificant.

It is clear from the DIES that no impetus or justification for
restricting PWC use can be found related to the issue of visitor
conflict or safety.

Problems with Alternative B:
Alternative B includes the adoption of the Appendix C protocol that,
after a three year further study period, sets the stage for new,
unspecified and perhaps draconian PWC restrictions.

It would deny operators of personal watercraft access to the important
areas of the full pool shoreline of Lake Powell.
The Park Service provides justification for Alternative B on page 69 of
the DEIS: "However, Alternative A would not ensure aesthetically
pleasing surroundings because it would allow personal watercraft users
in areas frequented by recreationists engaged in more reflective outdoor
activities". This statement well illustrates the NPS's unrelenting bias
towards its muscle- powered users and discrimination towards of all
others. The DEIS ignores the fact that muscle-powered users have the
vast bulk of the Colorado river system plus the entire Grand Canyon
available for their exclusive use. The same comments apply to the
affected sections of the Escalante, Dirty Devil, and San Juan rivers.

The fact that these restrictions outlined in Alternative B would apply
only to PWC's and not to other power craft makes them arbitrary and
capricious and utterly lacking in any sense whatsoever.

The restriction to wakeless speed for PWC's, but not for other power
craft in some of these areas also defies logic. PWC wakes are negligible
compared to those of the larger boats whose operations would be allowed
to continue.




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