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· Land Use Zeus
2,829 Posts
Discussion Starter · #1 ·
I know it's short notice, but this takes only a few minutes to whip out a letter in support of saving Clear Creek Management Area (CCMA) for us. Basically we need to support the BlueRibbon Coalition letter (Vision/Mission) already done and posted up. Grab a few excerpts from it or say whatever you want to keep this area open, but we gotta have these in by June 21st.

This is one of those do it, even if you don't use it (yet). :)

I posted up Don Amador's BlueRibbon Coalition letter so we could use it. Get it here: http://www.delalbright.com/Access/ccma_noi_letters.html
thanks ,Del

· pro web-wheeler
20,539 Posts
With only two days to go...someone needs to rally the troops in the other forums! Can anyone take that job on and get some people to write!

Thanks for the update Del...I'll try to write a letter on the road to Cedar!

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294 Posts
Hoping on it now... Passing on the word to the club.

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Joe analyzed the EPA data, and came up with the following:

June 21, 2008

Hollister Field Office, BLM
20 Hamilton Court
Hollister, CA 95023

Email: [email protected]

Re: Notice of Intent to Prepare a Resource Management Plan for the Clear Creek Management Area, California, and Associated Environmental Impact Statement

Dear Hollister Field Office:

Please accept the following document on behalf of the California Off-Road Vehicle Association, Inc. (CORVA) it's members, affiliated clubs, and myself. CORVA is a non-profit corporation representing off-road users who enjoy all types of off highway vehicle recreation throughout the state of California. CORVA is proud to be celebrating our 40th year as recreation activists, "Dedicated to protecting our lands for the people, not from the people." This document shall not supplant the rights of other CORVA members from submitting their own comments and the agency should consider and appropriately respond to all comments received.

CORVA agrees with and support the BlueRibbon Coalition's vision for the Clear Creek Management Area. The 75,000 acres of CCMA should remain and be managed as a destination recreation area that serves all aspects of the BLM's multiple-use mandate. Because this is the only federal multiple-use recreation area in a 300 mile section of California which extends from the SF Bay Area to the Santa Barbara area, the CCMA serves as an important recreation area for a large urban population. The OHV, hunting, gem collecting, rock hounding, equestrian and other uses must be preserved in this unique area.

Based upon information obtained from the BLM at the final scoping meeting, a reading of the EPA study results, and an investigation into the methods and history of asbestos exposure risk assessment, it is our contention that the emergency closure is at best premature.

Although we do not question that studies have indicated asbestos as a human carcinogen, the validity of the data collected in the EPA study is unclear for several reasons as follows:

1. Questions regarding the data collection methods:

A.Exactly which trails were sampled, and how much of the geographical area was used to collect air samples is not clear. The majority of the data was taken on graded roads which could reasonably be assumed to be far more dusty due to the volume of traffic from street-legal cars and trucks, recreational and maintenance vehicles, not to mention the possibility of being used as haul roads. The vast majority of recreational use is on back roads and single track trails, routes that do not seem to be represented in a balanced manner. There is no existing data to indicate that air quality is consistent assuming similar usage in different areas.

B.Data was collected in both “lead” and several “trailing” positions, presuming groups traveling in a single-file fashion. It appears that final measurement results were obtained by averaging these values as a group. This completely eliminates data representing the single/solo rider or driver, a very common recreational scenario. Averaging data from vastly different scenarios is reason enough for invalidation.

C.The results of an earlier air quality study which was recognized as qualitatively equivalent to the EPA study, resulted in fiber-count data about one order of magnitude (1/10th) that of the later study. A re-testing of samples from earlier collections also resulted in a much higher count. This, as well as the admittedly large variations between measuring methods puts any single method's data in question, and the fact that, in every case the measurements were higher (worse) in the EPA study could indicate a bias someplace in the process.

2. The validity of “risk” assessment values are not clear for several reasons:

A.Risk data was developed using actual epidemiological data from populations of workers who were subjected to “chronic” exposure, meaning constant consistent exposure to significant levels of asbestos over long periods of time... years. There is no data quantifying the risk associated with inconsistent short term exposure.

B.It is recognized, although not understood, that a synergistic effect exists when chronic asbestos exposure combines with smoking, resulting in a vastly higher risk of lung cancer. The data used to determine risk estimates came from populations in the mid 1970's, and include a much higher proportion of smokers than would be present today. This would result in artificially high risk estimation.

C.There is mixed consensus on just what constitutes acceptable risk. National and State estimations differ by a factor of 100.

D.No epidemiological data was used in this study. Because the Clear Creek area contains a large natural asbestos formation it can be presumed not only that there has been asbestos in the air for as long as there has been human habitation, but that wind would have carried it to a much wider area than that considered in this study. There is also a population of workers who should have been exposed in a chronic manner. Data to indicate a statistical correlation to health effects should be available from the CDC, and if not, the study needs to be done.

The results of this study are an indication that the investigation should continue, but needs to include representation from the BLM and user groups to insure an accurate representation of the recreational activities, and eliminate intentional or unintentional bias in the data. The results do not, however, justify a closure at this time.

But beyond this conclusion, there is a philosophical point to be considered. The EPA was formed, and exposure levels developed, to protect the public from toxins produced by industry that can result in toxic workplace or residential exposure. The public has no argument that the government should take the roll of protecting the citizenry from such unseen and unnecessary dangers. There is also no argument that workers who MUST tolerate a higher level of exposure due to their chosen occupation, can be exposed to some higher level, because there is value in taking this risk. The value of recreation is being ignored by the Clear Creek closure.

Clear Creek was closed to protect the public from a naturally occurring substance, not an industrial toxin, and recreationalists are well aware of it's presence but choose to accept some risk because there is enormous value in their activities. It is reasonable to insist that a different level of acceptable risk needs to be developed if the EPA is to continue this extension of it's responsibilities.

Clear Creek needs to be re-opened and a follow-on study designed that takes into consideration factors such as those presented in this document before such a drastic action as closure is considered. Because the overriding reason for this closure is to reduce the perceived liability, it should be considered that the BLM could be considered liable for the value of the activities they have taken from the public, which are quantifiable and considerable.


Joseph Sand [email protected]

Member, California Assn. of 4 Wheel Drive Clubs, Inc.
Member, California Off-Road Vehicle Association, Inc.
Member, BlueRibbon Coalition, Inc.
Trustee, California Assn. of 4 Wheel Drive Clubs Education and Conservation Foundation
President, Specialized 4Wheel Drive, Inc.

Amy Granat [email protected]

Director, California Off-Road Vehicle Association, Inc.
Director, California Trail Users Coalition, Inc.
Member, California Assn. Of 4 Wheel Drive Clubs, Inc.
Member, BlueRibbon Coalition, Inc.

P.O Box 298
Clarksburg, CA 95612

· Premium Member
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Yesterday I received a letter from the BLM dated 8/22/08 regarding Clear Creek. They have done a "Scoping Report" along with a "Resource Management Plan" and "Envinromental Impact Statement". The Scoping Report can be found here:http://www.blm.gov/ca/st/en/fo/hollister.html and then click on the link.

The letter also states "Additional opportunities for public involvement will be announced at least 15 days in advance through public access, media news releases, and mailings. Under the current schedule, BLM expects to publish notice in the Federal Register in January 2009 announcing the availability of the CCMA draft RMP/EIS, followed by ninety (90) day public comment period and additional public meetings in the Santa Clara Valley and Central Valley."
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