Blue Ribbon Coalition's Moab RMP analysis!!!

[greenjeep]

Sorry to start a new thread, but I think it is worth it so that everybody has a chance to see this information. This Action Alert was sent out tonight from the BRC.

HERE is a link to the Alert on BRC's website.

ear BRC Action Alert Subscriber,

There are exactly 25 days left to comment on the Moab BLM RMP and Travel Plan.

The clock is ticking. There will be no comment extension on this one.

This Action Alert is designed to help you formulate your comment letter on this important plan. We are asking our members who have enjoyed the spectacular trails in Moab, or think they might sometime in the future, to read this alert and begin today to write your comment letter.

There will be no "click and send" action alert from BRC on this one. That's because the BLM has "rigged" the process and the Alternatives so that a comment that says something like "I vote for Alternative D" will not work.

But we've taken a lot of time to look hard at what the Moab BLM is proposing so you don't have to wade through thousands of pages to figure out what they are proposing and how to comment.

In order to help you write your comment, we've taken all the important parts of the DEIS and compiled them in summaries available via hyperlinks below. There are several key issues that folks need to be aware of and comment on, so we also have formulated some specific comment suggestions on the most important issues (see below).

If you find yourself lacking motivation here, just take a second to look at the effort those anti-recreation zealots over at SUWA have put into this Moab plan. (http://www.suwa.org/) SUWA's Executive Director has moved to the Moab area and their staff of attorneys is making a very strong push to eliminate most of the OHV use in the region. Their effort is professional and it is strategically designed to supplement SUWA's foundation-funded legal and political efforts.

Hey, that's what you get when you have 2 million samoleans-per-anum to work with!!

Trust us on this: this effort by SUWA is a serious problem for you, if you use a vehicle for recreation in Moab. Like our ad says: "These guys want to rub you out!"

Please read this Alert, click the links and check out the maps and other materials. Bookmark the important sites, as updates will be added right up to the comment deadline. Forward this Alert to your friends, family, club land-use officers and your ridding buddies.

We put a lot of effort into making the Moab BLM's plans easy to understand. Once you click the links and check out our comment suggestions, you'll know what to do. It won't be difficult.

But if you have any questions, concerns, or just need some help writing a comment letter -- please call.

Brian Hawthorne
208-237-1008 ext 102
Ric Foster
208-237-1008 ext 107

SITUATION:

The Draft Resource Management Plan (DRMP) and Draft Environmental Impact Statement (DEIS) for the Utah Bureau of Land Management (BLM) Moab Field Office has been released for public review and comment.

In addition to a new RMP, Moab BLM will be formulating a Travel Plan for motorized vehicles and mountain bikes. Travel will be limited to designated roads, trails and areas.

The BLM has set a deadline of November 30, 2007, for receiving information and comments pertaining to the Alternatives and the analysis presented in the DEIS. Feedback regarding the four proposed alternatives will be used to formulate a Proposed Resource Management Plan, and ultimately, a Final Resource Management Plan and Travel Plan.

Comments and other information may be submitted electronically at: UT_Moab_Comments@blm.gov.

Comments and other information may also be submitted by mail to:
Moab Field Office RMP Comments
Bureau of Land Management
Moab Field Office
82 East Dogwood
Moab, UT 84532


INFORMATION ON THE WEB:

BLM information and documents:
The Moab DRMP/DEIS and supporting information is available on the project web site at: http://www.blm.gov/ut/st/en/fo/moab/planning.html.

BlueRibbon Coalition Resources:
http://www.sharetrails.org/alertlist/subscribeform.cfm
http://www.sharetrails.org/public_lands/
http://www.sharetrails.org/public_lands/?section=MoabUpdate

What the anti-access groups are doing:
http://www.suwa.org/site/PageServer?pagename=work_moabrmp


WHAT YOU NEED TO DO:

For maximum effectiveness:
1) Using the information provided from BLM and BRC's websites, as well as the info and the comment suggestions below, write a comment letter addressing Issues and Alternatives presented in the DEIS.

2) Copy your letter to your political representatives. Snail mail works best. Pen a quick personal note to your politico's staff and make sure they know you are PRO access, that you visit the area and that you oppose both the rhetoric and the proposals of the so-called "environmental groups." Find the address of your politico's here: Rapid Response Center (just enter your zip code)

3) 'CC' your comments to BRC
CC your comments to BRC at brlandsinfo@sharetrails.org. In the Subject line please put Moab RMP Comments.

Extra Credit:
Comments will be most helpful if you can state very specifically what you like and what you don't like about each of the Alternatives. Suggest changes. Also, it is good if you can reference a section or page number.

IMPORTANT NOTE:

Yes, this IS worth the time and effort to write a good comment letter. Public comment is extremely important and will help to move the Final Plan toward something that's good for the recreating public. Individual comments like yours will also serve as a foundation for groups like BRC to challenge any arbitrary or unfair closures, as well as defend the inevitable attack from SUWA's lawyers.

If at all possible, your letter should address these issues (please see comment suggestions below):

* Comments regarding the Alternatives -- (please note that Alternative A (no action) is not an "action alternative." So the "I vote for Alternative A" comment will be a waste of time and effort.
* Comments about specific roads, trails and areas to be designated for motorized and mountain bike use, and responses to specific questions associated with BLM's #1 formal Planning Issue: "How can increased recreation use, especially motorized vehicle access, be managed while protecting natural resource values?"
* Comments on Special Recreation Management Areas (SRMA)
* Comments on Dispersed Camping
* Comments on White Wash Sand Dunes
* Comments on ATV Trails
* Comments on Mountain bike trails/areas
* Comments regarding special designations such as ACECs, Wild and Scenic Rivers and "Lands with Wilderness Character"

COMMENT SUGGESTIONS:

Comments may be submitted electronically to: UT_Moab_Comments@blm.gov. Comments may also be submitted by mail to:
Moab Field Office RMP Comments
Bureau of Land Management, Moab Field Office
82 East Dogwood
Moab, Utah 84532.

Note:
A good comment letter starts with a brief paragraph about yourself and a bit, about what you like to do when you visit the Moab field office.

 

[greenjeep]

Part Two:

Issue: Comments about specific roads, trails and areas to be designated for motorized and mountain bike use.

Comment Suggestions:

BRC has several detailed maps for download that, for us anyway, are a lot easier to read. Click here, download the maps and talk amongst your friends, family and riding buddies.

NOTE:
Any specific comment on any road or trail, whether proposed as open or closed, is useful and we believe taking the time and effort to do so will be very worthwhile.

____________________________________________________________________________

Issue: There is not a true range of management options in the Alternatives

Simply stated, there just isn't much difference between the "Action Alternatives." And, both Alt. B and Alt. D are completely unworkable as written, which naturally makes BLM's Preferred Alternative the only "reasonable choice." The motorheads in the BRC Public Lands Department will forgive you if you think the BLM did that on purpose.

Finally, there are actually a bunch of alternatives here that the public should be commenting on. There are the three action alternatives for the RMP, then there are three action Alternatives for the Travel Plan, and there are an additional two alternatives for motorcycle (and ATV) trails.

Sheesh, BLM... how is the general public supposed to be able to figure all this out, especially when you give only a cursory discussion of the difference between the RMP and the Travel Plan in your own document?

Comment Suggestions:

* The fact that comments are needed on Alternatives for the RMP and the Alternatives for the Travel Plan is not made clear in the document.
* The difference between an RMP (general guidance) and the Travel Plan (implementation decision) is not clearly described in the DEIS. The FEIS should clearly articulate the difference.
* None of the Alternatives presented are acceptable as they stand, including the Preferred Alternative C, which mandates unworkable and impractical management of camping and motorized travel. In addition, in all of the Alternatives, management for the White Wash Sand Dunes is fatally flawed and must be reconsidered (see comment below).
* Alternative D fails to provide a true motorized focus.
* Tell the BLM that you are concerned that many of the restrictions in all of the Action Alternatives are simply not justified. Tell the BLM that the FEIS should clearly draw a connection between the facts on the ground and the decision made.

____________________________________________________________________________

Issue: White Wash Sand Dunes management plan is totally unacceptable and unworkable (BRC details here)

Months ago, when we blasted our Moab Update information to our members and supporters, we made fun of the BLM's management proposal for the White Wash Sand Dunes.
Months ago, when we blasted our Moab Update information to our members and supporters, we made fun of the BLM's management proposal for the White Wash Sand Dunes.

BLM's draft plan bans nearly all camping until (if) they get around to constructing a developed campground and would also implement a "fee system using individual Special Recreation Permits." The Draft Plan also requires fencing around all of the Cottonwood trees and "water sources" around the Dunes.

After meeting with the planning team and learning they are absolutely serious about that, I guess we aren't laughing anymore.

Comment Suggestions:

* BLM's open area in Alternative C and D must be expanded. The current proposal is unworkable because it confines a huge amount of vehicle use into a very small area and the area's boundaries are not well defined and cannot be easily identified on the ground.
* Requiring fences around the cottonwood trees and "water sources" is both impractical and unnecessary. We strongly oppose this provision of the Draft Plan.
* BLM's open area at White Wash Sand Dunes should include the popular and challenging hill-climb on the Northwest of the Sand Dunes.
* BLM's open area should be located along easily identified geologic features, or preferably along boundary roads of Ruby Ranch Road on the West, Blue Hills Road on the North, and Duma Point/Ruby Ranch (back way) on the East.
* You oppose the fee system contemplated in Alternatives C and D. Fee systems are inherently controversial and often unpopular with the recreating public. The Final RMP should not require a fee system. However, if funding for infrastructure needs cannot be met with existing funding and grant programs, then a fee system should be implemented only with the full involvement of the Recreational Fee Advisory Council and the affected user group.
* Because the open area boundary will not be easily identifiable on the ground, and also because of easy access to the proposed "fee area" from all directions, it will make this proposal extremely difficult to enforce. We suggest the BLM consider other funding mechanisms to pay for needed management infrastructure.

____________________________________________________________________________

Issue: Is BLM propsing a "close first - mitigate last" approach to OHV use?
In BLM's #1 Issue they ask: *Where should adaptive management practices be applied in response to unacceptable resource impacts?

Given the popularity of Moab for recreation, and the fact that large areas are proposed to be off limits to most recreational users, considering NOT applying adaptive management practices to mitigate impacts is, well, not logical.

Comment Suggestions:

* The Final RMP should mandate that adaptive management practices be used across the Field Office
* The Final RMP should direct that mitigation efforts will be exhausted prior to closure
* The Final RMP should direct land managers to work with the affected public to ensure all available mitigation efforts have been exhausted before closure.
* When using adaptive management principles, The RMP should mandate the mitigation of closing routes and areas to recreational use by designating a more sustainable, but similar recreational opportunity elsewhere.

____________________________________________________________________________

Issue: BLM states the 'user conflict' issue as a question: How should recreational uses be managed to limit conflicts among recreational users? (Read BRC's favorite statement on conflict by Art Seaman)

Contrasting the SRMA and Focus Areas with the Travel Plan indicates that Moab BLM's preferred answer is to create "exclusive use zones."

Providing opportunity for a non-motorized recreation experience is great, but by imposing a near categorical exclusion of other uses it removes the ability to designate key motorized uses that are needed in a well managed road and trail system.

Comment Suggestions:

* When addressing "user conflict," the Final RMP should avoid "exclusive use zones" where, based on perceived or potential "user conflict," one or more "conflicting uses" is categorically prohibited.
* Most of the non-motorized focus areas have designated routes open to motorized vehicles within them. If implemented as written in Alternatives B, C and D, many visitors will perceive these focus areas as establishing blanket restrictions on motorized use. The unintended consequences will likely result in increasing, not reducing actual or perceived "user conflict."
* In order to address the "user conflict" issue, the Final RMP should direct land managers to educate the non-motorized visitors (who may perceive conflict with motorized uses) where they may encounter vehicle traffic in certain areas as well as informing them of areas where they may avoid such encounters.
* The Final RMP should direct land managers to educate vehicle-assisted visitors of where a road or trail might be shared with non-motorized visitors, and if appropriate, direct slower speeds.
* The Final RMP should direct land managers to re-route either use so as to avoid sections of roads or trails that are extremely popular with both groups. For example, a hiking trail can be constructed to avoid a section of popular OHV route. Or an equestrian trail may be constructed to avoid a section of popular mountain bike route, etc.

____________________________________________________________________________

Issue: Moab BLM is closing a huge number of dispersed campsites. (See BRC's details on BLM's proposal)

Because vehicles are not permitted to travel off designated routes - for any reason - the Moab BLM is proposing a "vehicle camping only in designated campsites" in the entire Field Office. Such a restrictive policy would be appropriate for National Parks or National Monuments, but for Public Lands this is truly unheard of.

Moab BLM staff argues that the impacts from dispersed camping warrant such restrictions, and claim that their Travel Plan kept open the route to nearly every existing vehicle campsite. They say that most every campsite that did not have a "resource problem" remained open. Our review says different, and we believe hundreds of campsites currently being used could be closed.

 

[greenjeep]

Part Three:

Comment Suggestions:

* Tell the BLM that you oppose the camping policy as outlined in Appendix E.
* The Final EIS should disclose how many campsites would be closed under each Alternative.
* Tell the BLM that you support a policy where existing campsites are open unless determined closure was necessary via lawful public planning process.
* Tell the BLM that it is very important that the Final RMP mandate full public involvement in any establishment and management of "restricted camping areas" or "controlled camping areas."
* Finally, and perhaps more importantly, check the BLM's maps (http://www.blm.gov/ut/st/en/fo/moab/planning/draft_rmp_eia.html) to see if YOUR favorite campsite will be closed (see if a road is designated right up to the campsite). If you can't tell from BLM's maps, you need to tell them that!

____________________________________________________________________________

Issue: Special Recreation Management Areas

There are some "Action Alert" type comments below, but if you have the time we think it would be well worth the effort to review the BLM's proposal and give them your input.

Frankly, a lot of what they propose makes a creepy sort of sense. But there are "poison pills" that (unnecessarily) make future management uncertain. In other words, if BLM doesn't write this plan right, SUWA will be litigating them (and us) to death.

Check our info as well as BLM's proposals. Quick links and page numbers are provided to make it easy.

Comment Suggestions:

*
The Travel Plan and the Administrative Setting must be consistent in all SRMAs!
*
All SRMAs with a motorized focus should include direction regarding when and how additional or expanded routes/areas would be provided should there be a need.
*
SRMAs and their "focus areas" should avoid excluding other uses categorically. The Preferred Alternative clearly shows Moab BLM recognizes the importance of providing some motorized routes in non-motorized "zones."
*
The Utah Rims SRMA is necessary to properly manage this popular area. It should have a motorized and mountain bike focus, and include the ability to designate or construct routes should they be needed in the future. In addition, limiting camping to one small designated area, in the RMP, is not wise. The RMP should provide general direction and not limit camping in such a way.
*
The Utah Rims SRMA should extend further southwest to encompass Mel's Loop and beyond. Increased visitation there warrants the more active management of a SRMA. This larger area would also provide enough room for a full-day's motorcycle ride, and the establishment of a mountain bike focus area.
*
Yellowcat is increasingly popular for four wheeling and ATV riding. Designating a SRMA there would utilize the dense network of mine roads that already exist.

____________________________________________________________________________

Issue: Although many popular ATV routes are classified as roads in Moab BLM's Travel Plan, some ATV trails are not proposed as open and some of the Motorcycle routes should be designated as ATV/Motorcycle trails as well.

Staff at the Moab office seem to realize the error in their so-called "motorcycle maps" (e.g. no ATV trails). Thankfully, "Action Alert" type comments are relatively easy on this issue because Clif Koontz, with Ride with Respect, has been working with key ATV leaders and identified what we think is a really good proposal. Clif will have specifics soon, and we'll update you on those as soon as possible.

Comment Suggestions:

*
Some of the "motorcycle trails" are very popular with ATV users. The Final Travel Plan should designate a mix of single track and ATV trails.
*
The FEIS should consider designating more ATV trails, especially between White Wash and Red Wash. We strongly suggest looking closely at the proposal developed by Ride with Respect.

____________________________________________________________________________

Issue: In the Moab Field Office, true mountain bike single track trails are in short supply.

Comment Suggestions:

*
The Mill Canyon - Sevenmile Rim biking focus area should be redrawn as Mill Canyon -Tusher Rims in order to provide better terrain for pedaling.
*
The Final Plan should extend the South Spanish Valley biking area further south toward Black Ridge.

____________________________________________________________________________

Issue: Though 'stay on the trail' is a critical policy for most places, recreationists need a few distinct areas for open-riding.

In 1.8 million acres, White Wash is not quite enough.

Comment Suggestions:

*
An open area in addition to White Wash could provide different terrain for everything from bicycle free riding, to trials motorcycling, to hardcore rock crawling. As 99% of the Moab Field Office becomes limited to designated routes, open areas play an even more critical role for accommodating specialized sports. Perhaps parts of Black Ridge could remain unrestricted for this purpose.
*
The Sand Flats Recreation Area could adopt special policies to permit slickrock exploration. We support Ride with Respect's recommendation that mountain bike travel be allowed on any barren rock surface. Slickrock within one hundred yards of a designated route could be open to motorized travel. This two-hundred yard corridor would accommodate the ways that people currently enjoy Sand Flats.

____________________________________________________________________________

Issue: Some important motorcycle trails are missing from all alternatives.

The preferred alternative includes about 100 miles of true motorized single-track. Alternative D adds another 100 miles. But in total, the final plan should spare roughly 300 miles of non-road motorcycle routes from being closed.

Comment Suggestions:

*
Alternative D falls just short of providing sufficient motorcycling opportunities. Since no single-track inventory was performed, the BLM should continue accepting data on existing routes, and consider them for implementation.
*
The Utah Rims single-track network should include at least 25 miles of additional routes, in order to be as complete as the Dee Pass network.
*
In particular, long-distance single-tracks and rugged roads that connect SRMAs offer a unique experience. The Copper Ridge Motorcycle Loop should be combined with Thompson Trail in the final plan.
*
A few more non-riparian washes should be left open, especially in the Cisco Desert. These travel-ways provide ATV and motorcycle riders an unconfined challenge that roads cannot.

____________________________________________________________________________

Issue: In an incredible show of chutzpah, the Moab BLM has included the White Wash Sand Dunes as a proposed Area of Critical Environmental Concern (ACEC) in Alternative B.

Alternative B seems to be the; "give SUWA whatever they want, despite the existing, traditional uses that have existed for decades" alternative. Sheesh, I wish we got the same treatment in Alternative D!!

Comment Suggestions:

*
I strongly oppose the ACEC proposals in Alternative B. The White Wash ACEC is especially inappropriate.

____________________________________________________________________________

Issue: Comments regarding "Lands with Wilderness Character"

Decisions on this issue are being made at the highest levels. OHV users must begin now to pressure their elected representatives on this issue or many hundreds of miles of roads and trails will be closed throughout the West. (You can find the contact info for your political representatives on BRC's Rapid Response Center. Simply Click Here, http://www.sharetrails.org/rapid_response/ and enter your zip code)

Comment Suggestions:

*
Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. Congress instructed the agency to inventory all of their lands, identify which were definitely not of wilderness quality and then to begin an intensive inventory and analysis to determine which of the remaining lands would be recommended for inclusion into the National Wilderness Preservation System.
The process was completed in 1991. All stakeholders (including Wilderness Advocacy Groups) have exhausted the protest and appeal options. After 10 years the "603 Process" left Utah with approximately 3.2 million acres designated as Wilderness Study Areas. Of those, approximately 1.9 million acres were deemed "suitable and manageable" and were recommended to Congress for Wilderness designation. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for inclusion in the National Wilderness Preservation System, subject to existing uses.
*
There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
*
When formulating land use plans and considering opportunities for solitude and unconfined recreation, the BLM must consider all other resource values and uses and attempt to balance the competing uses and values using the Multiple Use/Sustained Yield paradigm.

 

[greenjeep]

I know it's long, but it is really worth the read. They bring up some great points, remember this is what they do for a living, so take their points seriously.

 

[scoutabout]

Excellent! Time for some letter writing parties!

 

[greenjeep]

A group of locals meet with Brian Hawthorn of the BRC and one really good point he brought up was that a VERY effective way to write your comments is to go to Chapter1 of the draft and answer the questions the BLM poses. This gives an excellent way to address their concerns and make sure we cover all the bases.

Here is a copy of the relevant section:

1.3.2.2 ISSUES IDENTIFIED FOR CONSIDERATION IN THE MOAB RMP
Issue 1. How can increased recreation use, especially motorized vehicle access, be managed
while protecting natural resource values? Recreation in southeastern Utah has grown in
popularity in recent years. With this popularity has come a demand for a greater variety and
availability of recreation opportunities, including OHV use, climbing, mountain biking, hiking,
camping, BASE jumping, and equestrian use, while protecting the natural and cultural values of
the public lands. With the number of visitors growing, recreation is expanding further into the
backcountry, while resource and user conflicts are becoming more common. Although all
recreational uses need to be managed, OHV use needs particular attention, including identifying
areas to be open, restricted or closed for the protection of other resource values.
Moab Draft EIS Chapter 1: Purpose and Need
Related Recreational Issues:
• Which areas should be designated as open, limited or closed to OHV use, and which OHV
routes should be designated within the limited category?
• What types of recreation travel should be available on which designated routes and under
what limitations?
• Where should adaptive management practices be applied in response to unacceptable
resource impacts?
• How should recreational uses be managed to limit conflicts among recreational users?
• How should camping, human waste, fires, and wood collection be managed?
• Where should Special Recreation Management Areas (SRMAs) be designated?
• How should conflicts with other, non-recreational uses be reduced?
• What management actions should be implemented to mitigate damage caused by recreational
uses, including vehicles, on other resources and sensitive areas, especially riparian areas?
• How should recreation in the MPA be managed to ensure public health and safety?
• Where and under what circumstances should permitted recreation uses be available?
• What types of recreational facilities and uses should be available, and what limitations should
be required?
• How will visual resources be managed?
Issue 2. What areas will be available for mineral development, and what restrictions should be
imposed? Historically, the mineral industry has been an important aspect of the local economy in
the MPA. Mineral development is considered a major issue for this planning area not only for
economic reasons but also for the degree to which it can potentially affect other resources.
Related Mineral Issues:
• How can conflicts be reduced between mineral development and increasing recreation?
• Where can mineral leasing and development occur, while protecting other resources?
• What are the economic benefits of mineral development?
Issue 3. What areas should have special designations such as ACECs and Wild and Scenic
Rivers? FLPMA and BLM policy require the BLM to give priority to designation and protection
of ACECs during the land use planning process. The Wild and Scenic River Act directs federal
agencies to consider the potential for including watercourses into the National Wild and Scenic
Rivers System during the land use planning process.
Related Special Designation Issues:
• What management prescriptions should be applied to areas with special designations?
• What resources need the protection provided by a special designation?
Moab Draft EIS Chapter 1: Purpose and Need
Issue 4. How can resources such as watersheds, wildlife, and vegetation be protected,
maintained, or restored? Some resource uses (i.e., grazing, mineral development, OHV use, and
recreation) can affect the natural function and condition of watersheds. A healthy cover of
perennial vegetation stabilizes the soil, increases infiltration of precipitation, reduces runoff,
provides clean water to adjacent streams, and minimizes noxious weed invasion. Plant
communities provide habitat for wildlife as well as forage for domestic animals.
Related Natural Resource Issues:
• Which watersheds may require special protection?
• What restrictions could be placed on resource uses in identified areas to maintain the
existence or promote the recovery of threatened and endangered species, or to prevent the
listing of additional species?
• How should wildlife corridors and unfragmented, critical wildlife habitat be protected or
improved?
• How should relict plant communities and hanging gardens be managed?
• What areas should be available for fuelwood harvesting?
• Where and with what methods can noxious weeds be controlled?
• How should activities and uses be managed during drought?
Issue 5. Are there areas where grazing should not be allowed due to resource conflicts? The
Secretary of the Interior, through the BLM, manages approximately 264 million acres of public
rangelands throughout the western U.S. The Taylor Grazing Act of 1934, the FLPMA, and the
Public Rangelands Improvement Act of 1978 together guide the BLM's management of livestock
grazing on public lands. The objectives for grazing administration regulations are to "promote
healthy sustainable rangeland ecosystems; to accelerate restoration and improvement of public
rangelands to properly functioning condition; to efficiently and effectively administer domestic
livestock grazing; and to provide for the sustainability of the western livestock industry and
communities that are dependent upon productive, healthy public rangelands" (43 CFR Part
4100.0-2).
Related Grazing Issues:
• How should grazing be managed during times of drought?
• How should grazing be managed in riparian areas?
Issue 6. How can riparian/wetland areas be managed to protect, maintain, and restore their
proper functioning condition? Riparian areas typically support a unique mixture of vegetation,
providing vital habitat for wildlife, aquatic species, and plants. The density and diversity of plant
and wildlife species are normally higher in riparian areas than on adjacent uplands. Healthy
riparian areas also reduce the impacts of flooding, filter sediment, stabilize banks, store water,
and recharge groundwater during floods and rainstorms. These areas also filter sediment and
nutrients from surface runoff from adjacent lands. However, resource uses such as grazing,
mineral development, and recreation, particularly OHV use, can affect the natural function and
condition of riparian and wetland areas.
Moab Draft EIS Chapter 1: Purpose and Need
Related Riparian Issues:
• How should riparian systems be managed to maintain or improve the quality of habitat for
fish, wildlife (especially migratory birds), plants, and invertebrates?
• How should human activities and uses be managed to protect riparian areas?
Issue 7. How can cultural and paleontological resources be protected from the predicted influx
in visitation as well as from impacts from other resource uses (e.g., motorized recreation,
livestock grazing, mineral development)? The MPA is known for its high density of cultural and
paleontological resources, many of which have yet to be recorded. For Native Americans,
aboriginal cultural resources provide a direct link to their past, and they request that these
resources be protected.
Related Cultural Issues:
• What management practices (i.e., method of development, and location) can be applied to
human activities and uses in order to protect cultural resources?
• Where can cultural resources be used for scientific, educational, recreational, and traditional
purposes?

 

[greenjeep]

Continued


Issue 8. What lands within the MPA should be identified as targets for acquisition, disposal or
withdrawal? As mandated by Sec. 102 (a)(1) of FLPMA (43 U.S.C. § 1701), public lands are
retained in federal ownership, the exception being those public lands that have future potential
for disposal (i.e., sale or exchange), as described under Sec. 203(a) and Sec. 206 of FLPMA (43
U.S.C. §§ 1713 and 1716).
Public lands cannot be effectively administered without legal and physical access. Therefore,
public lands have potential for disposal when they are isolated and/or difficult to manage. Lands
identified for disposal must meet public objectives, such as community expansion and economic
development. The preferred method of disposal is land exchange. Other lands can be considered
for disposal on a case-by-case basis. Disposal actions are usually in response to a public request
or an application and result in a title transfer, wherein the lands leave the public domain.
Methods used to acquire legal rights to lands that meet resource management needs include
negotiated purchase, donation, and exchange. In a withdrawal of lands, an area of public land is
withheld from settlement, sale, location, or entry, for the purpose of limiting activities in order to
maintain other public values.
Issue 9. Where is fire desired and not desired, and in what areas could fire be utilized as a
management tool for vegetative treatments? Drought and beetle infestation in southern Utah
have contributed to hazardous fuel loading, increasing the threat of wildfires. Areas of pinyon
die-off and dry grasslands have also created areas of higher risk for fire hazard and could require
treatment.
A fire management plan would be developed to address high risk areas, fire prevention,
prescribed burns, rehabilitation and restoration, hazardous fuels reduction, and the protection of
life and property.
Moab Draft EIS Chapter 1: Purpose and Need
Issue 10. How should non-WSA lands with wilderness characteristics be managed? Identify
what decisions need to be made to protect or preserve wilderness characteristics (naturalness,
outstanding opportunities for solitude, and outstanding opportunities for primitive and
unconfined recreation) in appropriate areas on lands with those values outside of existing WSAs.
There are also other issues related to resources and resource uses that are required to be
considered during land use planning efforts that were not identified during public scoping in
accordance with BLM's Land Use Planning Handbook (H-1610-1) and NEPA regulations and
policy. These include decisions for soil and water, wood-cutting, ROWs, environmental justice,
and air quality, as well as impacts to socioeconomics, among others.

 

[greenjeep]

Although judging by the interest in this thread, nobody give a sh!t about keeping Moab trails open!

 

[scoutabout]

Come on guys! Spend a few minutes reading this info! Help save a trail!

 

[Seth]

This is exactly the information needed. People don't be intimidated. Please write in.

 

[Greg]

I've read it, working on my letter. Just because no one replies doesn't mean no one cares.

 

[Brett]

Reading.....and will write a letter at home this evening. They frown on that at work

 

[Badbuggy]

Working on a letter too, this is alot of information to sort through. Thanks Dave for putting it together.

 

[greenjeep]

Thanks guys for showing some interest in this. This analysis is exactly what we have been waiting for, let's do our best to put it to good use.

Just to reiterate, keep these recommendations from Blue Ribbon Coalition in mind; I'm going to CC my replies to our congressmen, senators, Moab's mayor, and the Grand County Council.



WHAT YOU NEED TO DO:

For maximum effectiveness:
1) Using the information provided from BLM and BRC's websites, as well as the info and the comment suggestions below, write a comment letter addressing Issues and Alternatives presented in the DEIS.

2) Copy your letter to your political representatives. Snail mail works best. Pen a quick personal note to your politico's staff and make sure they know you are PRO access, that you visit the area and that you oppose both the rhetoric and the proposals of the so-called "environmental groups." Find the address of your politico's here: Rapid Response Center (just enter your zip code)

3) 'CC' your comments to BRC
CC your comments to BRC at brlandsinfo@sharetrails.org. In the Subject line please put Moab RMP Comments.

Extra Credit:
Comments will be most helpful if you can state very specifically what you like and what you don't like about each of the Alternatives. Suggest changes. Also, it is good if you can reference a section or page number.