Posting this lengthy message from USA-ALL.....READ IT! ACT ON IT!
We need everyone's help on this, IT'S NOT JUST A UTAH THING!
Thank you for your support!
Jeff Turner
Imtn Chapter Pres
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USA-ALL LAND USE UPDATE:
IMPORTANT CLARIFICATION -- URGENT ACTION STILL REQUIRED
COMMENT DEADLINE DECEMBER 30 2003
Dear Friends,
I want you all to know that everyone at USA-ALL really appreciates those who are writing to the Moab BLM office. We really like it when you guys 'cc us your comments. It's great reading!
We've had folks contact us regarding two important issues and asked for clarification. Please see the information below.
Thank you all so much for the kind words and Holiday greetings.
Brian Hawthorne
Utah Shared Access Alliance
USA-ALL MOAB UPDATE -- IMPORTANT CLARIFICATION
IMPORTANT ISSUE NUMBER 1: Special Recreation Permit regulations should not be incorporated into the RMP.
Folks are very concerned about BLM's new Special Recreation Permit regulations and how they might be incorporated into the new Moab Land Use Plan. The Bureau of Land Management (BLM) requires Special Recreation Permits (SRP’s) for commercial recreational operations, competitive events and activities, and for organized group activities and events.
Last year, BLM revised their regulations on how they issue Special Recreation Permits. Previously, BLM required SRP's only if the group size exceeded a 50 person limit, of if any money was charged for any reason.
The new regs still require permits under these circumstances, but they permit Field Office Managers to implement much stricter guidelines if they wish. An example of how a BLM office might implement is available on BLM's Salt Lake Field Office's website:
http://www.ut.blm.gov/saltlake_fo/Recreation/Recreation/recreation.htm and also here:
http://www.ut.blm.gov/saltlake_fo/Recreation/More Info/srp.htm
Moab BLM has not decided how to implement the new regulations. They are currently requiring permits only if there is a fee or if the 50 person limit is exceeded.
Naturally, USA-ALL is concerned about how the new regs might be implemented nationally. But the issue at hand is the BLM's intent to incorporate these new, untested regulations into their new Resource Management Plan (RMP).
BLM's information states:
"€ Incorporating into the plan Special Recreation Permit (SRP) policies and regulations that require consistent application within the planning area and coordination with neighboring BLM offices. Establish limits of use or limits of acceptable change that will protect resource values while satisfying the public's demand for these uses."
Why in the world is that a problem?
It's a potential nightmare. Incorporating a policy such as this into the Resource Management Plan removes any flexibility. If for some reason their plan isn't workable, in order to change the policy the BLM will have to amend the RMP. Also, if the BLM can't implement the new policy, for any reason whatsoever, anyone with a piece of paper, and envelope and a stamp can file a successful lawsuit.
>From behind the wheel of a club president's 4x4, navigating the permit process can be a REAL nightmare. Permits mean applications must be filled out correctly and submitted on time. Fees must be paid and stipulations met. BLM can require a club have insurance and possibly pay for environmental analysis.
If you fail to dot every I and cross all those it's you might find yourself in some real hot water.
Here's a nightmare scenario, and it's true! A motorcycle club recently applied for a race permit in the Moab Office. All but 10 miles of the race is on trails that have been permitted for races as recently as 2001. Every inch of the trail is on existing, legal trail, and much of it is on county roads.
Yet the Moab BLM notified the club that it would cost them over $19,000.00 for environmental analysis and monitoring. Given that all but 10 miles of the course has been previously studied, that amounts to about $1,900.00 per mile!
This is an issue the OHV groups are going to need to address on a National level. Rest assured USA-ALL will be contacting our National Partners regarding this important issue.
But the task at hand is just a bit different. We need to persuade the BLM not to include any specific SRP mandates in the new RMP. We need to let them know that OHV clubs are a resource for them in helping manage OHV use. We need to remind them that most of these clubs are social, community organizations and we often raise funds for local charities. The BLM should not be making it HARDER for these clubs to recreate on public lands!
Please scroll down to "WHAT YOU NEED TO DO" below or access our website for important comment information. Please make those comments today! Go to
http://www.usa-all.com and click on "Action Alerts" for more information.
IMPORTANT ISSUE NUMBER 2: De-facto wilderness management.
Another issue the BLM has in their planning documents is the notion of designating something called: " € Identifying Backcountry Management Areas and establishing management objectives."
Lots of folks want to know if the BLM's Backcountry Management Area" is anything like the BlueRibbon's Backcountry Designation Initiative (see:
http://www.sharetrails.org/index.cfm?page=38 )
The answer to that question is definitely not. BlueRibbon's proposal is for a Congressionally established Backcountry Area designation. It's a Congressional designation just like a Wilderness Area or National Park. BLM cannot ask or propose or even study another congressional designation. They must manage their lands as Congress intended, under the principles of Multiple Use and Sustained Yield.
This is precisely the problem. BLMers, since the Babbitt era, have been looking for ways to take lands out of Multiple Use management. They clearly want to manage lands as de-facto wilderness areas. Remember the proposal by the Arizona Strip BLM to designate vast "Primitive Areas"?
Could this be a similar scheme? Maybe, we don't know because BLM has included ZERO information regarding what a "Backcountry Management Area" is, or might be.
Recreaionists need to comment!
BLM needs to know that we don't like it when the BLM suggests something that the public doesn't fully understand. We need them to clarify what a Backcountry Management Area is. They need to know that you do not support de-facto Wilderness Study Areas whether they be BMA's or some other similar designation.
The BLM should not be attempting a Zone Management concept, which is not authorized by law or regulation. BLM must formulate management plans that reflect the Multiple Use/Sustained Yield policy of the United States regarding all public lands! Tell the BLM that they should abandon any designation that specifically manages for "wilderness character".
WHAT YOU NEED TO DO:
Letters need to be sent to the BLM regarding several key issues. Please take a minute and read the information below and send your comments via email or U.S. mail as soon as possible. We've made it as easy as possible for you to understand these important issues. However, if you have any questions give USA-ALL a call at: 801-465-1145
Send comments via email to: Brent Northrup at
[email protected]. or via U.S. Mail to: Brent Northrup, 82 East Dogwood, Moab, Utah 84532
Tips and pointers:
Comments must include your name and address. Be certain to mention that you want to be added to their mailing list so you will be notified of future opportunities to comment. You can learn more about BLM's planning process on their website at:
http://www.moabrmp.com . Preliminary issues can be found at
http://www.moabrmp.com/documents.html (click "pre-plan")
Letters should include a brief description of how important OHV recreation is to your family.
SPECIAL HINT #1 Tell the BLM about your club and all of the great work you do. Tell them how your club instills a proper backcountry recreational ethic. Include a link to your clubs homepage so you can let them see for themselves how much we work at recreational ethic education. Ask them why in the world they would consider a policy that makes it HARDER for your club to have runs on Moab trails!
SPECIAL HINT #2: BLM is apparently attempting a Zone Management concept, which is not authorized by law or regulation. BLM must formulate management plans that reflect the Multiple Use/Sustained Yield policy of the United States regarding all public lands! Tell the BLM that they should abandon any designation that specifically manages for "wilderness character".
Comment Suggestions:
** The Moab area is extremely important to my family. I want the BLM to acknowledge the importance of OHV recreation.
** Please keep all existing roads and trails open.
** Please keep all washbottoms open for vehicle travel. Dry washes are very valued by OHV users.
**I would like the following routes to be considered for inclusion in the BLM OHV route inventory, as requested by Planning Bulletin #3:
"The Rusty Nail"
"Where Eagles Dare"
"Escalator" and "Gates of Hell" on Hell's Revenge
"The Pickle"
"Killer Kane Mines"
All of these are very highly valued by 4 wd folks. Please include these routes in the Easter Jeep Safari permit system.
**The special recreation permit process is too hard and too expensive for OHV clubs. Please allow for group rides of 50 people and under without any permits. Our club works hard to teach a proper OHV use ethic. Why in the world would BLM consider a policy that makes it harder to visit Moab with a club?
**Please remember that motorized vehicles are the only means of access to the backcountry for many Americans with physical disabilities. This portion of the public deserves to be able to experience the remote and scenic wonders that Moab offers as much as the able-bodied.
**Motorized recreation is an activity that is enjoyed by millions of American families. Moab is one of the premier destinations for a great number of these people. OHV users contribute millions of dollars each year to the local economy.
**Closing existing trails would have an adverse effect on the surrounding area. Fewer legal trails would cause overcrowding on the remaining open routes. This may lead to increased off-route travel, resource damage and user conflicts.
** OHV recreation is a family oriented social experience. OHV enthusiasts prefer to recreate in groups and often belong to clubs and organizations. OHV clubs should be seen as a resource to BLM. Clubs can help leverage OHV grant money for OHV management and law enforcement. BLMs new plan should not make it harder for clubs and organizations to visit and enjoy the Moab area.
** Ask the BLM to clarify what a Backcountry Management Area is. Tell the BLM that you do not support de-facto Wilderness Study Areas whether they be BMA's or some other similar designation.
** BLM should formulate a complete and accurate inventory of currently used travelways.
** BLM should realize that there is extensive opportunity for "primitive" recreational pursuits in adjacent National Parks. In Canyonlands National Park, for example, there is over 1/2 million acres of lands that are currently managed as Wilderness.
** There is no need to provide additional "primitive" opportunity. Conversely, there is a need to provide more designated motorized and mechanized trails.
** BLMs new plan should provide instructions to land managers to engage in cooperative management efforts with OHV groups.
** The new plan should recognize OHV clubs and organizations as a resource the BLM can use to leverage OHV grant money and to educate the public on proper backcountry recreational use.
** BLM's new plan must prudently provide increased OHV recreation opportunities to meet current and anticipated demand.
** BLM planning must develop alternatives that provide for the dramatic increasing demand for OHV recreation opportunities and anticipate even more demand in future years.
** OHV clubs and organizations should be considered a resource to the BLM. The RMP should not require a special recreation permit for groups under 50 people.
**I defiantly do not support de-facto Wilderness designations. Please manage all lands in the Moab area under Multiple Use principles.
**I oppose any Backcountry Management designation. The BLM must formulate management plans that reflect the Multiple Use/Sustained Yield policy of the United
States regarding all public lands!
**I support pro active OHV management. The new plan should allow for more cooperation between OHV groups and BLM.
**The new RMP should allow for "adopt a trails" and other agreements in order to manage OHV use. I do not support the manner in which BLM has relied on closures to deal with resource issues.
** I also strongly oppose any kind of "designation" that is designed to protect "wilderness qualities". Only Congress can designate Wilderness. BLM's authority to look for and manage for wilderness qualities has ended.
** I do not support any kind of zone management. BLM must formulate management plans that reflect the Multiple Use/Sustained Yield policy of the United States regarding all public lands!
** The BLM should abandon any designation that specifically manages for "wilderness character".
** BLM should formulate a complete and accurate inventory of currently used roads and trails. This information should be available to the public for review prior to release of any alternatives.
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