This is the text version of DirtRider.Net
Click Here for the Full Version

• 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"

• 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.

• 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.

• 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.

• 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...ft_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!

• 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.

• 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.

• 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.

• 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.

• 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.

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

• 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.

This is the text version of DirtRider.Net
Click Here for the Full Version