----------------------------------------------------------------------------------------------------------------------------------------------------------------
September 12, 2004
Questions & Public Comments
----------------------------------------------------------------------------------------------------------------------------------------------------------------
There is a lot wrong with the Draft Environmental Impact Statement (DEIS) that the BLM has produced. Here are some issues to raise:
Record of Decision (ROD): Why does the BLM not have a copy of this document available for the public to review since the DEIS? The Salinas Ramblers were certainly able to post it. What is their problem? Are they afraid for the public to know what was decided during an eight year process in the 1990s and for which they have done a marginal job of implementing. Maybe they lost it? Doesn't seem that they paid an attention to it while preparing the DEIS!
Scoping Period: For starters, the BLM released the DEIS without conducting an EIS scoping period and soliciting public comment. They will claim that they conducted scoping with public involvement by working with the Technical Review Team but these meetings were a joke and nothing meaningful ever transpired. In addition, they have failed to follow NEPA (National Environmental Policy Act) guidelines and prepare a formal scoping document. The Club requested a copy of this document 45 days ago. If they had done one, it should have been available long ago.
Trail and Barrens Designation Criteria: The first time that the general public saw of these criteria was when the DEIS was released. These criteria were created the vacumn of the Hollister Office with little input by the OHV community and it shows. The general public has had NO opportunity to comment on these criteria. These criteria should have been presented to the public for comment during a scoping period and fine tuned before the BLM took any action to designate trails.
Alternatives: The BLM states in the DEIS that "The alternatives selected for analysis were developed with public involvement,..." but nothing could be further from the truth. This whole process to date has bee a sham and a disgraceful display of arrogance (or perhaps stupidity) by an agency that does not have a clue how to manage OHV recreation.
Open unless posted closed: The Record of Decision calls for the area to be managed as "Open unless posted Closed. While this terminology is not specifically cited, the combination of the definition of limited use meaning that use must remain on existing routes and the EAP management philosophy in effect provide for the area to be open unless posted closed. In the DEIS, the BLM redefines the meaning of limited use and specifies that use most remain of designated routes. In other words, it a route does not have a sign on it stating that it is open, then it is closed. Therefore, the DEIS is inconsistent with the ROD.
Encourage, Allow, Prohibit (EAP): On page 53 of the DEIS is a discussion of EAP. Whoever wrote it certainly did not read the ROD because it clearly states that all routes would be shown on a user map. The BLM claims that "This management strategy has proved extremely difficult at best." What a joke for them to say that the EAP management philosophy doesn't work because they have never implemented it.
Route Mileages: Because they changed the definition of Limited Use and thrown out EAP, in the DEIS preferred alternative they have limited routes for general use to 209 miles of routes, some of which are on private or state land. While I have not determined the true number of miles outsile the BLM control, I believe that it would bring the total below 200. In their "Enhanced Recreation" alternative -B - there are only 230 again with some existing on private and state land.
Now, if you assume the ROD states that there will be 270 miles of routes as the BLM does, then why did they not propose an alternative with at least that number of miles of routes that are open for the public? Read the DEIS carefully. The BLM has lumped 25-28 miles of closed administrative miles into their route total. These routes should be included in the closed total that they are afraid to list.
Barrens: The Record of Decision, that the BLM has kept hidden from the public during this entire process, calls for approximately 937 acres of barrens controlled by the BLM to be open to the public. Neither Alternative A nor B meets this requirement. What gives. In addition, the BLM is proposing to close some of the most popular barrens in Clear Creek, the area just above Staging Areas 1 and 2 while keeping open flat barrens that have very little recreational value.
Private Property: The BLM does not control what happens on private property so why then are they counting routes on private and state land? These routes could be closed at any time by the owner. This whole DEIS process is backwards, i.e. cart before the horse. The last time I spoke with the BLM they had not yet contacted the private property owners in clear creek. How can you develop a management plan and a route system if you don't know the intentions of the inholders???