MOAB, UTAH, Draft Resource Management Plan
BLUERIBBON COALITION ACTION ALERT:
Dear Friends,
The Bureau of Land Management's Moab Field Office in Utah has released their Draft Resource Management Plan (Draft RMP) and Draft Environmental Impact Statement (Draft EIS). The Draft RMP includes a comprehensive travel plan affecting both motorized and non-motorized recreational trails.
The Draft EIS includes four Alternatives, including a "no action" alternative which will be used as a baseline for comparison. Moab BLM has also developed a "Preferred Alternative" which is what BLM would like to do. There are two other alternatives.
The BLM is just beginning a 90 day public comment period. Based on the input they receive, the agency will modify the "Preferred Alternative" into a "Proposed RMP" (and Final EIS). After a brief comment and appeal period, this will ultimately result in a Final Plan (or "Approved Plan"). BLM will likely select parts of all of the Alternatives to formulate the Proposed RMP.
Your comments on this plan are extremely important. But formulating substantive comments may not be easy. The document itself is huge (the Table of Contents alone is nearly 50 pages) and it is difficult to discern exactly what the BLM is proposing to do.
BRC will be releasing a detailed review and analysis of the Alternatives, but it will take several weeks to complete. The purpose of this email update is to give you some help in wading through the document in order to learn what changes the BLM is proposing.
Those of you who regularly visit the Moab office are strongly encouraged to take a look at key parts of the document and provide comments.
As always, feel free to contact BRC with comments or questions. Part of our job is to help you understand what the BLM is proposing and help you make effective comments.
Thanks,
Brian Hawthorne
BlueRibbon Coalition
IMPORTANT NOTE:
BLM is proposing huge changes from what is currently allowed. Much of the proposed management is decidedly "Park-like." While some of the changes are needed, and BRC will be supporting the BLM on many of these, others are arbitrary and unnecessary.
Anti-recreation groups such as the Southern Utah Wilderness Alliance (SUWA) have staff to review the environmental analysis to find flaws that will nudge the final decision their way. Indeed, many stakeholders are paying for professional review of these documents in order to protect their interests. The OHV community must do this as well.
As always, funds for such an effort are limited. In order to raise funds for this important effort, BRC has initiated the "Moab Partnership" program.
Partners make a pledge of $10.00 per month or make a one-time Partnership donation of $120.00 to enroll for one year. Your donation is placed in a restricted account to be used for efforts related to the BLM's Moab and Monticello Field Office planning processes.
Please consider helping us with the detailed analysis this project deserves. Become a Moab Partner today. Click here:
http://www.sharetrails.org/public_la...?section=Moab2
Moab BLM'S Draft Resource Management Plan
and Draft Environmental Impact Statement
AT A GLANCE:
Moab BLM's website is pretty easy to navigate. Check
http://www.blm.gov/ut/st/en/fo/moab/planning.html for the complete Draft RMP and Draft EIS as well as all the background documents.
Comments may be submitted electronically at:
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. To facilitate analysis of comments and information submitted, we strongly encourage you to submit comments in an electronic format.
NOTE:
Please do not send the overworked and underpaid BRC staff emails complaining that the maps are un-readable. We know. If you contact the BLM regarding this, please be polite. We are working with Moab BLM to find a solution.
Brief Description of an EIS
Chapter 1 is the Purpose and Need, where BLM is supposed to define specific areas where management needs to be changed. Chapter 1 also describes the Planning Issues and Planning Criteria.
Chapter 2 is a detailed description of the Alternatives.
Chapter 3 is the Affected Environment section where the agency described the current condition and existing management.
Chapter 4 is the environmental analysis.
Chapter 5 describes the public involvement, consultation and coordination.
Key Sections of the Document:
It will be helpful to review the Dear Reader letter and the Executive Summary. The Executive Summary is worth review and gives a brief description of the "theme" of the Alternatives, but it won't give you much detail.
Chapter 2 describes the Alternatives and includes the "matrix" (pages 2-7 through 2-56). The matrix is a comparison of how each Alternative addresses the key issues. Important sections include "Recreation" (pages 2-17 through 2-20) and "Travel Management" (pages 2-48 through 2-50). This will be a lot easier to understand if you print and reference maps 2-8 A through D as well as 2-9 B through D. (Don't miss the description of how BLM addressed SUWA's "Red Rock Heritage Travel Plan Alternative" on page 2-107.)
Also important are the Recreation Rules in Appendix E, where you will find the Moab BLM's policy on Dispersed Camping and other activities.
Appendix G is the explanation of how the Moab BLM developed the Travel Plan. It will help if you can print and reference the following maps:
Maps 2-10 A through D
Maps 2-11 B through E
Maps 2-11-F B through D
The very brave will want to view Appendix F, the Special Recreation Management Areas (SRMA). But making sense of all of the various "overlays" isn't for the faint of heart!
Appendix F is a critical section. But the way the BLM is managing the SRMA's is unnecessarily confusing. Pay close attention! You'll need to fully understand the difference between Physical and Administrative management zones (Primitive, Back Country, Middle Country, Front County and Rural), Goals, Settings and Outcomes. The final step is to overlay all of that with the travel management program and see if it makes any sense at all. Again, you'll need maps 2-8 A through D.
Advanced level Access Advocates may want to review the "lands with wilderness character" and Areas of Critical Environmental Concern sections. (Chapter 2, pages
2-16 through 2-17, Appendix P and Maps 2-24 B and C for lands with wilderness character. ACEC's are on pages 2-33 through 2-39. Reference maps 2-14 A through C.)
Long time BRC members probably just felt a chill down their spines. The "lands with wilderness character" business is the legacy of Bruce Babbitt and his illegal effort to double the amount of Wilderness Study Areas in Utah. It's a long story, and we'll post details on our Moab Update webpage soon. But it is a key problem for recreation, and not just for motorized recreation. This is because some recent BLM plans require the agency to "enhance" wilderness character, instead of say, "maintain" or "protect against significant impacts." What this means is that eventually, these lands will be managed as Wilderness.
De-facto Wilderness. Nice....
That's why BRC and other multiple use stakeholders oppose this designation altogether. Let me be perfectly clear. Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of the Federal Land Policy and Management Act (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 legal mandate and no process requirement for engaging in an ongoing, never ending wilderness inventory and 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 WSAs, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
IMPORTANT INFO ABOUT MAKING COMMENTS:
Your comments on the Alternatives are extremely important. But the BLM is saying comments containing only opinion or preferences will be considered and included as part of the decision making process, but they will not receive a formal response from the BLM.
Comments will be most helpful if you can state specifically what you like and what you don't like about each of the Alternatives. Suggest changes and be specific. Include information, sources, or methodologies if possible. Also, it is good if you can reference a section or page number.
BLM is also encouraging feedback concerning the adequacy and accuracy of the four proposed alternatives, the analysis of their respective management decisions, and any new information that would help the BLM produce a Proposed Plan.
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. To facilitate analysis of comments and information submitted, we strongly encourage you to submit comments in an electronic format.
