MOAB Comments Needed by 11/30/2007

Submitted by tsm1 on Wed, 11/14/2007 - 10:49

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

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:

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

Read on for more details on what to comment on and how..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. ( 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!!


BLM information and documents:
The Moab DRMP/DEIS and supporting information is available on the project web site at:

BlueRibbon Coalition Resources:

What the anti-access groups are doing:


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 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.


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"


Comments may be submitted electronically to: 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.

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.


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.

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.

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 ( 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, 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.