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Speak up or Shut up

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By PATSY STODDARD Editor

Time is running out for comments on the BLM resource management plan

Water is strangely absent at the South Coal Wash even though this wash is being considered for wild and scenic river designation in the BLM draft resource management plan.

Now is the time to submit comments regarding the Price Field Office Resource Management Plan. The deadline for comments for this draft RMP is drawing to an end. Nov. 29 will be the last day for submitting comments.
To date, 50,000 comments have been received from all over the United States as well as comments from people in other countries. How many comments have come from the Carbon and Emery county people who will be affected the most by the final RMP document?
The Emery County Economic Development Council hosted a RMP information meeting on Nov. 16 to help citizens form their comments. Representatives from the BLM, Ruth McCoard and Floyd Johnson were on hand to take questions from the audience and add the BLM perspective to the discussion. Emery County Public Lands Director, Ray Petersen displayed the draft RMP on the screen and went over the different aspects of the RMP.
He stressed that the most important thing right now is to make a substantive comment and make your views and perspectives of the actions and directives taken in the draft RMP known to the BLM. The only way to do this is to get your comments into the BLM by Nov. 29. You can make your comments on the email to Comments@pricermp.com or the internet at www.pricermp.com. You can mail a letter or fax a letter to 435-636-3657. The mailing address is Price RMP/EIS Comments, Bureau of Land Management, Price Field Office, 125 South 600 West, Price UT, 84501.
Petersen pointed out the RMP is a massive document which includes two volumes. It contains sections on air quality, soil, water and riparian, vegetation, cultural, paleontology, special status species, fish and wildlife, wild horses and burros, fuels and fire management, non-Wilderness study areas, forests and woodlands, livestock grazing, recreation, minerals and energy development, special designations, wilderness study areas, wild and scenic rivers, areas of critical environmental concern, transportation and motorized access, environmental concerns and impacts and socio-economics. The document also contains a number of maps, graphs and tables.
The BLM has developed five alternatives with different combinations of management to address issues and resolve conflicts among uses. Alternatives must meet the purpose and need; be reasonable; provide a mix of resource protection, use and development; be responsive to the issues; and meet the established planning criteria. Each alternative is a complete land use plan that provides a framework for multiple use management of the full spectrum of resources, resource uses, and programs present in the planning area. Under all alternatives BLM will manage the public lands in accordance with all applicable laws, regulations, and BLM policy and guidance, as well as the Standards for Rangeland Health.
Johnson pointed out that Alternative D is the preferred BLM alternative, but the final document will be a modified version of all the alternatives with bits and pieces of each. As the final document is prepared with all the comments received being taken into consideration; the draft document will be amended as needed to address the concerns raised when all of the comments are evaluated.
Alternative A allows the most liberal use with Alternative C being the most restrictive of uses.
None of the alternatives deal with current WSAs as they will be designated by Congress at some point in time or not, this also applies to wild and scenic river designations.
Petersen said he believed the draft document to be flawed and as it is going to be the management tool for the next 15-20 years, “Now is the time to voice your criticism of the alternatives. Tonight we want to help you formulate comments,” said Petersen.
Kathleen Truman emphasized that form letters are not the way to go. “Comments are important and the BLM needs substantive comments. For instance, people need to say, in this area you propose this and a more appropriate use would be to do this and then list the reasons why. Those comments are used to address issues in the final document.”
It was also mentioned that the BLM should be as consistent as possible to county plans already in place.

Bellevue Flat may be in a semi-primitive motorized area under the new resource management plan.

Discussion went on to the wild and scenic rivers designations in the alternatives. It was noted that streams (dry washes) are listed that do not run all the time. Be specific with your comments and say, “I don’t think this stream is eligible because it only runs once every six years.”
It was noted by Alan Peterson that some rivers are listed as wild in one alternative and scenic or recreation in another alternative. He wondered how this could be when it is the same river all the time. Johnson said that how the BLM would choose to manage it makes the difference. To be eligible a river must meet certain requirements and the requirements are more restrictive under a wild designation than under scenic or recreation. It was mentioned that all valid and existing rights on the waterways would still exist even with designation and also would not interfere with the Colorado River compact. The comments received will help determine the BLM recommendation for wild and scenic river designation. If a river is designated the BLM will be required to manage that river to maintain the characteristics of the listing.
The recreation portion of the draft RMP was also discussed. It was mentioned, if you know of roads which were closed improperly and are not listed as closed on the Route Designation Plan to let the BLM know and also to comment on it so that problem can be corrected in the final RMP.
Truman spoke about recreation in the San Rafael Swell Special Recreation Management Area. The San Rafael SRM contains 936,000 acres except in the no action alternative which is 844,000 acres.
On Map 2-21 the special recreation management area in alternative D lists 113,669 acres as primitive, 110,504 acres as roaded natural, 484,546 acres as semi-primitive motorized and 227,756 as semi-primitive non-motorized. The concerns came with the recommendations of the allotted numbers of people to be allowed into these areas.
The boundaries of the San Rafael SRMA would be realigned to include Mexican Mountain WSA, the Cedar Mountain area, and the area surrounding the cut-off road on Map 2-21. In alternative D for organized groups occupying an area for more than two hours, maximum group size without a permit would be in the primitive areas, 15 people, in the semiprimitive nonmotorized the number would be 25 people and in the semiprimitive motorized the number would be 25.
The roaded natural and others would be limited to 50 except in the designated large group sites.
Groups larger than these would be required to obtain a permit, SRP-special recreation permit. Large group areas would be designated in the San Rafael Swell, developed and made available through reservation. Large groups using these sites would receive a recreation use permit through their reservation. Large group areas would include Temple Mountain, Hidden Splendor, Buckmaster Draw, South Salt Wash, Juniper, Staker Spring Area and others as necessary to meet recreation demand and protect resources.
The question arose as to when you went camping and there were already people there and you camped near them. Is that a group? Or does it have to be just people you bring with you? McCoard said those are the kind of comments that need to be made. Tell the BLM that they have to be more specific when it comes to who constitutes a group. The definitions need to be more defined. If you disagree with the number recommendations then voice your opinion in comments to the BLM.
Emery County will submit comments to the BLM to the effect that they have become too specific by mentioning numbers of people and that those numbers would be more adequately addressed down the road in activity level planning.
McCoard reminded everyone if you do not comment on the draft RMP you will lack legal standing down the road.

The San Rafael is a popular destination for locals and tourists, but things could change under the RMP.

Mike Dunwoody from Green River wondered about the implementation of the RMP. He said the route designation plan has been out for two years now and the signage is still not complete. It was also mentioned that some signage is not correct and signs were placed closing roads which are still open.
McCoard said they recognize that implementation will not take place overnight and that the document is a guideline which may take years to implement and enforce. Comments were made on the improvement of the resource since the signs have been in place and how it looks better than it did three years ago and will continue to improve as the public is educated on where they can and cannot use motorized vehicles.
The need for more accurate and readable maps was discussed and the BLM realized their error in this and plans are being made for improved maps. It was also mentioned that comments need to be made addressing how many yards off a designated road you can go to access a dispersed campsite. This was not done in the route designation plan and confusion exists.
Comments are also needed on the socio-economic impacts. The socio-economic section was left out of the draft document and can be viewed on the BLM website. Mike McCandless, economic development director for the county said there was not a lot of information about mining and gas and substantive comments regarding those issues need to be made.
One rancher expressed his frustration that he waited for two years to get permits to put in a stock watering pond and yet a gas company came in and made roads all over in the same area and he doesn’t understand why things like this happen.
Alan Peterson said he believed the BLM should not be moving forward with layers of protection and designations for land and use without first properly taking care of the route designation. Many motorized routes have been lost. For instance with ACEC, you need to see what’s out there first and fit the land use planning around the routes and uses that already exist, not the other way around. Forty percent of the motorized routes were closed with the route designation plan.
Johnson said, “The BLM hears close everything from the environmental community and keep everything open from some people and we just need to find a middle ground which allows use without destroying the resource.”
Petersen stressed the importance of the working relationship with the BLM. He thanked Ruth and Floyd for attending the meeting on their own time. He said the BLM has been very interested in the county’s views and opinions. Petersen said they do have the interest of the county at heart.
The emphasis again was to make your comments. The worst thing you can do is not comment on the draft RMP document. Also comments to date can be viewed on the website and read. All comments are public information and available for perusal.

BLM Alternatives
No Action Alternative
The No Action Alternative represents current management, as outlined in the 1983 Price River MFP and the 1991 San Rafael RMP, as altered through amendment and policy since adoption of the records of decision for those plans. This management includes a broad array of management methods of various resources with different approaches applying in the former Price River and San Rafael areas.
Alternative A
Alternative A is designed to allow maximum access and development of mineral resources, including oil, gas, coal bed methane, and coal allowed by law, with mineral resource development given primacy over other uses and resource consideration. This is generally characterized through designation of the field office as Open to Leasing for oil and gas with standard terms and conditions, except in areas closed to leasing due to congressional or legislative actions (e.g., WSAs).
Alternative B
Alternative B is designed to balance uses in the field office. This balance is achieved by emphasizing different resources and uses in different areas of the field office. Such management includes application of Areas Open to Leasing, subject to minor constraints (timing limitations, controlled surface use, lease notices) management of minerals development and targeted recreation management within Special Recreation Management Areas (SRMA), to provide for quality recreation setting, experiences, and benefits, and designation of ACEC.
Alternative C
Alternative C is designed to provide maximum conservation and protection for natural resources from minerals and energy development and motorized recreation use allowed by law. Such management includes application of Open to Leasing, subject to minor constraints (timing limitations, controlled surface use, lease notices), No Surface Occupancy, and Closed to Leasing policies for management of mineral resources, management of recreation for more primitive and semi primitive recreation activities within SRMA, designation of ACECs and recommendation for suitability for inclusion in the national Wild and Scenic River system for all eligible rivers in the field office.
Alternative D (Preferred Alternative)
Alternative D is designed to provide for a wide variety of resource needs throughout the field office. This alternative is similar to Alternative B in that it includes maximizing minerals development potential in areas with greatest potential for development, as well as targeting recreation management in areas with the highest potential for development, to provide for quality recreation settings, experiences, and benefits in an environmentally appropriate manner.
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