Update on Carson BLM RMP Revision Comment Suggestions Included

Update on Carson BLM RMP Revision Comment Suggestions Included Hot

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BlueRibbon Coalition

We wanted to update our members on the progress of the Nevada BLM's Carson City District Office process to revise their Resource Management Plan. We also have a few comment suggestions for folks who haven't made comments yet.

The comment deadline is Monday, April 30, 2012 so please take a minute to send an email today.

BRC's Don Amador and Del Albright have been working with various OHV clubs across California and Nevada on various issues related to this important planning effort. Both Del and Don report that many OHV clubs are very involved and have been in contact with the BLM planning team.

Del and Don report that the BLM has been receptive to the concerns of the OHV community. Naturally, everyone is approaching the process with a bit of trepidation. These are popular recreation destinations, and the greenie groups are going to try to eliminate as much OHV and mountain bike recreation as they can.

Our update includes several important issues. One is that the BLM will be conducting a Resource Management Plan and Travel Plan simultaneously. This "two plans in one" paradigm has been done in most BLM offices, and a successful plan can result. However, it mandates that the entire recreation community get involved early on in the process.

This means that, except for designated "open" areas (such as Hungry Valley), most of the office will be moving to "travel limited to designated roads and trails," and BLM's new "comprehensive travel management" rules limit ALL modalities to designated routes. Equestrian, and mountain bikers take note!

Another update we have is a "rumor control" notice. It is NOT TRUE that BLM is proposing the elimination of target shooting. This office has some "urban interface" and popular family recreation areas were target shooting is likely to be limited. However, they are not proposing a total ban.

To their credit, the Carson City office is planning to host several travel workshops this summer and fall. BRC will be involved, but we can't be effective without the involvement of local OHV clubs and OHV enthusiasts. We'll let you know when and where the meetings are going to be held.

Learn more on the Carson City office RMP revision webpage HERE. To the left of the page there are links to documents, reports, planning timeline, info about issues, maps and other goodies.  

Below is an Action Item with a few comment suggestions.

Thanks in advance and, as always, please call or email with questions or concerns.

Ric Foster
Public Lands Department Manager
BlueRibbon Coalition
208-237-1008 ext 107


Action Item
Comment Suggestions for Nevada BLM's Carson City District Office Resource Management Plan and Travel Plan.

The Bureau of Land Management (BLM), Carson City District - Sierra Front and Stillwater Field Offices - are seeking public comments to identify issues and concerns that should be analyzed in the Carson City District Resource Management Plan (RMP) and Environmental Impact Statement (EIS).

The Carson City office is currently in the "scoping" phase of the planning effort. The scoping phase takes comments on planning issues and potential alternatives. This information will be used to formulate a range of Alternatives to be presented for public review and comment.

Send comments regarding potential planning issues and alternatives to the BLM by Monday, April 30, 2012. The email address is: This email address is being protected from spambots. You need JavaScript enabled to view it. 
Please put "RMP Revision Scoping Comments" in the subject line of the email.

Please be polite and, if possible, make your comment letter as personal as you can.
Use the comments suggestions below as a guideline for your comments. Cut and paste is okay, but try to make your comment letter as personal as possible.

Take just a minute to add a bit about where you live, how you recreate, where you go, how often you go, how long you have been recreating in the area and/or how important the area is to you and your family. Let the BLM know how much you and your family value OHV recreation on the Carson City District.


The BLM should formulate a pro-recreation alternative.
Such an alternative should not substantially reduce the opportunity for OHV recreation. There is an increasing demand for OHV recreation opportunities on public lands and National Forests. BLM's OHV Strategy states, "Motorized off-highway vehicle use on public lands administered by the Bureau of Land Management (BLM) has increased substantially in recent years. At least one Alternative should seek to meet the need to provide for the documented increase in the popularity of motorized recreation experiences. I strongly oppose being presented with a "range" of management alternatives, all of which represent significant reduction in OHV and other recreation opportunities.

Permitted and Competitive events should be planned for in the RMP.
In anticipation of Special Recreation Permit requirements for organized recreation activities - as well as to streamline the permitting process for mountain bike events, rock-crawling events, ATV Jamborees and off highway motorcycle races - BRC suggests the CCDO consider developing an Alternative that would evaluate certain routes/areas for competitive and permitted events. It would provide a public benefit to all trail users, both motorized and non-motorized, to approve routes for permitted events in the programmatic travel planning process. We also believe this would benefit the agency by helping to reduce the future workload when processing permit applications.

BLM planning must recognize and address the need for the "Open" designation where appropriate.
There are areas that have long been used for cross-country OHV activities, with no adverse environmental impacts, such as the Hungry Valley/Moon Rock "play areas." Some open areas are recognized for their high OHV popularity and should be kept available for those who value this type of recreation. Other examples of valued "open" designated areas are: dry lake beds, staging areas that provide recreationists to gather before and after traveling on OHV trails and "Tot Lots" where children and young adults can recreate with their friends in an area close to parental supervision. Some OHV events, such as trials competitions, require the "open" designation to be viable. Staging areas for competitive and other commercial events are another example. The Planning Team is cautioned not to segregate users who value the "open" designation into smaller and smaller areas. Crowding users who require the "open" areas can increase safety risks to the public as increasing numbers of OHV enthusiasts are compacted into ever-smaller areas.

Consideration of non-Wilderness Study Area lands with wilderness characteristics
Many stakeholders believe that the BLM has unlawfully embedded an ongoing inventory and protection scheme for lands with wilderness characteristics in its land use planning guidance. Unlike the US Forest Service, where direction from Congress provides the direction to inventory for wilderness during the revision of each Land Use Plan, this is a very controversial idea for BLM lands.

I respectfully ask the decision maker to carefully consider these comments when considering inventory for wilderness characteristics and potential designation of "LWC" or "Wild Lands" areas.

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 should 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. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for preservation as Wilderness, 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 is done. 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.

While the current regulations allow BLM to inventory for resources or values associated with wilderness, regulations do not allow for formulating management plans based on an inventory for a single resource value. All resources, including OHV and mountain bike recreation, must be included in your inventory for wilderness characteristics.


The BlueRibbon Coalition is a national recreation group that champions responsible recreation, and encourages individual environmental stewardship. With members in all 50 states, BRC is focused on building enthusiast involvement with organizational efforts through membership, outreach, education, and collaboration among recreationists. 1-800-BlueRib - www.sharetrails.org

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