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Old 01-10-2012, 01:57 PM
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Default COLORADO BLM Comments Needed on Kremmling and Colorado River Valley Proposed RMPs

COLORADO BLM Comments Needed on Kremmling and Colorado River Valley Proposed RMPs

Our partners over at the Colorado Off-Highway Vehicle Coalition (COHVCO) have just forwarded us information on two important issues that need IMMEDIATE ACTION.
Two Bureau of Land Management Field Offices are updating their management plans, including travel management. The gang at COHVCO has been doing yeoman's work analyzing these plans and helping develop some comment ideas.
We've combined both of COHVCO's action alerts below and recommend you take action on both alerts today! Please pass this important alert on to your friends and family, and please ask them take action as well.

As always, if you have any questions or concerns, please contact BRC.

Thanks in advance for your support,

Brian Hawthorne Ric Foster
Public Lands Policy Director Public Lands Department Manager
208-237-1008 ext 102 208-237-1008 ext 107

Action Alert from COHVCO -
BLM's Kremmling Office Proposed Resource
Management Plan needs your comments!!
This e-mail may be one of several you will receive from COHVCO, AMA, BRC or other organizations asking for your help. PLEASE read and respond as suggested. Your help is greatly appreciated as we continue the fight.
BLM's Kremmling Office Proposed Resource Management Plan needs your comments.
The Kremmling Field Office ("KFO") of the BLM located in Kremmling, CO has released the proposed Resource Management Plan ("RMP") for the office and is looking for public comment by January 17, 2012. The Kremmling Office manages BLM lands located north of I-70 between the eastern boundaries of the Medicine Bow/Rout National Forest and western boundaries of the Arapahoe Roosevelt National Forest. The office has extended the comment deadline until January 17, 2012 and your comments are needed!

Comments should be mailed to:
Kremmling Field Office-Dennis Gale, RMP Project Manager
PO Box 68
Kremmling, CO 80459

Your comments may also be emailed to: co_kremmingrmp@blm.gov

The RMP proposes to:
1. Decrease cross-country travel currently allowed on 307,300 acres to 200 acres;
2. Decrease designated route mileage for full-size vehicles from 1,739 miles to 872 miles;
3. Decrease designated route mileage for ATVs from 73 miles to 14 miles;
4. Decrease designated single-track route mileage for motorcycles from 53 miles to 21 miles;
5. Decreasing mileage for mechanized/ non motorized from 99 miles to 72 miles; and
6. Decreasing mileage for foot/horse traffic from 33 to 6 miles.
Alternative D is the best alternative for OHV recreation but this Alternative fails to address usage trends on the Office and fails to provide a viable plan for realistic management of the lands over the expected life of the RMP. The RMP could be outdated at the time the final decision document is released. COHVCO and TPA are opposed to Alternative C as the Alternative lacks scientific basis and violates both state and federal planning guidelines.

COHVCO and TPA's concerns are:
1. The RMP provides a large amount of information regarding uses which are very disorganized and hard to review. The lack of basic organization will limit the amount and effectiveness of public comment provided. Combining travel management and resource management plans is simply not a viable management process, and these issues should be addressed separately. There is simply too much information to be analyzed under a combined plan.
2. There is no meaningful analysis of travel management issues in the RMP. The travel management portion of the RMP is covered in 51 pages addressing four alternatives for 378,884 acres.
3. The economic impact of the proposed travel management closures in the RMP has been incorrectly calculated. The RMP asserts that closure of 50% of the motorized routes will have no negative economic impacts. This calculation is simply incorrect, as every mile of trail has value as a recreational resource. A lack of access has already been identified as a hunting management issue on the KFO, and closing 50% of routes will clearly impact many uses outside motorized recreation.
4. The Travel Management Plan proposed simply does not reflect current usage levels, future usage projections developed in the numerous state planning documents which must be reviewed and incorporated in federal public lands management. The failure to accurately address demands on the KFO going forward will result in a plan that rapidly looses utility for on the ground management.
5. The RMP moves to a fully designated trail system for all users but the benefits of the designated trail system change simply are not addressed. The RMP does not analyze why the habitat protection of a designated trail system is not sufficient to achieve RMP objectives and why the RMP finds further closures are necessary, when most habitat management plans identify a designated OHV trail system as the single biggest step towards protecting habitat.
6. While the initial closures proposed in the RMP are painful for the OHV community, many of the standards and guidelines proposed lay the groundwork for significantly more closures in the future, if area specific travel management plans are developed to address site specific issues. The issue specific travel management standards (i.e.: big game habitat, lynx and sage grouse habitat) are often not supported by scientific research and often directly conflict with regional management guidelines for the species. The RMP standards almost always seek to exclude motorized access first, even if it is not identified as a concern in regional planning documents.
7. The RMP proposes "optimize big game habitat". This standard is of significant concern as most of the planning office is mule deer habitat and optimizing this habitat would require removal of any use that could impact the mule deer, such as inadvertent striking of deer by motor vehicles on arterial roads. This lack of analysis for travel management related issues is a violation of NEPA's requirements for a detailed statement of high quality information of why decisions in the Plan have been made. If the required NEPA analysis had been undertaken, the fallacy of these positions would have been revealed to the persons who developed the RMP.
8. The RMP proposes closure of all roads and trails on landlocked parcels to all motorized travel. No management issue is identified as the basis for this closure and this blanket closure will worsen issues on the significantly restricted trail system proposed in the future, as these landowners will now be forced to use other motorized recreational opportunities in the planning office.
We have to note the above concerns are NOT a form letter that can be cut and pasted for a comment, and there is a good reason for that. If a form letter type comment is used, the form letter is counted as one comment regardless of how many times it is submitted. We believe the closures are very important issue to everyone and want to make sure everyone's voice is heard. If the above bullets are personalized, that should be sufficient to allow each comment to be viewed separately and be of more value in the planning process.
PLEASE TAKE THE TIME TO SEND IN YOUR COMMENTS!!

Action Alert from COHVCO
Your comments are needed regarding:
The Colorado River Valley (Glenwood Sp.) office
proposed Resource Management Plan

This e-mail may be one of several you will receive from COHVCO, AMA, BRC or other organizations asking for your help. PLEASE read and respond as suggested. Your help is greatly appreciated as we continue the fight.
The Colorado River Valley (Glenwood Springs) office of the BLM has their proposed resource management plan out and they are looking for comments. Many people are not familiar with the office. Click on the following to view its location:
http://www.blm.gov/pgdata/etc/medial...ge.-1.-1.1.jpg

Comments need to be mailed by January 17, 2012 to:
BLM CO Colorado River Valley Field Office
2300 River Frontage Road
Silt, CO 81652

Or emailed to: cormpkg@ttsfo.com

The Colorado River Valley Plan proposes to:
1. Eliminating all cross-country travel currently allowed on 123,000 acres;
2. Decreasing designated route mileage for full-size vehicles from 760miles to 470 miles;
3. Decreasing designated route mileage for ATVs from 82 miles to 62 miles;
4. Decreasing designated single-track route mileage for motorcycles from 85 miles to 66 miles; and
5. Close an additional 47,900 acres to open snowmobile recreation; and
6. Close snowmobile usage on anything other than a trail on an additional 14,800 acres.
While all forms of motorized recreation are to be restricted, non-motorized usage expands significantly:
1. Increase mileage for mechanized/ non motorized from 180 miles to 220 miles; and
2. Increase mileage for foot/horse traffic from 160 to 420 miles.
Alternative D is the best alternative but it still fails to address usage trends and economic impacts on the CRVO- COHVCO and TPA are opposed to Alternative C as the alternative is very weak scientifically and violates both state and federal planning guidelines.

COHVCO and TPA's concerns are:
1. There is a lot of information provided in the plan for a lot of uses- however it is very disorganized and hard to review. Travel management analysis and decisions appear to have been overlooked in the development of the plan and there is no analysis of why all routes closed for motorized usage were assumed to be available for non-motorized and mechanized usage going forward.
2. The lack of analysis for travel management related issues is a violation of NEPA's requirements for a detailed statement of high quality information of why decisions in the Plan have been made.
3. The economic impact of the proposed closures in the travel management portion of the RMP has been overlooked, such as examination of the economic impact of closing approximately 40% of the motorized routes on the planning area. A lack of access has already been identified as a hunting management issue on the CRVO, and closing 40% of routes will clearly impact many uses outside motorized recreation. The RMP asserts that closing 40% of the motorized trails will result in no negative economic impacts to Colorado communities. This simply is not correct as the RMP notes that 85% of users will seek other recreational opportunities if the route is not provided in the CRVO area.
4. Motorized users are the only loser in the plan as travel management is the first tool used to address management issues that have nothing to do with travel management, like big game hunting issues and cave management.
5. The Plan moves to a fully designated trail system for all users- however the benefits of the change simply are not addressed. The Plan does not analyze why this protection is not enough and further closures are necessary, when most habitat management plans never identify the need for any trail closures to protect the species.
6. User conflicts are often overstated to obtain closures for other reasons and most user conflicts cannot be addressed with closures of trails and roads.
7. Loss of the Gypsum Hills SRMA area is unfair and violates the spirit of why it was originally created as it was created to off-set the impacts of the two WSAs in the area. The WSA are still present and the SRMA should not be removed until there is a proposal for removal of the WSAs.
8. Closure of the Hardscrabble Area for motorized access and subsequent designation the Hardscrabble area for targeted recreational motorsports activities is not only inconsistent and verging on offensive. This plan fails to given any analysis of the existing motorized opportunities that will be lost in the Hardscrabble area.
9. Many of the Wilderness characteristics areas and areas of critical environmental concern
10. Many proposed management standards violate multiple usage requirements such as the standard of managing all big game habitats to optimum standards.

We have to note the above concerns are not a form letter that can be cut and pasted for a comment, and there is a good reason for that. If a form letter type comment is used, the form letter is counted as one comment regardless of how many times it is submitted. We believe the closures are very important issue to everyone and want to make sure everyone's voice is heard. If the above bullets are personalized, that should be sufficient to allow each comment to be viewed separately and be of more value in the planning process.
PLEASE TAKE THE TIME TO MAKE YOUR CONCERNS BE HEARD!!
PLEASE SEND IN YOUR COMMENTS!!




The Colorado Off-Highway Vehicle Coalition
was formed in 1987 by a group of leaders from the Four Wheel Drive, Motorcycle, Snowmobile and ATV communities. COHVCO is a coalition working to protect your right to enjoy your public land!
COHVCO works to promote legislation and regulation favorable toward OHV recreation. COHVCO has established relationships with Federal and State Legislators and Land Managers to enhance OHV opportunities in Colorado.
COHVCO works closely with local clubs, state and national OHV organizations, as well as other trail and recreational coalitions to promote OHV opportunities and responsible use of our public land.
You need COHVCO and COHVCO needs you.

COHVCO
P.O. Box 620523
Littleton, CO 80162
www.cohvco.org

The Mission of the Colorado Off-Highway Vehicle Coalition (COHVCO) is to represent, assist, educate, and empower OHV recreationists in the protection and promotion of off-highway motorized recreation throughout Colorado. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations.
__________________
Member: SAWS - WSSA - BRC






Last edited by rmk2112; 01-10-2012 at 02:01 PM.
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