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Hey it's Rick,

I thought I would forward this info on.  We are working really hard to come to the bottom of the issues we have In the Glade.

March 30, 2010

Bureau of Land Management
1235 La Plata Highway, Suite A
Farmington, NM  87401

RE: Glade Run Recreation Area Proposal

Planners et al,

I am President of the New Mexico Off Highway Vehicle Alliance (NMOHVA) and am representing that organization in providing these comments on the Glade Run Recreation Area Proposal.  NMOHVA represents motorized recreationists in New Mexico including 4WD enthusiasts, dirt bike riders, and ATV users.  The Farmington Field Office-managed public lands, and specifically the Glade Run Recreation Area, the subject of this project, provide important recreational resources to the members of the public we represent.

We appreciate the opportunity to provide Scoping comments on the Glade Run Recreation Area Proposal.  We take the responsibility of reviewing the public land management agency documents for compliance with the National Environmental Policy Act, Resource Management Plans, and agency planning regulations with the utmost seriousness. 

We must admit that we are not sure just what we are providing Scoping comments on.  In my conversation with Janelle Alleman, she assured me that it was an Environmental Assessment (EA) for a Glade Run Recreation Area Management Plan but it doesn’t fit within the parameters of any EA we have ever seen.  More importantly, it doesn’t meet the basic requirements of an EA as set forth in 42 CFR 1508.9 (emphasis added):

“Sec. 1508.9 Environmental assessment.

"Environmental assessment":

(a) Means a concise public document for which a Federal agency is responsible that serves to:

1. 1.       Briefly provide sufficient evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact.
2. 2.       Aid an agency's compliance with the Act when no environmental impact statement is necessary.
3. 3.       Facilitate preparation of a statement when one is necessary.

(b) Shall include brief discussions of the need for the proposal, of alternatives as required by section 102(2)(E), of the environmental impacts of the proposed action and alternatives, and a listing of agencies and persons consulted.”

The document on the Farmington Field Office (FFO) web site, Proposed Glade Run Recreation Area Management Plan, does not include any type or form of a Purpose and Need Statement.  As 42 CFR 1508.9 (b) so clearly states, this is absolutely required by the most fundamental of NEPA requirements.  Without this basic element, it is impossible for the public to accurately assess what the agency is attempting to accomplish.  It also strips the public of the ability to make rational and meaningful public input.  This opportunity for meaningful public comments is also a fundamental requirement of NEPA.

Without a clear Purpose and Need statement, we are left to ponder important questions:

• What is the FFO trying to accomplish with the presented alternatives?
• Why are alternatives being presented now?
• What is driving the project?
• Why does Alternative B only identify a special area for singletrack activities?
• Why is there not an Alternative presented for identifying ATV/UTV recreation opportunities?
• What would happen to the designated and proposed trails in the La Plata Travel Management Plan?
• What would happen to the ATV trail in the Glade Run Recreation Area (GRRA) that was announced via Press Release in 2009?
• Is motorized recreation being singled out for special enforcement activity by the FFO?
• Why would the FFO not add a Purpose and Need statement to the proposal document when the public has repeatedly identified this deficiency in the current document?
• Is the La Plata Travel Management Plan (LPTMP) actually the document that currently prescribes management of the GRRA?  We realize that the FFO claims that the LPTMP is the current management document but we remain skeptical given that the same document specifically excludes Special Management Areas including the GRRA.

In terms of general input toward the management situation for the Glade Run Recreation Area, we are resubmitting our pre-scoping comments submitted in our letter dated January 11, 2010:

1.  The GRRA is highly valued by NMOHVA and its diverse motorized recreation membership for its very existence, its terrain, and its location.  The mere existence of the GRRA is highly valued as Special Recreation Management Areas (SRMA’s) that provide motorized recreation opportunities are all too rare given the user base.  Motorized recreation is growing and this burgeoning need is badly underserved by the federal land management agencies.  While the western United States, including New Mexico, are blessed with an abundance of public lands on which to recreate, the growing numbers of users and the attendant concerns about compatibility with resource health has severely restricted venues where motorized recreation is welcomed.  Providing suitable SRMA’s where more intensive recreational use can be sustained is one avenue available in supporting this growing need.

The GRRA also contains a concentration of interesting and varied terrain that lends itself well to meeting the broad spectrum of needs of our members and larger motorized recreational community.  From the broad sandy washes to the pinon-covered mesas to its highly eroded sandstone formations, the GRRA provides opportunities for just about everyone.  The GRRA has achieved and enjoyed national acclaim as a destination for high challenge rock crawling but also offers spectacular terrain for milder forms of 4WD enjoyment, observed motorcycle trials, ATV and ROV use, and single-track motorcycle trails.

The location of the GRRA directly adjacent to Farmington offers both benefits and challenges.  Access for local residents is literally minutes away, offering a perfect location for a quick ‘after-work’ ride to purge away stress or an ideal location for a day trip of family-based recreation.  The location of the GRRA provides significant economic benefit for the City of Farmington as motorized recreationists take full advantage of the City’s nearby lodging, dining, supplies, and services.  The challenge lies in the additional factors required for successful management of diverse forms of recreation in an urban interface environment.

2.  NMOHVA membership enjoys and partakes in the full gamut of motorized recreational activities:

• 4WD
  • High challenge ‘rock crawling’
  • Adventure driving
  • Driving for pleasure
  • OHV
    • ATV (both ‘sport’ and utility)
    • ROV (‘side by sides’)
  • Motorcycle
    • Single track trail riding
    • Motorcross
    • Observed trials riding

It should be noted that NMOHVA membership also participates heavily in a variety of non-motorized recreation on public lands.  Statistics and studies show that motorized recreationists are highly likely to participate in a broad range of other outdoor activities.  As such, they are educated in, and respectful of, other forms of outdoor recreation.  While the GRRA provides a full range of other non-motorized activities, our interest is in maximizing the full potential of motorized recreational opportunities of the area.  It is the motorized recreation that makes the GRRA a truly unique resource to our members and the motorized community.

3.  The overriding existing problem within the GRRA that needs to be resolved before the motorized community’s vision of the Glade can be fulfilled is the BLM and other user groups needs to acknowledge and demonstrate acceptance of motorized recreation as a legitimate and sustainable use of the public recreation resource.  We are sick and tired of being portrayed as the villains by the selfish elitists who desire to establish their own form of recreation as the only allowable use.  NMOHVA and its members will insist that the BLM meet the stated management goal for the GRRA:

“Manage the recreation area to accommodate a large variety of recreational uses and outdoor recreational experiences.  Coordinate management efforts with multiple users and regulatory groups.”

This current review of the existing GRRA management strategy prior to the implementation of the objectives and actions of the current Resource Management Plan, the La Plata Travel Management Plan, or the Glade Run Trail System Recreation Area Management Plan serves as a stark indictment of catering to special interests that have publicly stated that they desire the removal of motorized recreation from the GRRA (http://www.velodeanimas.com/20…..ev1%20.doc).

4. The current FFO RMP provides adequate protection for the natural and cultural resources.  Why wouldn’t it?  What has changed significantly since the recent revision was completed, analyzed, and approved?

5. There is considerable confusion and dispute as to which documents are providing management direction for the GRRA.  While the FFO contends that the La Plata Travel Management Plan (LPTMP) is the current management document, the LPTMP document itself very clearly states otherwise. 

The LPTMP states, on page 4:

 “The La Plata Unit contains 145,066 acres, of which 73,380 are public lands. There are seven SDAs within the planning unit with a total acreage of 46, 404 acres of public land. That leaves 26, 976 acres of public land in the dispersed area for analysis in this planning document.”

This is no mere typo or small oversight.  The above statement sets the scope for the entire LPTMP under the Need for the Proposed Action.  The specific exclusion of the GRRA from the LPTMP is further described on page 5 LPTMP under RELATIONSHIP TO STATUES, REGULATIONS, POLICIES, PLANS OR OTHER ENVIRONMENTAL ANALYSES:

“Management of the Special Management Area, The Glade Run Recreation Area is addressed in the Glade Run Trail System Recreation Area Management Plan, 1996 and the Farmington RMP, 2003 which made changes to the boundary, among others.”

NMOHVA and its members have other concerns about the need for a review of the current management direction.  If the LPTMP is, indeed, the document that is providing direction for the GRRA, there are numerous items in the ‘Action Items’ of that document that have not yet been accomplished:

“Signs and Markers

 Objective: Identify the designated routes on-the-ground in a clear and consistent manner to provide easily understandable information to the public, and to facilitate compliance and enforcement of the route designations.

Information signs and/or kiosks will be placed at each main entry point onto BLM managed lands in the La Plata Travel Management Unit. These signs will include a map of the area showing designated routes and an explanation of the route marker system. Other signing may be incorporated at these locations to better inform the public as to reasoning, effects of non-compliance, etc.”

From the ‘Glade Signs Letter’ on the current FFO website, it appears that the area designation signs are finally being installed.  Are signs installed that clearly show the designated routes for motorized use?  In addition to providing the basis for enforcement, route signs also clearly identify to non-motorized users that they CAN EXPECT to find motorized use on that particular trail.  Setting accurate expectations via signage can go a long way to alleviating ‘conflict’ between users.

“Route Construction

Objective: Establish a system of trails, and routes to provide a range of recreational opportunities to the public.

• Construct an ATV trail network using historic trails, where feasible, and additional new trails to establish a system of stacked loops from the GRRA to the Colorado line.

• Re-align the mountain bike trail in the GRRA using International Mountain Bike Association guidelines for single-track trail construction.

• Any proposed new segments of trail will have all environmental documentation completed before any construction is undertaken.

• Any proposal to include existing trail as part of the BLM trail network will have all environmental documentation completed before final designation.

• Any new trail construction will use recognized principles of trail construction.”

Has any of the ATV trail network been constructed?  Has the FFO provided appropriate trail opportunities for this large user group to enjoy the quality recreational experience that the RMP and LPTMP promises?

“Monitoring

Objective: Identify actions, including timeframes, methods, and resource needs for environmental monitoring

Use counters to document visitation to various sections of the travel area. Counters would be left in place for a minimum of one year. Counter(s) for the GRRA would be left in place indefinitely.

Closed routes will be monitored for signs of use. Restored areas and routes will be monitored to assess the rate of recovery and effectiveness of the techniques used in the project.

The area signs and barriers will be monitored for condition and effectiveness.

Data collected will be used to assess the effectiveness of the plan and implementation strategy.

Modification of the plan will be considered if the goals and objectives are not being met.”

Monitoring the success of the implementation of the current existing plan and analysis of the resulting data must absolutely be the precursor to any revision of the existing plan.  The LPTMP says that “Data collected will be used to assess the effectiveness of the plan and the implementation strategy,” and “Modification of the plan will be considered if the goals and objectives are not being met.”  

Monitoring and data are supposed to drive potential changes to the plan, not complaints of non-documented conflicts from a small group of users who have publicly stated that they want to eliminate motorized recreation from sections of the GRRA.

“Enforcement

Objective: Identify actions, including timeframes, methods, and resource needs for compliance and enforcement related to route designations.  

• Emphasis will be placed on self-regulation by the user groups.

• Increased law enforcement patrol would be instituted if monitoring efforts show non-compliance with this plan.”

Have those “actions….methods, and resources” been identified?  Has monitoring showed non-compliance with the plan?  Have increased law enforcement patrols been instituted as the results of monitoring?  Are the same actions, methods, and resources being utilized to ensure equal compliance across all of the various motorized and non-motorized users?

Based on our review of the management documents, conversations with the FFO, and conversations with local NMOHVA members and others in the motorized community, NMOHVA is very concerned that the proposed review lacks a demonstrated, data-driven need  and that it is merely a vehicle for abolishing responsible OHV use before the current plan has even been implemented.

The current RMP includes “Provide opportunities for environmentally responsible recreation” within its GOALS FOR RESOURCE CONDITIONS AND RESOURCE USES (p. 2-1).  NMOHVA will support the FFO in its efforts to meet that goal.

In addition to the input above, we would like to add the following comments:

1. Why has a ‘singletrack  area’ been identified in Alternative B?  If resource concerns and/or public input indicate that this area needs a different management prescription, it can be accomplished under the existing management plan.  The area is already limited to designated routes only.  If the public desires singletrack routes in this area and the routes are compatible with the resources, designate some singletrack routes.  It would also make sense to designate some ATV routes (like the segment of proposed ATV route that the BLM announced that would cross this area). And the 4WD routes that the Cliffhangers 4WD club already marked and posted.  If the routes desired by the public create use conflict (note that the term and concept is ‘use conflict’ and not ‘user conflict’), a planning effort to determine which routes best meet the public need and resource management prescription would be in order.
2. If growth pressure from the City of Farmington is causing issues with the current management plan requirements, clearly state it as so.  If that is the case, it would make sense to look for alternate lands, further from the current eastern boundary of the GRRA, to designate for motorized recreation.  A well-designed and well-sited multiple mode trail system located between the La Plata highway and the main road up the Glade would likely serve the public needs and Farmington’s growth requirements for years to come.
3. We strongly support monitoring and the use of the resulting data as starting points for planning and plan revisions.  Unsubstantiated claims of “population increases in the region, explosive growth in the use of all kinds of off-highway vehicles, and the advances in vehicle technology generating increased social conflicts and resource impacts within the GRRA” is not a legitimate reason to throw out previous planning decisions that have never been implemented.

Sincerely,

Mark R. Werkmeister, P.E.

President, New Mexico Off Highway Vehicle Alliance

thanks rick keep us posted.  we need to make sure rock garden has all its paper work in order so we dont lose are rights to wheel there as well.

I am trying to get more info on all of our areas that we love to play in. I am trying to get a few more letters in. I will keep posting as we see them come through.

Rick

Post edited 6:18 pm – April 18, 2010 by 4x4tricks

New Mexico Gov. Bill Richardson calls on federal government to block riding opportunities

Post edited 9:24 pm – April 19, 2010 by 4x4tricks

Hey guys we have some great people working with us to help fix our situation.

Joanne sent this.

Since the rest of you guys don’t know him, I need to introduce Jim Cooper, (‘Coop’).

Coop and his wife Nora Hamilton are super-avid dirtbikers, and were both long time employees of the FS and BLM in various states.

Coop retired last year from the Grand Jct BLM, he was the transportation planner. He’s the guy that made the Bangs Canyon OHV area happen  (over the dead bodies of the local environmentalists who wanted to get it designated as a Wilderness Study Area).

Coop is a huge resource for what is and isn’t (#8216) kosher’ for the BLM to do.

I have no doubt he met Nora on the trail. Maybe he was broke down and she fixed his bike, she’s a certified Honda master mechanic.

Nora has been training us on how to deal with these NEPA documents. That’s what you’ll be facing with the Farmington BLM. they’re talking about doing an Environmental Assessment (EA) to modify the RMP. the EA must be done by NEPA regulations.  The good news is that NEPA is a wowerful weapon when we know how to use it.

For example, Coop just pointed out that they are trying to apply a Wilderness standard in a non-wilderness recreation area.  that’s wrong. Our job is to keep them honest and make them do the analysis right. This is how we’re going to help you save the OHV use in the glade.

Hey Jeremy this goes along with the information we talked about as far as when 667 brings large groups to play.

Here are some examples of Freedom of Information Act (FOIA) requests that we have sent in over the years.  You will note two of them to the SFNF are ‘chains’ of letters as the FS played ping-pong with the request.  A little persistence may be needed, especially if they have something to hide.  If they give you any grief in their response to your first request, we can help supply a response.  There are certain ‘magic’ words and phrases they are looking forward if they play hard ball but we know the ‘words’.  We have always ended up getting what we asked for….sometimes it just takes a while.

The Sandia Ranger District one is sort of an empty templ=te that you might want to use as a starting point and then tailor to your speccfic needs.

Here is the link to the BLM FOIA website:

http://ww=.blm.gov/wo/st/en/re…..quest.html< p>

And here is the actual address/contact for FOIA reques=s in NM:

New Mexico State Office
Eileen Vigil
P.O. Box 27115
Santa Fe, NM 87502-0115=br> 505-954-2129
Fax: 505-954-2131
NM_FOIA@BLM.GOV=/o>

Mark

 This will help us make sure that all is in order when we invite groups out. We may have a large group coming in from Albuquerque this summer. If there are some who are interested in seeing some hardcore wheelin I will contact you guys.

Thanks

Rick

BLM response:

Dear Mr. Cooper,

This email is a response to your phone call from 4-6-2010 requesting the 1996 Glade Run Trail System RAMP. Please contact our State Records Administrator Eileen Vigil to file a Freedom of Information Act request for this document so we can adequately track and process your request in a consistent time frame. Ms. Vigil can be reached at (505) 954-2129 or via email at Eileen_Vigil@blm.gov.

Janelle Alleman
Outdoor Recreation Specialist
Bureau of Land Management – Farmington
505-599-8944
Janelle_Alleman@blm.gov</font

Rick,

Here is a link to the thread I have started on Pirate. The letter generator is linked and alot of comments have already been sent asking for the comment period extension.

http://www.pirate4x4.com/forum…..p?t=921255