Document y4v1vJwv3NrJ9N2kZGD4XdvE

7/25/2017 DEPARTMENT OF THE INTERIOR Mail - CTVA comments for improvement of the BLM planning process Streamlining, BLM_WO <blm_wo_streamlining@blm.gov> CTVA comments for improvement of the BLM planning process 1 message CTVA Action Committee <ctva_action@q.com> To: BLM_WO_Streamlining@blm.gov Cc: ctva_action@q.com Sat, Jul 8, 2017 at 4:26 PM We have assembled the attached information and issues from our members and other motorized recreationists for the project record that if addressed would significantly improve the BLM planning process. We appreciate the opportunity to provide our comments for the Improvement of the BLM planning process. We enjoy riding our OHVs on primitive trails and roads on all multiple-use land managed by the Bureau of Land Management. BLM managed land provides a significant source of these OHV recreational opportunities. Thank you for considering our comments and suggestions. Sincerely, /s/ CTVA Action Committee on behalf of our 240 members and their families and friends Capital Trail Vehicle Association (CTVA)[1j P.O. Box 5295 Helena, MT 59604-5295 [1] CTVA is also a member of Montana Trail Vehicle Riders Association (mtvra.com), Blue Ribbon Coalition (sharetrails.org), and New Mexico Off highway Vehicle Alliance (nmohva.org),. Individual memberships in the American Motorcycle Association (ama-cycle.org), Citizens for Balanced Use (citizensforbalanceduse.com), Families for Outdoor Recreation (ffor.org), Montana 4X4 Association, Inc. (m4x4a.org), Montana Multiple Use Association (montanamua.org), Snowmobile Alliance of Western States (snowmobile-alliance.org), and United Four Wheel Drive Association (ufwda.org) https://mail.google.com/mail/b/Alk_JgZII-qmEpvgAsweZY-Dc-jtdzyfVxPUqdlGMx_S70c6D_ET/u/0/?ui=2& k=c1ad5b0200&jsver=HFKfDbXmXEw.en.&view=pt&cat=lnput%20-%20Public&search=cat&th=... 1/2 7/25/2017 DEPARTMENT OF THE INTERIOR Mail - CTVA comments for improvement of the BLM planning process CTVA Comments BLM Planning Process Improvements 7 4 2017.pdf -J 3549K https://mail.google.com/mail/b/Alk_JgZII-qmEpvgAsweZY-Dc-jtdzyfVxPUqdlGMx_S70c6D_ET/u/0/?ui=2& k=c1ad5b0200&jsver=HFKfDbXmXEw.en.&view=pt&cat=lnput%20-%20Public&search=cat&th=.. 2/2 CAPITAL TRAIL VEHICLE ASSOCIATION (CTVA) P.O. Bo, 5295 He l e n a f MT 59604-5295 July 4,2017 Mr. Michael Nedd Acting BLM Director 1849 C Street NW, Rm. 5665 Washington DC 20240 mnedd@blm.gov Re: Comments for the improvement of the BLM Planning Process Dear Mr. Nedd, We have assembled the following information and issues from our members and other motorized recreationists for the project record. We appreciate the opportunity to provide our comments for the Improvement of the BLM planning process. We enjoy riding our OHVs on primitive trails and roads on all multiple-use land managed by the Bureau of Land Management. BLM managed land provides a significant source of these OHV recreational opportunities. We are passionate about OHV recreation for the following reasons: njoyment and K ewards of UnV Kecre a t i o n Opportunity for a recreational experience for all types of people. Opportunity to strengthen family relationships. Opportunity to experience and respect the natural environment. Opportunity to participate in a healthy and enjoyable sport. Opportunity to experience a variety of opportunities and challenges. Camaraderie and exchange of experiences. We like to build and maintain trails for use by everyone. For the adventure of it. cknowledged Responsibilities of (VI oto r i z e cl Visitors Responsibility to respect and preserve the natural environment. We are practical environmentalists who believe in a reasonable balance between the protection of the natural environment and the human environment. Responsibility to respect all visitors. Responsibility to use vehicles in a proper manner and in designated places. Responsibility to work with land, resource, and recreation managers. We are committed to resolving issues through problem solving and not closures. Responsibility to educate the public on the responsible use of motorized vehicles on public lands. We are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Pa ge 1 of 7 Our position is that the existing system of OHV routes does not adequately meet the needs list above. The benefits to the public would greatly benefit from an enhanced system of OHV routes. We feel that we are representative of the needs of the majority of visitors who recreate on public lands but may not be organized with a collective voice to comment on their needs during the public input process. These independent multiple-use recreationists include visitors who use motorized routes for family outings and camping trips, weekend drives, mountain biking, sightseeing, exploring, picnicking, hiking, ranching, rock climbing, skiing, camping, hunting, RVs, shooting targets, timber harvesting, fishing, viewing wildlife, snowmobiling, accessing patented mining claims, and collecting firewood, natural foods, rocks, etc. Mountain bikers seem to prefer OHV trails because we clear and maintain them and they have a desirable surface for biking. Multiple-use visitors also include physically challenged visitors including the elderly and veterans who must use wheeled vehicles to visit public lands. All of these multiple-use visitors use roads and motorized trails for their recreational purposes and the decision must take into account motorized designations serve many recreation activities, not just recreational trail riding. We have observed that 97% of the visitors to this area are there to enjoy motorized access and motorized recreation. Our position is that the existing system of OHV routes does not adequately meet the needs listed above. The benefits to the public would greatly benefit from an enhanced system of OHV routes. The agency has a responsibility to adequately identify the needs of the silent majority and reasonably provide for those needs. As currently practiced the BLM planning process does not reasonably address these needs. A BLM Planning Process that promotes Pro-Recreation alternatives is viable and needed by the public. Motorized recreationists are the majority of the visitors to the project area. There is a great need for motorized access and OHV recreational opportunities. We support a process that promotes Pro-Recreation alternatives. We support a process that promotes Pro-Recreation alternatives that will provide additional motorized recreational opportunity in order to meet today's needs and the needs of tomorrow. The comments following this letter support our position in an extremely strong manner. We are looking forward to the development of modifications to the BLM planning process that will enact reasonable Pro-Recreation alternatives on all BLM managed lands. We are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Pa ge 2 of 7 Thank you for considering our comments. Sincerely, /s/ CTVA Action Committee on behalf of our 240 members and their families and friends Capital Trail Vehicle Association (CTVA)1 P.O. Box 5295 Helena, MT 59604-5295 Contacts: Doug Abelin, President Jody Loomis, VP Ken Salo at (406) 461-4818 at (406) 459-8114 at (406) 443-5559 dabelin@live.com iloomis@mt.net ctva action@q.com OUTLINE OF SIGNI FICANT ISSUES Significant overarching issues associated with the current BLM Planning Process include: 1. Lack of Reasonable Alternative to Address the Public's Need for More Motorized Access and Motorized Recreational Opportunities > The agency must adequately identify the needs of the silent majority including motorized recreationists and OHV recreationists and reasonably provide for those needs. > There are over 50 million OHV recreationists in the United States. > The analysis does not include an alternative that would provide a reasonable level of motorized trail opportunities to meet the existing and future needs of OHV recreationists. > The proposed management plan actions are based on out of date travel plans. Furthermore, the travel plans that the proposed action are based on did not adequately consider the needs of motorized recreationists at the time. Moreover, conditions and information has changed dramatically as documented in the following comments. 1 CTVA is also a member of Montana Trail Vehicle Riders Association (mtvra.com). Blue Ribbon Coalition (sliaretrails.org), and New Mexico Off highway Vehicle Alliance (mnohva.org),. Individual memberships in the American Motorcycle Association (ama-cycle.org). Citizens for Balanced Use (citizensforbalanceduse.com). Families for Outdoor Recreation (ffor.org), Montana 4X4 Association, Inc. (m4x4a.org), Montana Multiple Use Association (montanamua.org). Snowmobile Alliance of Western States (snowmobile-alliance.org), and United Four Wheel Drive Association (ufwda.org) 1Ne are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Page 3 of 7 2. Lack of a Reasonable Alternative to Address the Need for Motorized Access and Motorized Recreation for Youth > The analysis does not include any alternatives that would provide motorized opportunities to replace the closure of opportunities close to town. > Areas used extensively by youth were not given adequate consideration of the need. > Consideration for motorized trail riding opportunities for the youth has not been given a hard look. 3. Lack of a Reasonable Alternative to Address the Need for Motorized Access and Motorized Recreation for the Elderly, Handicapped, and Disabled > The analysis does not include any alternatives that would provide motorized opportunities to replace the closure of opportunities close to town. > Areas used extensively used by elderly, handicapped, disabled and veterans and were given adequate consideration of the public need. > The analysis does not include any alternatives that would provide motorized opportunities that adequately meet the needs of the elderly, disabled and veterans. > Consideration for motorized trail riding opportunities for the disabled, elderly, and veterans has not been given a hard look. 4. Fails to Adequately Address the Impacts On and Benefits of Motorized Recreation on the Human Environment > The public is losing a lifetime of motorized access and motorized recreational opportunities for reasons that are not significant when judged with a reasonable sense of magnitude. > The motorized closure trend on all public lands is destroying a culture based on motorized access and motorized recreation on our public lands. The analysis has not given this significant issue a hard look. > Our pursuit of happiness has been significantly impacted by all of the motorized closures. 5. Over-Represents the Public's Need for More Wilderness > Less than 3% of the visits to our public lands are for wilderness recreation and 97% of the visits are for multiple-use. > Management of our public lands must reflect the ratio of visitors and meet their needs in an equal manner. > Current wilderness is poorly managed and to create more only compounds the problem. > The current planning process is being used as a backdoor process to create defacto wilderness areas by closing motorized access and motorized recreation on lands designated for multiple-use. 6. Improperly Considers Roadless Areas > The proposed alternative effectively converts multiple-use lands to defacto wilderness lands which circumvents congressional law and the wilderness designation process. 7. Does Not Adequately Consider Cumulative Impact of All Motorized Closures > Motorized recreationists have been hammered by motorized closure after motorized closure in our public lands. > The analysis does not adequately disclose the amount of motorized access and motorized recreation that has been lost to public use since the 1960's. 1Ne are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Page 4 of 7 > Travel plan and other planning actions have closed 25 to 75% of the historic motorized routes and all cross-country opportunities. > The significant negative cumulative effect of all motorized closures on the public have not been adequately evaluated and mitigated in this proposal. > The significant negative cumulative effect of all motorized closures on the youth, disabled, elderly, and veterans has not been adequately evaluated and mitigated in this proposal. > The public has been squeezed into too small of an area with too few motorized routes. Every weekend when we talk to fellow motorized recreationists they ask us where they can go to ride trails and camp. > Our pursuit of happiness has been significantly impacted by all of the motorized closures. 8. Fails to Adequately Identify and Address the Imbalance of Trail Opportunity in the Project Area > There are far more miles of non-motorized trail in the project area and adjoining public lands. > The miles of non-motorized and motorized trail in the project area and adjoining public lands has not been adequately disclosed. > Miles of trail in wilderness areas and quality must be adequately disclosed. > Non-motorized opportunity must be compared to motorized opportunity including the miles of trails, costs and conditions, and number of users. > Every BLM and Forest Service planning action creates more non-motorized trail opportunities. 9. Does Not Provide for a Reasonable Level of Multiple Use > The lands in the project area are designated by congress for multiple-use. > The existing routes, mines, historic use, and current use demonstrate that the area does not qualify as wilderness and, therefore, should not be treated as wilderness. > Management for multiple-use best meets the overall needs of the public. > Congress recognized that management for multiple-use best meets the needs of the public and gave their direction in the law. > The agency is applying wilderness standards to lands designated for multiple-use. > Some visible use of the land for the good of the public is reasonable. > The proposed land use actions would effectively convert congressional designated multipleuse lands to defacto wilderness which circumvents congressional law and the wilderness designation process. > Public lands need to be made great again by restoring wide-ranging multiple-use management to all multiple use lands. 10. Unreasonable Use of Climate Change as a Reason to Eliminate Motorized Access and Motorized Recreation > Motorized recreation is not a significant factor. > If C02 is a significant factor, then wild fires are a significant impact. 11. Required to Provide Adequate Coordination with Local and State Government > Coordination with all adjoining counties is required. 12. Fails to Adequately Recognize and Address RS2477 Route Standing 1Ne are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Page 5 of 7 > The proposed action closes and obliterates many routes that have RS2477 standing and should be perpetuated for public motorized access and use as originally allowed by the law. 13. Arbitrary and Capricious Analysis and Decision-Making > There are no site specific studies and analysis of OHV recreation as required by the 3-State OHV record of decision. > Reasons are being used to close motorized opportunities that do not have data and studies to back them. > Studies that support OHV recreation or give an unbiased analysis are being ignored. > Impacts on fish and wildlife are being assumed (imagined) without adequate site specific data and studies. > Impacts on the natural environment are being assumed (imagined) without adequate site specific data and studies. 14. Fails to Adequately Address Justice Issues > The agency must adequately identify the needs of the silent majority including motorized recreationists and OHV recreationists and reasonably provide for those needs. > The proposed action includes many non-motorized trail opportunities. > The proposed action does not include any OHV trail opportunities. > The USDA presents itself as "USDA is an equal opportunity provider, employer and lender." > Public lands in the project area have considerably many more miles non-motorized trails than motorized trails. > There is not an equal opportunity in miles of trail and quality of experience for ATV recreationists. > There is not an equal opportunity in miles of trail and quality of experience for motorcycle single track recreationists. > The inter-disciplinary team does not include ATV, motorcycle single track, UTV and fullsize 4x4 enthusiasts. > Motorized recreationists are the only group to lose in every BLM and Forest Service planning action and are bearing a disproportionate share of the negative consequences. > The Agency is making decisions that ignore the overall needs of the public for motorized access and motorized recreation, equal opportunity requirements, and congressionally directed management for multiple-uses. > Motorized recreationists cooperated with the travel management rule believing that travel management planning would be reasonable. In reality travel management planning has been a massive motorized closure process and our trust has not been honored. > Motorized had been marginalized since the 1960's without adequate disclosure and analysis of the significant negative impacts on the public and the needs of the public for motorized access and recreation. > The lack of adequate and full disclosure of significant impacts on motorized recreationists and the lack of adequate and meaningful consideration of the needs of motorized recreationists including OHV recreationists by the agency must stop with this action. > In the past OHV recreationists trusted the agency with the belief that they would look after our needs and we agreed to cooperate and be managed based on that belief. However, in return our needs were ignored and OHV recreationists were rewarded with excessive motorized closures. It is time to compensate and mitigate for this injustice. 1Ne are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Page 6 of 7 15. Overstates the Impact of Motorized Access and Motorized Recreation on Fish and Wildlife > The analysis has not adequately considered data and studies that supports an unbiased and a balanced view of how motorized recreation impacts the natural environment. > The analysis does not have adequate site specific data and studies as required by the 3-State OHV ROD to justify motorized closures. > Impacts from all users groups and natural impacts must be adequately compared to demonstrate a true sense of magnitude for impacts. > Alternatives to wholesale motorized closures that would mitigate fish and wildlife concerns were not given a hard look. 16. Overstates the Impact of Motorized Access and Motorized Recreation on the Natural Environment > The analysis has not adequately considered data and studies that supports an unbiased and a balanced view of how motorized recreation impacts the natural environment. > The analysis does not have adequate site specific data and studies as required by the 3-State OHV ROD to justify motorized closures. > Impacts from all users groups and natural impacts must be adequately compared to demonstrate a true sense of magnitude for impacts. > Alternatives to wholesale motorized closures that would mitigate natural environment concerns were not given a hard look. 17. Motorized References need to be adequately considered > The analysis has not adequately considered information that supports the need and value of motorized recreation. 18. Maintenance, Funding and Gas Tax Issues > The analysis has not adequately considered information that identifies significant issues surrounding maintenance, funding and gas tax issues. > If motorized is removed, then motorized funds should not be used in the area. > If motorized is removed, then motorized funds used previously in the area should be returned for use on motorized projects. 1Ne are a locally supported association whose purpose is to preserve trails for all recreationists through responsible environmental protection and education. Page 7 of 7