Invest 3 Hours to Save Access to Your Public Lands

UPLA, BlueRibbon Coalition, SLOREX, and At Your Leisure are cosponsoring a Workshop to be more effective in preserving access to our Public Lands. We need you to invest 3 hours to learn how you can make a difference.

Even though motorized OHV has always had a strong relationship with BLM and Forest Service staff, and been quick to volunteer to complete projects on public lands, we have been at a disadvantage in Travel Management Planning because we have not been as effectively engaged as our opponents. If we fail to improve our strategies,  these closures will expand to affect every outdoor recreationist. Equestrians, campers, rock climbers, base jumpers, snowmobilers, hunters, fishermen, boaters, and mountain bikers will all be affected as more public lands are designated as wilderness, areas with wilderness character, or Areas of Critical Environmental Concern (ACEC) The elimination of roads and dispersed camping areas will limit access to staging and parking areas, making your favorite areas further and further from accessible roads. Even those clamoring for more wilderness experiences will have much longer treks to get to their favorite areas, a weekend trip now will become a week long trip in the future. Cyclists, rock climbers and canyoneers are currently facing rulings that propose elimination of e-bikes and fixed anchors in National Parks. As remote areas are more limited with accessibility, injuries and rescue attempts will increase and be even more expensive, resulting in further restrictions or closure.

In Utah, there are 25 Travel Management Areas on BLM’s calendar for development or reevaluation of current plans. More are in store for Forest Service and National Monuments.

The importance of understanding the NEPA process, and being able to proactively and effectively participate in the process has never been greater, and we must become smarter and more effective at working together to influence the NEPA process.

Utah Public Lands Alliance, BlueRibbon Coalition, Salt Lake Off Road Expo, and At Your Leisure are cosponsoring a workshop on February 29 to help us all understand how we can make a difference. Our workshop presenter will be Tammy Pike, a retired BLM Travel Management Planner, who is a renowned expert in the NEPA process. Her experience spans 30 years, the last 25 focused on trails, off highway vehicles and travel management planning while both conserving our natural resources AND providing the best recreational opportunities for the public to enjoy now and in the future. She has won countless awards from not only BLM, but the Forest Service, Arizona State Land Department, and many OHV and other recreational groups.  She earned a National Customer Service Award from BLM, one of the highest possible commendations.

Tammy will help us develop a strategy to communicate clearly in the NEPA process at all levels to get our views considered in the process. We believe she is the best person to teach us how to restore balance to a system that has been heavily weighted against us. Making comments is a critical step in influencing final outcomes, and she will teach us how to make comments that are both substantive and effective. Questions and answers are an invaluable part of any discussion, because it allows you to ask your questions  and get answers from an expert. We have a full hour at the end of the program allocated just to your questions and answers where she will be joined by panelists Ben Burr and Simone Griffen from BlueRibbon Coalition, as well as Rose Winn, our new UPLA Public Policy Consultant.

For us to change the tide, we must all come together, and we must start acting as Big As We Are. If you really care about making a difference in keeping our lands accessible, make plans to attend this workshop the day prior to SLOREX opening.

What:            NEPA Comments Training Workshop

Where:          Mountain America Expo Center, 9575 State Street, Sandy UT

When:           February 29 1:30 -4:30

Space is limited, RSVP and submit questions and topics you would like included in the presentation.

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BLM Rule Proposal May Devastate OHV Use on Public Lands

The BLM is considering a rule that could devastate our access to public lands. Watch this short video from Ben Burr at BlueRibbon Coalition to learn why you should be concerned.

The BLM is accepting public comment until June 20, 2023 on a proposal to adopt the BLM Conservation and Landscape Healtlh Rule BLM-2023-0001-0001 (Click to see the entire Highlighted Rule) which could lead to massive restrictions for public land access across all lands managed by the Bureau of Land Management. Following is an article that explains the basis for our concern, and will be used by UPLA as a starting point for comments to be submitted.

I enjoy accessing and recreating on public lands. I believe BLM managed lands are crucial to the health and well being of our country. Access for many different user groups is crucial. I am writing to provide feedback on the proposed conservation and landscape health proposed BLM rule. I do not support the rule as it stands and believe it will be detrimental to public land across the United States. I think FLPMA, as it stands does a sufficient job in directing management of our public lands and should not be altered with the proposed changes.

Conservation is already rooted heavily in land management, and does not need to have additional complex levels of rules that would benefit wealthy organizations rather than the US Citizen. The rule establishing that “conservation” be defined to include both protection and restoration is especially troubling.

There should not be a stated objective of BLM to prioritize designating new ACEC’s, which are often used to restrict public access. There are already substantial methods in place such as congressionally designated Wilderness and Wilderness Study Areas which restrict land management uses, and there should not be more prioritization for designations of land that could harm use such as ACEC’s.

The broad use of the terms “intact, native habitats” and “degraded landscapes” are troubling, vague, and unclear. Theoretically, if a person ever walked on land and left a footprint, that land could be defined as a “degraded landscape” or one that is no longer intact or native. These terms are used in key recitals in the document, without any definition of what they actually mean. Page 10 states “The proposed rule would define the term “intact landscape” to guide the BLM with implementing direction. The proposed rule (§6102.1) would require the BLM to identify intact landscapes on public lands, manage certain landscapes to protect their intactness, and pursue strategies to protect and connect intact landscapes.” Although the rule states that BLM would define the term, there is no definition present. The same is true with the terms “landscape” and “intact landscapes” on Page 11. There are many other instances of terms that are not clearly defined in the document, which means the definitions and intent of the rules will have to defined by the courts and the teams with the best lawyers.  

The proposed conservation leases make it possible for entities to essentially buy off our public lands for their own selfish purposes. The BLM should not be selling the land through these leases to the highest bidder restricting all other forms of use on public lands that benefit our nation in various ways. Only the best funded entities will have a chance to qualify and buy these leases, again removing the majority of users from participating.

We are extremely concerned that conservation extremist groups, such as Sierra Club and SUWA, would have the financial resources to bid on these leases to “restore” the land back to it’s natural condition, and to develop their own plan to “mitigate” the conservation activities by restricting access. Although the term of the leases is limited to 10 years, there are extensions allowed until the outcome is achieved. Based on prior experience, this would include removing roads and dispersed camping, which is the path to having the area declared as a Wilderness area resulting in even broader access issues.

It is also likely that this rule will be utilized as a tool for socioeconomic class discrimination. It is already common for conservation easements to be used by wealthy landowners in gateway Western communities to prevent development and turn these communities into enclaves for billionaires. The subject of this as a tool for wealthy or prospective landowners has even reached media in the Yellowstone Series. Conservation leases are used as a tool to keep the middle classes and working classes away from what eventually become private nature preserves for the wealthy. To spread this toxic outcome across the hundreds of millions of acres of BLM land is completely misguided.

The adoption of Conservation Leases should be stricken completely from the proposed rule.

Conservation is already used to restrict, regulate and deny access to public lands. By codifying conservation as a use, environmental groups will be given even more power to lock out the public from public lands. Lands are already sufficiently being conserved by various laws and Executive Orders such as NEPA, Clean Air Act, Clean Waters Act, Antiquities Act, Endangered Species and many many more. I do not believe the proposed rule is warranted or necessary. In order to gain better compliance, less complexity is needed in rulemaking, not more.

The rules requiring decisions be evaluated based on complex “high-quality science” removes the ability for all but the most well funded organizations to submit their “evidence.” Science is a study, and is generally composed of all different views of a subject. By codifying this as a requirement, it eliminates lesser funded organizations and citizens from making substantive comments that may represent a less restrictive approach to conservation. It has long been stated that if the consequences are high enough, you can always find an expert to testify on your behalf. This rule is simply not needed and will again remove the ability for users to participate in substantive comments.

Economic effects must be considered and analyzed. BLM needs to more fully analyze the effects that would result from the proposed rule. Recreation is a huge economic driver across BLM managed lands as well as other uses such as grazing and mining. These changes could greatly affect access in general for all users on public lands and that analysis and data needs to be available to the public to submit thoughtful comments. The BLM also needs to fully understand the depth of the effects from the proposed rule.

Every time motorized routes are closed, people with disabilities that require the use of motorized means to access public lands are barred from those areas forever. In the past, there has been little resource available to people with disabilities because the American with Disabilities Act does not require public land management agencies to consider disproportionate effects on the disabled community, requiring only that there is equality of opportunity. This has resulted in the BLM’s historical failure to give any real impact to the effects on the disabled community.

On his first day in office, President Biden issued an “Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government” This changed the equation, now requiring focus on equality of outcome rather than the prior equality of opportunity. Allowing closures of public lands through any of the methods outlined in the Rule will further the longstanding discrimination towards American with disabilities within federal land management agencies. The entire rule should be eliminated from consideration entirely because it will adversely impact disabled users in their outcome of enjoying public lands.

It is also likely that this rule will be utilized as a tool for socioeconomic class discrimination. It is already common for conservation easements to be used by wealthy landowners in gateway Western communities to prevent development and turn these communities into enclaves for billionaires. The subject of this as a tool for wealthy or prospective landowners has even reached media in the hit television series “Yellowstone”. Conservation leases can be used as a tool to keep the middle classes and working classes away from what eventually become private nature preserves for the wealthy. To spread this toxic outcome across the hundreds of millions of acres of BLM land is completely misguided.

The Federal Government already has enough protections available to protect our available resources, reject this Rule in it’s entirety. 

Please submit your comments to prevent this rule from taking place with these sweeping changes. We encourage you to submit your detailed comments in either of 2 ways.

  1. Use the BlueRibbon Coalition’s Action Alert. Please edit to include your personal concerns in your comments.
  2. Federal eRulemaking Portal: Click on this link to take you directly to the Comments page for this action. If this link does not work, go to https://www.regulations.gov. In the Searchbox, enter “1004-AE-92” and click
    the “Search” button. Follow the instructions at this website.

Thanks in advance for your support in taking action against this proposal.

Remember,

Together We Can Win,
But We Can’t Do It Without You

Loren Campbell
President

Learn How You Can Help Us Achieve our Mission at http://www.UtahPLA.com/help




BLM Warner Valley Land Exchange Resolution

Thank You For Helping

Save Sand Mountain!

When we come together, we can accomplish great things. The proposed BLM Sand Mountain Land Exchange posed a serious threat to both the OHV community and Dispersed Campers that used Warner Valley. When we raised a Call to Action to the Community, nearly a thousand of you turned up at the St George Library for BLM’s scoping meeting with only 4 days notice. Hundreds of you submitted scoping comments, including some of the most substantive comments I’ve ever seen. Your response set the stage for how committed the OHV community was in protecting Sand Mountain and helped us immensely in negotiating with BLM, Washington County Water Conservancy District (DISTRICT), and the City of Washington.

The team that negotiated on behalf of the OHV community consisted of Jeff Bieber from DRATS, Ben Burr from BlueRibbon Coalition, Milt Thompson from Dixie 4 Wheel Drive, Steve Jacobs from Tri State ATV, Steve Maxfield and Casey Lofthouse. I had the pleasure of leading the team as the representative from Utah Public Lands Alliance. Together, we spent many hours, weeks, and months strategizing and meeting with 4 different government agencies to find a mutually agreeable solution.

I must recognize the leaders of the agencies for taking the time and effort to understand our needs and respond to them. Jason West, BLM Field Manager was always quick to respond to our inquiries and set up our initial meetings with the DISTRICT. Mayor Nanette Billings from the City of Hurricane setup our first meeting with the City of Washington, Mayor Kress Steheli. General Manager Zach Renstrom and Attorney Morgan Drake from the DISTRICT spent many hours working with us and refining the agreement and working document. Both Mayor Steheli and Jason West went on field trips with Jeff Bieber and I to tour to affected parts of Sand Mountain, and to show them the work the OHV Community has done on Sand Mountain. Morgan Drake and Zach Renstrom organized a field trip in UTVs for DISTRICT staff and Board members to view the mountain for themselves. They got a first hand experience of why we’re so proud and protective.

Last night, the DISTRICT Board passed a Resolution unanimously that identified the protections the OHV Community needed, as well as limited protection for Dispersed Camping until we can find another option. The Resolution, Map and Press Release can be seen here.

As stated in the Board Meeting last night by Morgan Drake and Mayor Kress Steheli from the City of Washington, this has been an excellent example of how difficult land use decisions can best be worked out when everyone sits at the table and work together to find a solution.  Is it a solution that everybody got everything they wanted? No, that only happens in fairy tales. Is the work over? No, there’s still work to be done in the coming months-but this was a very important milestone for us because BLM will insert these conditions into the terms of the Land Exchange if it is approved.

We still have several review processes to complete with the NEPA process, and we’ll be asking you to reengage as those came up. But a sincere thank you to everyone that participated in this effort for a successful outcome.

Remember this for the future…

Together We Can Win,

But We Can’t Do It Without You

Gratefully and with Sincere Appreciation,

Loren Campbell
President
Utah Public Lands Alliance

Learn How You Can Help Us Achieve Our Mission




BLM Sand Mountain Land Exchange Update and Scoping Comments Apr 16

The proposed BLM land exchange would affect a large portion of our West Rim area trails and Warner Valley disbursed camping, so it is no surprise that it has generated a lot of interest. As with anything important, there have also been a lot of rumors that we’ve found not to be true, so this article should tell you the facts and where we’re at in the process. At the end of the article are UPLA’s Draft Comments.

Who is Involved in the Exchange? There are 4 parties directly involved in the Exchange.

  • His Family Matters (HFM)-Representing Alan Carter who has 89 acres near Green Springs, which is a private in holding located in the Desert Tortoise Conservation Area. This land exchange was structured so that His Family Matters would only received cash in the transaction, and would not receive any of the exchanged land.
  • Washington County Water Conservation District-(WCWCD) would be the recipient of the 1050 acres from the BLM, where they are proposing to build a 750 acre reservoir.
  • Washington County is acting as the Facilitator of the transaction to coordinate between all the different parties. The County has also promised to make up any cash deficit needed to complete the exchange.
  • Bureau of Land Management (BLM) would be exchanging the 89 acres for the 1050 acres based on appraisals.

Who is on the Steering Committee negotiating for OHV and Camping Interests? We formed a diverse group of OHV leaders to work on protecting our interests

  • Loren Campbell, UPLA
  • Jeff Bieber, DRATS
  • Milt Thompson, Dixie 4 Wheel Drive
  • Rich Klein, Trail Hero
  • Ben Burr-BlueRibbon Coalition
  • Casey Lofthouse, Casey’s Off Road
  • Steve Jacobs, Tri State ATV
  • Steve Maxfield, MX2

The Steering Committee began meeting in mid February to strategize and conduct phone, in person, online, and field trips with BLM, WCWCD, City of Washington, and City of Hurricane.

Key Objectives:

  • Preserve Open OHV Access for all the land above the 2980’ elevation level on the Eastern side to the BLM border
  • Maintain OHV access from the Washington Dam area to the trail system above, either via the current Ridgeline Trail or another trail that Washington County Water Conservancy would construct
  • Prohibit Zoning and Building on top of the ridge, except for necessary infrastructure for the reservoir.
  • Allow construction of a minimum 3 acre staging area in the Washington Dam Area, including installation of a restroom
  • Maintain or relocate the current restroom on Pipeline Road
  • Maintain access to the above facilities without any fees for use
  • Disbursed camping in Warner Valley often attracts up to 300 campers that have enjoyed camping there for years without any charges. Develop a plan that would allow camping and Open OHV use to continue in the Valley until Dam construction begins, and when construction begins, offer alternatives for reasonable alternatives for campers displaced by the Land Exchange.

To date, we obtained verbal agreements that satisfy the first 6, we are still working on the disbursed camping. We also have some other items we will work on going forward such as the maintenance of the restrooms, and who will be the manager(s) for the new recreation areas. BLM has also agreed to incorporate any agreements we come to in the Alternatives if the Land Exchange proceeds. We also now have verbal consensus from both State Parks and the City of Washington that they agree with our objectives.

What we are trying to achieve? We are working to achieve an agreement that would have legal protections for the above items in perpetuity, and provide a unified approach to finding solutions. Although we have not directly encountered any Environmental Groups protest, we believe they will be forthcoming in the process at some point.

What lies ahead After the current scoping comment period ends on April 19, BLM will begin work on a Draft EA, which will also have a comment period. Followed by the Final EA document that will also have a comment period. It’s a long process, but we’ll stay engaged with you throughout to keep you updated and informed. Be sure to like us on social media and subscribe to our newsletters to be sure you get the information.

Now- Get your Comments Sent In By Wednesday April 19, here’s some more details on thought starters….

Email Comments to blm_ut_sgfo_comments@blm.gov with a copy to StopSandMtnSale@Gmail.com

 

UPLA Draft Scoping Comments Guide April 16, 2023

Utah Public Lands Alliance is a 501c3 organization whose mission is to protect access to public lands for all users. The proposed land exchange poses serious threats to many of our user groups, including OHV users of all types, campers, equestrian, and users that just want to play on the beautiful red rocks of Warner Valley. Utah has long been popular worldwide for OHV and other outdoor recreation opportunities. Moab has been said to be Mecca for as long as I’ve been off roading, but Sand Mountain has become the alternative of choice because of many factors. Sand Mountain is unique because of the Open OHV designation which allows development of trails to the already extensive trail network. This ability to add new trails has helped us to accommodate both the increased numbers of visitors, as well as the ever increasing abilities of vehicles and drivers. Combined with Washington County’s fantastic weather, supporting businesses, and OHV friendly local governments, and it is easy to understand why the Sand Mountain OHV area is now becoming the location of choice for not only users, but also a rapidly growing number of events that bring even more people and income to the local economy.

Not only do our users recreate on the land, but Utah Public Lands Alliance, as well as many other groups such as Desert Roads and Trails Society, Tri State ATV Club, and Ride Utah spend many, many weeks each year on the mountain to protect, preserve, and develop the resources of “our Mountain.” We accept and embrace our responsibility as practical environmentalists that believe in a reasonable balance between the protection of the natural environment and the human environment. Not only do we volunteer our time and efforts, we also bring money to complete projects. In the last year along, we have funded the addition of a new composting toilet on West Rim, as well as completing the 5 Acre Waddy’s Corral Staging Area. Our work is not done though, in the next year we are planning to pave the Water Tank Road from the highway along with the addition of another restroom at Waddy’s Corral. Next will be the creation of a new staging area at the Green Gate to get people quickly away from the interchange, and following that another staging area near the Hurricane Airport for that new area of trails.

The OHV sport has literally exploded in the last few years, and with rapid growth, there will come new challenges. I am proud to say that on Sand Mountain, we recognize issues often before BLM or Sand Mountain is aware, and use our skills as problem solvers to work with Land Managers to find a solution, find the funding when necessary, and mitigate the problem.

We are strong defenders of the use and trail system that will be affected by this proposed Exchange, and we appreciate the opportunity to offer our following comments with respect to the Land Exchange that will help you develop a more comprehensive Environmental Analysis leading to expanded pro recreation alternatives.

It’s important that UPLA does not oppose the exchange for the land to be used for a reservoir. We view the reservoir recreation opportunities as just another way to enjoy the area. We accept the loss of trails in Warner Valley that are necessary for the construction of a reservoir, but we want to clearly establish the following goals as follows:

  • Preserve Open OHV Access for all the land above the 2980’ elevation level on the Eastern side to the BLM border
  • Maintain OHV access from the Washington Dam area to the trail system above, either via the current Ridgeline Trail or another trail that Washington County Water Conservancy would construct
  • Prohibit Zoning and Building on top of the ridge, except for necessary infrastructure for the reservoir.
  • Allow construction of a minimum 3 acre staging area in the Washington Dam Area, including installation of a restroom
  • Maintain or relocate the current restroom on Pipeline Road
  • Maintain access to the above facilities without any fees for use
  • Disbursed camping in Warner Valley often attracts up to 300 campers that have enjoyed camping there for years without any charges. Develop a plan that would allow camping and Open OHV use to continue in the Valley until Dam construction begins, and when construction begins, offer alternatives for reasonable alternatives for campers displaced by the Land Exchange.

Please also answer the following questions in your Environmental Analysis of the Land Exchange Proposal:

  1. Provide specific information about the proposed action, including its location, purpose and need, and potential environmental impacts.
    1. We understand the purpose of the reservoir use, but what is the purpose of the large acquisition east and north of the reservoir?
    2. We asked the Water Conservancy District and City of Washington what they plan to use the land for, and their response has been they have no plans or it’s too early to have thought about it. BLM should demand a clear direction from WCWCD and the City of Washington as to their involvement and precise plans for the future, including alternatives if the reservoir is built or not built.
    3. My understanding is that the exchange has only the purpose of providing for the acquisition of the designated critical habitat for the Mojave desert tortoise. Although there has been much talk about the reservoir, it is my understanding that the proposal for the reservoir is only speculative, and it is not even mentioned in your public scoping notice. It is also my understanding that the BLM has determined in their EA that all 1047 acres of BLM land proposed for the exchange is also suitable for the desert tortoise population. Simple math would indicate that giving up 1047 acres of land proposed to be speculatively used for a reservoir in exchange for 89 acres would result in a net loss of 960 acres of tortoise habitat, which might actually hurt the desert tortoise population. This might be a simplistic view,  explain the science behind this exchange on how much the net effect of this exchange will be on the desert tortoise population.
    4. How specifically will it affect visitors and their economic impact to the region?
    5. Adjoining lands that are managed by different agencies often cause conflicts because of differences in rules governing that use, and law enforcement.
    6. Dr. Mark Rappaport at the University of Utah reported in 2021 that Utah now has the highest rate of mental health disorders (26.86% or 599,000 of adults) of any other state, as well as Lifetime Depression of 23.1% versus 18.8% for the United States. Not only adults are affected, suicides by youth 10-24 is the leading cause of death in Utah, and for ages 25-44 it is the second leading cause of death. Outdoor recreation has been cited as one of the best environmental solutions to stress and mental health.  One of the basics in OHV is learning how to share our trails and resources responsibly, an important lesson for everyone when so much effort is expended on efforts to divide us from each other. What studies have you done on the impact that restriction of use of the land, especially if the reservoir is not built, would have on reduced opportunities for recreation, the quality of life, and the human environment?
    7. Much of the increase in OHV recreation has come from UTV/ATV users that need staging areas to unload and park their machines. Where do they go if Washington Dam is closed? What will you need to do to prevent users from parking in unsafe or unauthorized areas? What law enforcement agency will be responsible for this?
    8. The area between Pipeline Road and West Rim is becoming increasingly popular with dirt bike users. What will be the impact on them if this is eliminated?
    9.  What will be the Visual Resource Impacts of the exchange. Currently, most of Sand Mountain is classified as Class 2, but it appears from Map 2.14 in the BLM St George Field Office 1999 Recreation Management Plan that the West Rim is classified as Class 3. How will you ensure that the basic characteristics and visual appearance will be maintained if the exchange is approved?
    10. Describe what the impacts and visual resources will be if the Land Exchange is approved and:
      1. The Dam and Reservoir are built
      2. If the Dam and Reservoir are not built

What provisions can BLM build into the Exchange Agreement that acceptable uses of the exchanged lands will be as indicated?

    1. In the Agreement to Initiate a Land Exchange, BLM agreed not to encumber the land without first notifying WCWCD and giving them an opportunity to comment. This will affect all future  the consent of WCWCD. This affects all Special Recreation Permits to limit their term from the standard 10 year period to only 2 years. This further burdens the applicants and the BLM in the processing and review of new permits. What steps can BLM take to ensure this burden is not passed on to Applicants in extra paperwork, expense, and potential delays?
  1. Identify any alternatives that the BLM should consider, including no action, and explain why they would be preferable or less impactful.
    1. What other locations have been considered for the exchange located north and east of the reservoir? Explain why you came to the conclusion that this is the best of those alternatives.
    2. I have been told the reason for the expansion of 169 acres to the original proposed exchange was because a survey had already been done. How much would it actually cost to survey a better defined area?
    3. There is another section of BLM land between the Southern border of the Proposed Exchange and Foremaster Holdings Private Property. This approximately 90 acres of land would be better suited for the exchange than the Northeast corner, and it would also be a better solution for recreation development on the southern edge of the proposed reservoir. It would also provide easier access to this area from Warner Valley Road, right off Highway 7. Have you considered replacing our area of concern with land to the south of the proposed reservoir location, where WCWCD is considering for recreation already.
    4. I understand that the exchange must be based on value for value appraisals, and that the Private Parcel must be valued as if it was not encumbered by the Desert Tortoise Habitat restriction. Generally, when property is being valued, it is valued several ways, such as “As Is”, “Highest and Best Use”, and “For Intended Purpose” Please explain what criteria will be used for valuing the 1047 acres of land, and without a clear intended purpose of the land from WCWCD, please explain how you arrive at appraisal values.
    5. What alternatives have been considered that eliminate portions of the 1047 acres?.
    6. What other alternatives have you considered for acquiring the 89 acre Non Federal parcel?. Did you apply for a grant from the Land and Water Conservation Fund? What were the results of that application?
    7. If no action is recommended as an alternative, please provide precise details what that means.
  2. Highlight any potential significant impacts that may result from the proposed action and suggest ways to mitigate or avoid them.
    1. Without knowing what the new use will be, how will you clearly analyze potential impacts or mitigations.
    2. How do you propose to resolve impacts such as user conflicts between OHV and development, noise or traffic concerns.
    3. Although WCWCD does not want to manage the area for recreation, they indicated that their intent is that recreation would be allowed and managed by another agency. What types of commitments would bind these other managers to abide by the terms of any agreement with the OHV/Disbursed camping communities?
    4. Although a State Park, California’s Oceano Dunes OHV users have been attacked by new residents building communities adjacent to the Dunes because of User Conflicts. What consideration have you given that the transfer could lead to even further losses if undetermined future users complain about current OHV use such as noise, traffic, or blowing sand.
    5. Open OHV areas like Sand Hollow are rare. OHV use has been increasing dramatically, yet trail closures are also increasing. This is leading us to a serious future conflict. Please provide your analysis of the land currently available, what it was  5 years ago, and any projections in the next 5 years in Utah for each of the following designations:
      1. Open OHV use
      2. Open for Use on Existing Roads and Trails
      3. Open for Use on Designated Roads and Trails
      4. Closed to OHV Use
      5. Change in OHV Registration Data Over the same period
  3. Provide relevant scientific data, studies, or other sources of information to support the comments.
    1. Any reduction in Warner Valley that is currently used for disbursed camping will be both a huge loss and a problem that needs to be solved. On busy weekends, over 300 rigs are camped throughout Warner Valley, with most near the Highway, but many going down the valley for more secluded camping. The Dyrt published their 2022 Camping Report, which revealed several important facts:
      1. 1 in 5 Americans went camping in 2021
      2. First time campers are increasing more diverse, with over 40% of first time campers self identifying  as Black, Indigenous, and People of Color-that is up from on 23.8% in 2018.
      3. It was 3x harder to book a campground in 2021 than pre-pandemic, with campers in the West finding the highest percentage (48%) of fully booked campgrounds than any other region in the West.
      4. People that sought disbursed camping doubled in 2021 versus 2020. OHV users overwhelmingly want disbursed camping for ease of access with trailers, ability to camp surrounded by friends, being more isolated, and lower costs, especially for longer trips.

Please identify alternatives, both short and long term, for how you will accommodate any potential loss in disbursed camping.

  1. If the “disbursed” camping is eliminated at Washington Dam, law enforcement issues may rise with those people desiring free camping will arise in other areas, i.e. our Waddy’s Corral staging area may have people trying to camp there, especially after we pave the road to it. Last weekend there were probably 250-300 people camping in the valley. Hurricane Area RV parks are expensive, starting around $75 and going up to $158 per night for the new Jellystone Park. Sand Hollow State Park RV camping is often full. Most commercial campgrounds have limited hours for check in and checkout, eliminating that day for use if they must check out in the morning and cannot check in until the afternoon, this particularly causes difficulty for weekend users, who will lose 1/3 of their weekend because of check in/check out times, or park their RV’s somewhere unauthorized leading to more problems. Another reason that people often prefer disbursed camping is they want more space, not being to restricted to only being 15’ from the next rig and only having the side of their rig as a view. During the pandemic, users flocked to disbursed camping to gain social distancing. Where are the people that have enjoyed free camping for many years in Warner Valley going to go, or will they be unable to continue the recreation they have enjoyed? This seems that it may severely impact low income communities. Provide your analysis of this problem, and the mitigations to solve it.
    1. Oceano Dunes is a great example of how user conflicts were created that led to further losses to OHV. In many communities, airports have come under attack from new communities built around them that complain about the noise, ultimately resulting in the closure of 378 airports since 1990, almost 7% of the total. Explain what measures you are taking to ensure that OHV does not suffer a similar fate.
    2. Explain how you quantify the value of land used for recreation, including significant factors that influence that valuation?
    3. One of the strong mental health benefits that people get from OHV use is good balance; challenge vs comfort and self control. A Berkeley study published an interesting article on how varying levels of control were often the best balance for happiness. Fear and uncertainty are also both some of the strongest motivators of human behavior. How will the various options being considered affect people’s happiness?
    4. OHV Users enjoy all of the following rewards:
      1. Opportunity for a recreational experience for all types of people.
      2. Opportunity to strengthen family relationships.
      3. Opportunity to experience and respect the natural environment.
      4. Opportunity to participate in a healthy and enjoyable sport.
      5. Opportunity for relief from the pandemic.
      6. Opportunity to experience a variety of opportunities and challenges.
      7. Camaraderie and exchange of experiences.
      8. We like to build and maintain trails for use by everyone.
      9. We enjoy observing flora, fauna, and landscapes.
      10. For the adventure and “flow” of it.

The agency’s evaluation of the human environment should include the significant value of flow that is provided by motorized recreation. OHV riding is our time to relax and find the “flow”. “Flow is a state of mind in which a person becomes fully immersed in an activity. Positive psychologist Mihály Csíkszentmihályi describes flow as a state of complete immersion in an activity. Being immersed can be defined as a state of focus in which a person is completely absorbed and engrossed in their work.” It often occurs when you are doing something that you enjoy and in which you are quite skilled. “This state is often associated with the creative arts such as painting, drawing, or writing. However, it can also occur while engaging in a sport, such as skiing, tennis, soccer, dancing, or running.” OHV riding that provides a balance of skill versus challenge allows one to get so focused that time stops and anxieties, worries, apathy, and boredom disappear. https://www.verywellmind.com/what-is-flow-2794768 https://youtu.be/8h6IMYRoCZw https://youtu.be/fXIeFJCqsPs  Please explain how your actions will contribute to improving “flow”

 

  1. Address the scope of the proposed action, including any indirect or cumulative effects that may result from the action.
    1. How will continued access to the public lands on top of Warner Ridge and West Rim be accomplished?
    2. What will be the impact of the loss of staging and dry camping in the area?
    3. What will be the impact on the remote disbursed camping sites on Pipeline Road? What alternatives have you considered?
    4. What will be the impact on OHV traffic patterns from the recently constructed Waddy’s Corral Staging area and other Sand Mountain trails?
    5. Why are you giving more land than needed for the reservoir? What is the cost of having the land resurveyed to accommodate a smaller footprint of the exchange?
    6. Where will the people that use the disbursed camping sites on Pipeline Road go?
    7. Where will the campers using Washington Dam free camping area go?
    8. There are often many conflicts when different land managers are in charge of adjacent areas, who is going to manage the acquired land, and what is their experience working in conjunction with BLM as the adjacent land manager?
    9. How will the view sheds from the West Rim trail and above be impacted by the change?
    10. The OHV Area loss from this is 1050 acres, plus an additional loss of almost 400 acres if the reservoir project proceeds in a future request. This is in addition to the indirect and direct cumulative effects from various options from the 2016 Lake Powell Project proposal, ranging from 60 to 290 additional acres of land being closed to OHV use. This brings the total OHV loss to 1740 acres from the Sand Mountain SMRA. What other options have you considered?
  2. Identify any potential environmental justice concerns that may arise from the proposed action, such as impacts on low-income or minority communities.
    1. Explain your scientific analysis of the impact of potentially losing the free and disbursed camping affect users of lower income?
  3. Discuss any potential cultural or historical impacts on Native American tribes or other affected communities.
    1. I recently learned that there were archaeological/cultural finds in Warner Valley that may have been damaged. These sites have never been published as far as I know. What studies have you conducted that show comparisons in keeping sites “secret” versus publishing locations and encouraging conservation measures? What cultural, anthropological, and historical impacts will result from this Proposed Exchange, and how will they be mitigated?
  4. Offer specific suggestions for how the BLM can address public concerns and incorporate feedback into the decision-making process.
    1. Visitors to the area come at all different times of the year, and from very wide geographic areas. When the next phase of comments is released, please consider a longer comment period to allow OHV and camping groups to reach more individuals that will have an interest.

 

 




Watch our Youtube Update on the BLM Sand Mountain Land Exchange




Sand Mountain Land Exchange Questions and Answers

Join UPLA and DRATS for an update about the Sand Mountain Land Exchange, and get your questions answered. Loren Campbell from UPLA and Jeff Bieber will be taking your questions via chat during the call.

We are getting great comments being submitted, but like anything of great importance, there are lots of rumors that we want to do our best to answer.

This Zoom event is limited to the first 100 people, but you must preregister. Register Here

If the event fills up, we will either post the recording or reschedule a repeat session.