The Comment Period for the Kanab Field Office Release Draft RMP Ends January 10, 2008. Your comments are needed asap. The key issues that need to be addressed are outlined in U4's position paper. We have included the official position of the Utah 4 Wheel Drive Association for reference. Please take a moment to write a short letter that addresses these concerns.
Address letters to:
Bureau of Land Management
Kanab Field Office
318 North 100 East
Kanab, UT 84741
BLM Kanab Field Office
318 North 100 East
Kanab, UT 84741
To Whom It May Concern:
The Utah 4 Wheel Drive Association (U4WDA) is a non-profit group made up of clubs and enthusiasts who enjoy 4x4 recreation on public lands in Utah. We represent over 1,000 members and 23 member clubs throughout the state. Our mission is to preserve access by promoting education and stewardship. Since our founding in 1978, U4WDA has worked with land managers across Utah on service and education projects aimed at maintaining recreational access while ensuring protection of natural resources.
We are pleased to have the opportunity to offer input on the Kanab Field Office DRMP/DEIS. Please consider this letter and attached documents as the official comment from Canyon Country 4x4 Club regarding the DRMP/DEIS currently under review.
U4WDA is in general support of the of the BLM’s Preferred Alternate, Alternate B. However we would like to see some modifications made and offer comments on some specific items concerning the final RMP and Travel Plan implemented in the area. These comments represent the opinions of the U4WDA Board of Directors and the expressed concerns of our general membership.
Kanab Community Special Recreation Management Area (SRMA) Off Highway Vehicle (OHV) Recreation Management Zone (RMZ) aka. Hog Canyon Trail System
We support this RMZ, but the RMP should include more direction regarding when and how additional or expanded routes would be provided. We feel that an expanded and improved trail system in the area would give the public an appropriate place for motorized recreation and take pressure off of more sensitive areas. We support the proposal and map submitted by Canyon Country 4x4 for managing this RMZ.
Special Recreation Management Areas (SRMA)
SMRAs and their “focus areas” should avoid excluding other uses categorically. The DRMP should provide more direction on how these areas are to be managed.
Proposed SRMA for John R. Flat area
We support the inclusion of SMRA for the John R Flat area for an OHV RMZ as proposed by Kane County. We would like to see it added to Alternate B.
Proposed Dry Wash Routes
We support the inclusion of some dry wash routes as proposed by Kane County
This proposal was not included in any of the Alternates and we would like to see it
added to Alternate B
Special Recreation Permits
The Special Recreation Permit requirements as written in Alternate B are totally unworkable. As written, not only would organized 4x4 and ATV events be unlikely, but probably any organized events like family reunions, scout camps or even a large barbeque. Clear cut guidelines are needed for when a SRP is required. The Group size limit of 25 people is totally unrealistic.
Visual Resources Management Classes (VRM)
The DEIS page 2-58 states that “To the extent practicable, bring existing visual contrasts into VRM Class conformance as the opportunity arises.” This statement is too vague and subjective as to what the Management Action is. What is meant by “To the extent practicable”? We oppose designating the VRM Classes as shown in Alternate B unless the Management Actions are defined.
Non WSA Lands With Wilderness Characteristics (WC)
Although Alternate B “Requires no prescriptions specifically to maintain WC areas.” U4WDA opposes having the designation of Non WSA Lands with Wilderness Characteristics. The Map 3-15 and table 3-22 should not be included as part of this process.
Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review
Areas of Critical Environmental Concern (ACEC)
Alternate B designates the potential Cottonwood Canyon ACEC (3,800 acres) as an ACEC. We can accept this ACEC to protect the watershed, however we question the size and if that much acreage is needed. We strongly oppose the designation of any additional ACECs
Unreliable information should not be used as planning criteria in the RMP process.
Table 3-26 appears to be very unreliable and slanted towards a specific user group. Anyone who has spent any time in any of the areas managed by the KFO can see how greatly flawed this table is. Some special interest groups are making grossly inaccurate statements using this table as evidence. Unless there is some data that could give some credence to the highly unbelievable numbers on the table, we ask that this table be removed in it’s entirety from the RMP documents as it is being misused to distort issues rather than determine how areas should be managed. Also, this table is contradicted in 4.1.6; Incomplete or Unavailable Information, which states; “Direct recreation visitation based on actual use and economic expenditure
data associated with such use”
In studying the maps and documents in the DRMP/DEIS for ALT B. U4WDA has found roads shown to be closed that should not be closed and has been informed by the local clubs that some existing roads are not shown on the maps.,
We also consider it a mistake to attempt to close roads that are part of the Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. Less conflict would arise by having the validity of these route determined before any attempt was made to close any of these roads. We also feel that not having existing roads on the maps as part of the RMP process does not give us the opportunity to make meaningful comments on the roads shown on the maps as part of Alternate B.
Management Actions for the Transportation System Management 2-26 states; “Coordinate transportation planning with Kane and Garfield counties” We would like to see how this is to be implemented.
We appreciated the opportunity to comment on the proposed Resource Management Plan, and we hope that our comments and concerns will be given the proper consideration.
U4WDA Southwestern Vice President
The U4 Letter as a pdf can be found here.