# San Rafael Swell



## Huge29 (Sep 17, 2007)

The Swell is a place near to my heart as my buddies and I spent countless days/nights there camping and messing around. I think this call to action is worthy of our time as SUWA has struck again. I am sure that several of you will object to what is being requested; that is fine, but then again, let's have a balanced representation. I, personally, think that restricting areas really only hurt those who already obey the laws and use good common sense, "it's just those dang mullet wearing rifle hunters that I have a beef with"--in Treehugnhunters own words.

Subject: Comment Letters Needed for San Rafael Swell!

BLM PRICE FIELD OFFICE WILDERNESS CHARACTERISTICS ALTERNATIVE "E" TALKING POINTS
If you enjoy public lands in Carbon or Emery County and support multiple use activities on those lands, then YOU need to get involved with the latest land use battle at the BLM. As the result of a Federal Court Decision (for SUWA and against the BLM) the BLM was forced to stop work on their Resource Management Plan Update process and re-evaluate Non Wilderness Study Area lands for "Wilderness Characteristics" (WC). The BLM has now completed that project and is asking for public comments on their new Alternative "E" which would identify over 970,000 acres in the Carbon-Emery County area as having WC.

We are asking EACH of you to send a letter to the BLM Price Field Office. Your letter will be very simple because this comment period is only for you to reply to Alternative E. In 2004, we (hopefully you) commented on the other four alternatives, namely A, B, C and D. We are using the opportunity here to voice our opposition to the proposed 970,000 acres of proposed area that SUWA claims contains WC. The designation of areas containing WC will negatively impact popular riding areas as Eva Conover, Coal Wash, Temple Mountain Trail System (red, blue, green, orange and the Five Miles of Hell), Behind the Reef Trail and the entire Chimney Rock Area. In other words, SUWA claims WC in every popular riding area within the BLM Price Field Office lands.

In addition we are taking advantage of this opportunity to request that the BLM recognize and DESIGNATE the Chimney Rock Trail system in the final alternative. As it sits now, only the "no-action" alternative in the DRMP contains the trails in the Chimney Rock area. The Sage Riders Motorcycle Club submitted a trail map showing a substantial inventory of the trails in the Chimney Rock-Neversweat-Humbug-Lost Springs area. Somehow, the BLM lost the data and have once again asked motorized user groups to provide information that would refute SUWA's claims. Thus, we are now left to fight an uphill battle in getting the Chimney Rock Trail System designated.

The Sage Riders Motorcycle Club, namely Dick Brass, Wade Allinson, Alan Peterson, Scott Wheeler, Weston Allinson and Paul Anderson have spent the last 45 days gathering over 1,200 photos and waypoints that will positively show the BLM that these WCs were created by LIES perpetuated by wilderness advocacy groups.

Any WC designation will negatively impact all forms of multiple use, especially motorized vehicles and natural resource development on ALL lands administered by the BLM Price Field Office.

Every letter will count.
1. Tell the BLM who you are, where you are from and what type of recreational activities you like to do on the San Rafael Swell.

Example: My name is Joe Dirt Biker. I live in New York City and I enjoy coming to the San Rafael Swell two or three times a year to ride my motorcycle on the single-track desert trails.

1. Tell the BLM that you do NOT support Alternative E.

2. Tell them that the Wilderness Characteristics as described in Alternative E are not substantiated on the ground, specifically Chimney Rock (Lost Springs WC and the Never Sweat WC), San Rafael Reef WC, Molen Reef WC and Eagle Canyon WC.

3. Tell the BLM that the Never Sweat and Lost Springs proposed WCs contain the Chimney Rock Motorcycle Trail System that needs to be recognized and DESIGNATED. This trail system has been permitted by the BLM for off road competition events for over 25 years. Tell the BLM that you support the designation of the Chimney Rock Trail System that was submitted by the Sage Riders Motorcycle Club.

4. Tell them that you do not support the reduction of 250 miles of travel routes as described in Alternative E. Tell the BLM that you support the designation of the Purple Trail, VJ Trail and Cottonwood Wash Trails as being open to motorized use.

Send your comment letter to:
Bureau of Land Management
Price Field Office
125 South 600 West
Price, Utah
84501

E-Mail
[email protected]

Snail mail is recommended

Comments are due by 12/12/07.
If you have any questions contact Wade Allinson, Southeastern Utah Public Lands Representative, Sage Riders Motorcycle Club [email protected] 435-384-2711 (after dark).


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## GaryFish (Sep 7, 2007)

Just a hint here to those that want to write letters. And I offer this as a technical expert who handles these kinds of projects professionally - 

1. This is not a vote. The number of letters sent does not matter. 1000 letters that say the same thing is considered the same as one letter that says the same thing.

2. If you want to have "standing" in this project, a simple "I do not support" is nothing the BLM can even deal with. Such a comment will be dismissed.

3. If you want your letter to have serious impact, you need to specifically address the technical merits of the environmental assessment. Such comments HAVE to be addressed by the BLM - where as "this sucks" does not have to be addressed and is not worth your time to submit.

4. BLM is required to consider a range of alternatives in their Resource Management Plan - and this is the extreme alternative, and no way in hell will it be adopted. 

5. On the Chimney Rock Trail System, this was part of the Price Field Office San Rafael Swell Route Designation Plan that was finalized in 2002. Base your consideration of this system, and reference the previous route designation plan, and point out that wilderness characteristics were not considered environmental impacts in that plan, and nothing has changed since that adoption that would require additional analysis. Additionally, and here is a hint on how to discredit the report, chunks of land have to have at least 5,000 contiguous acres void of any road, trail, or "sign of man" to "possess wilderness characteristics." So with this trail system in place, I would bet you can't find a 5,000 piece of ground. So discredit the analysis by attacking that.

6. Lastly - If you care about how your tax dollars are spent, do not spam BLM with tens of thousands of post cards and letters that say "I think Alternative E Sucks". It costs BLM $2-3 to deal with every letter received. (I've managed the budget on several of these projects and so I know what it costs them) Even though this kind of comment may represent how you feel, it will not change what is done, and has no merit and is of no use. It only costs the agency money - and a lot of it. Send a comment that addresses the specific technical aspects of the plan and analysis in the EIS - or it is a waste of yours and their time.


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## Huge29 (Sep 17, 2007)

Gary,
Good work, that is very insightful, thanks! It always helps to have someone from the inside; you are much brighter than your avatar insinuates-j/k.


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## GaryFish (Sep 7, 2007)

> you are much brighter than your avatar insinuates-j/k.


Don't be so sure.


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## Trooper (Oct 18, 2007)

I'm a little torn on this one. I agree that some of the riding areas ought to be preserved for riding (ie the color trails, five miles of hell), but if we don't preserve a lot of the wilderness quality land now, how many new trails will open up? You spoke of a new trial being put in... who authorized those guys to take it upon themsleves to create a new trail/road system on public land? It sure wasn't me. We can't have every Tom, Dick and Harry with a quad and a shovel building new trails wherever they want.


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## GaryFish (Sep 7, 2007)

Its not a new trail. Its been there for decades. BLM has not formally "designated" trails. This trails plan is an attempt at getting a better handle on things which will help to avert the proliferation of new trails.


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## Petersen (Sep 7, 2007)

I've been making regular trips to the San Rafael Swell for going on 30 years now, and I've witnessed way too many great places slowly trampled into a maze trails and gullies. 

I have no problem with responsible riders, but the Swell is a prime example of what can happen when selfish and irresponsible people take it upon themselves to ride over top of any and everything that strikes their fancy. The land there is extraordinarily fragile, and it will take generations for the damage to repair itself.

I have no particular faith in the ability of the BLM to deal with this problem in the best possible manner, and I have no opinion on the specific issue brought up here, but I do have an opinion on the health of the Swell in general: there are just way too many people driving off the established trails and roads in way too many places. Something needs to be done about it before that magnificent stretch of land is reduced to several hundred square miles of tire tracks and denuded hillsides. 

Again, I have absolutely nothing against responsible riders, but I have no sympathy whatsoever for some of the jerks I've seen down there destroying some of mother nature's finest handiwork.


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## Finnegan (Sep 7, 2007)

I don't get it. Wasn't this business resolved 4 or 5 years ago? As I recall, the legal trails were designated and funding was provided for the county sheriff to patrol for violations. Various concerned groups (except SUWA) agreed to provide volunteers to educate visitors. SUWA was involved in the development of that plan and agreed to the conditions. Isn't that plan working? (Haven't been there for over a decade, so I really don't know.)


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## GaryFish (Sep 7, 2007)

Finnegann -you are correct. There was a route designation plan completed for the San Rafael Swell area - signed into policy in spring of 2002.


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## Trooper (Oct 18, 2007)

> BLM has not formally "designated" trails.





> There was a route designation plan completed for the San Rafael Swell area - signed into policy in spring of 2002.


So which is it?


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## GaryFish (Sep 7, 2007)

> BLM has not formally "designated" trails.
> 
> There was a route designation plan completed for the San Rafael Swell area - signed into policy in spring of 2002.
> 
> So which is it?


Sorry about that. I thought that after I posted.

The San Rafael Route Designation Plan covered approximately the southern 2/3 of the Price Field Office, or roughly Emery County. This new plan addresses the northern 1/3 of the Price Field Office, or roughly Carbon County. Also - routes that were designated in the previous plan, are also under review in the larger, Price Field Office Resource Management Plan. So there are about four things out there that cover routes in that region. This most recent will designate more (or less in some cases) routes that have previously not been designated.

This is driven by the BLM's method of governing OHV use. They essentially have four classifications for OHV use:
1. Open - This means that an area is open to OHV use anywhere within a designated area - you can drive your wheeler on or off trails, whereever you want to go. This is usually reserved for dune type enviornments where open play will not harm the ecosystem components. Think Little Sahara or Coral Pink Sand Dunes here. 
2. Closed - The area is closed to OHV use - including on roads/trails that might be in an area. This is seldom used except in Wilderness areas, or small areas where there are endangered plants present, or archiologoical resources are subject to damage. 
3. Limited to Designated Roads and Trails - This means you can drive your wheeler on established, designated roads and trails but may not go off trail for any reason. Think here about the Piute or Great Western Trails Systems as excellent examples here.
4. Limited - with Seasonal Restrictions - Same as #3, but the trail may be closed during times such as winter - to protect wildlife during most vulnerable times, or when conditions are too wet and riding will trash the trails, etc.... Again - think of sections of the Piute/Great Western Complexes that close seasonally.

For these classifications to work, the BLM has to formally "designate" the trails systems that may be used - either year round, or seasonally if there is a strong case for it. It is a very long and volitile process to go through. But one that is necessary.

I will say that BLM is very concerned about keeping OHV opportunities open as much as possible, but still needs to manage things to protect what we all enjoy about some of these areas. They get huge pressure from all sides on this thing, and no matter what they do, most sides will be ticked off. But I do commend them and believe me - they are trying the best they can do balance things.

Again - as you look to comment on the proposal for route designations - be sure to address the technical aspects of the analysis - and the factual basis of the route designations for consideration. Simply saying "you suck" is a waste of your time and their time and does not help anything.


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