BLM - Barstow Field Office
Off-road vehicle (ORV) use has resulted in significant damage to previously reclaimed closed route sites in the Ord Pilot Project area and within the Juniper Subregion area, as well as in many additional public land areas, over the last ten years.
Relative to BLM’s request for use of California state monies for proposed restoration, how will previous "restoration" work effectiveness be evaluated? In most instances, work accomplished with respect to vehicle use damage or non-compliance is well known to be long-lasting in the western Mojave Desert. At best, such work, while necessary, is often better referred to as reclamation, as restoration to a previous, undisturbed condition has never been documented per current scientific literature. The BLM should acknowledge this fundamental precept in its requests to use California monies for vehicle management-related actions and address related actions accordingly.
Relative to the BLM grant application request, will all previously reclaimed closed routes be evaluated or will a statistically valid sampling design be established to determine which sites are to be evaluated? What is the existing monitoring protocol specified in this grant request to consist of? What will the effectiveness monitoring plan be comprised of?
The cited environmental documentation specified in this grant request is unclear as to the specific types of monitoring techniques to be used and what the monitoring objectives are; and further, are applicable to the Ord Mountain area only. What monitoring extent sampling, techniques, and intervals will be used in the Juniper Flats and other subregions?
Will BLM’s monitoring plan in both the Ord and Juniper locales, as well as other areas, be based on the establishment of “SMART” objectives, i.e., objectives which are Specific, Measurable, Achievable, Relevant, and Time-framed? If these types of objectives are not to be identified, why not? Will the general public be informed of proposed monitoring objectives and be given an opportunity to comment on the monitoring plan to be developed with California monies? The cited environmental documentation specified in this grant request is unclear as to the specific types of monitoring techniques to be used and what the monitoring objectives are. California citizens should be properly informed, and have some basic level of involvement, in how their monies are spent.
How exactly will the collected monitoring information be used? Will closed route rehabilitation actions that have been vandalized be repaired? Will closed route signing be used? Will Executive Order 11989 be implemented (i.e., "Where off-road vehicle use is or will cause adverse effects to soil, vegetation, wildlife, or cultural resources, affected areas or trails will be immediately closed to the vehicle type causing such effects, until these effects are eliminated and measures implemented to prevent future recurrence)? Will any remedial repair and signing efforts continue to be monitored, and what will the interval of monitoring be? What will BLM do if these remedial reclamation efforts designed to repair vandalism are damaged yet again?
Will any form of stakeholder involvement be sought? Which stakeholders will be provided an opportunity for involvement and "solicited" for information? At least one organization, the Friends of Juniper Flats, is well known to have closely monitored off-road vehicle non-compliance and vandalism damage to previously reclaimed closed routes. This information would be extremely important in determining appropriate repair and action implementation priorities, and best make use f California monies requested for this grant. Will BLM use monitoring data submitted to the Barstow Field Office by this group, or request information from this organization to address known non-compliance and damage to previously reclaimed closed routes in the Juniper Flats Subregion? If not, why not?
Will progress reports be submitted to the OHV Commission in a timely manner? Will this information be submitted to the general public as well, in an easily accessible manner, as directed by President Obama’s 2009 Open Government Directive? Such reporting to the general public would further the transparency of BLM’s monitoring effort to all interested parties, as now mandated for federal agencies by the Open Government Directive. If this monitoring information is not to be provided to the general public in an easily accessible manner, the OHMVR should question why a federal directive is not to be applied relative to using State of California monies.
The State of California has established rules for both green-sticker and red sticker vehicle use, relative to where such vehicles can be used on public lands. Yet these rules and associated information are not posted in Limited Use public lands in western Mojave Desert. Nor has relevant San Bernardino Ordinance information (i.e., County Off-road Vehicle Use Restrictions & Penalties; no use on private lands unless in receipt of written permission, etc.) been posted. Will BLM as part of its request for State of California monies to monitor use compliance/previous vehicle management actions/repair damage also include an effort to inform motorized vehicle users of these state and county rules and regulations? If the state of California is to provide monies to the federal government for monitoring and vandalism repair, it should have some assurance that every effort is being made to inform the public of use rules and allowances, and ensure these monies are being used wisely.
BLM’s proposal to monitor previous vehicle use management actions and repair vandalism to previously reclaimed closed routes, signing etc. is a step in the right direction and should be supported. However, California taxpayers should be provided an opportunity to review and comment on the details of a federal agency action such as this which will be using state funds to monitor an activity authorized on public land which has damaged public and private lands, and previous activity funded by California OHVMR grant monies.
Thank you for your consideration of these comments. [Thomas Egan - 3/21/11]