BLM - California State Office
Attached is a letter on behalf of the Pacific Crest Trail Association in support of the California BLM grant for restoration on the PCT in southern California. [Brendan Taylor - 4/4/11]
See attached comments. [Alliance for Responsible Recreation - 3/28/11]
See attached comments. [ORV Watch Kern County - 3/21/11]
Off-road vehicle (ORV) use has been reported by the California Air Resources Board to produce 118 times as much pollutants contributing to smog as automobiles. Wind can disperse suspended particulates over long distances and dust raised by OHV traffic can blanket plant foliage close to and away from vehicle activity. This can add to existing air quality problems in areas where non-attainment with established air quality levels complying with the Clean Air Act have been set, both within and outside of designated open areas. Reductions of particulate matter sources by limiting vehicle use on unstable or inappropriate roadways have been suggested as a means of improving public health, as reported by Arizona’s Maricopa County Planning Department in 2008.
Relative to BLM’s request for use of California state monies, it is assumed that the agency establish monitoring stations both within open areas. Will monitoring stations also be established at a distance from open areas, and what will this distance be? Which pollutants will be monitored and how? Will BLM’s monitoring plan be based on the establishment of “SMART” objectives, i.e., objectives which are Specific, Measurable, Achievable, Relevant, and Time-framed?
BLM states that "Air quality monitoring will provide information on both direct and indirect affects of fugitive dust on special status species habitats, potential soil loss from OHV travel, and transport of dust offsite to other adjacent lands." Exactly how will direct and indirect affects of fugitive dust on special status species habitats and potential soil loss be assessed? How exactly will the collected monitoring information "lead to improved facilities that provide motorized access to camping, hiking, birding, equestrian trails and rock climbing areas?"
The agency states that stakeholder involvement is sought, including OHV groups. Which additional stakeholders will be provided an opportunity for involvement and "solicited" for information relative to "known dust issues, areas of high and low use", and how will these stakeholders be selected? 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?
There is a statement made by BLM in its proposal that “Progress reports will be submitted to the OHV Commission every 6 months”. 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 addressing air quality pollutants. Yet these rules and associated information are rarely if ever posted in open areas or adjacent public lands in western Mojave Desert. Will BLM as part of its request for State of California monies to monitor air quality impacts, also begin posting open and limited area interpretive kiosks and bulletin boards with information that identifies where each of these types of registered vehicles (red and green sticker vehicles) can and cannot be operated? If the state of California is to provide state monies to the federal government for monitoring air quality impacts, it would seem incongruous for the state to not request BLM begin informing vehicle users of these vehicle registration/use requirements.
It would also seem necessary that any plan for pollutant and air quality monitoring include actions items to minimize the effects air quality impacts if particulate matter or other pollutants exceed standards established by the State Implementation Plan for the area. What specific action items might be used by the agency to minimize impacts if the proposed monitoring detects impacts exceeding state standards?
BLM’s proposal to establish a particulate matter and air quality monitoring program 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 is known to affect citizen health.
Thank you for your consideration of these comments. [Thomas Ega - 3/21/11]