Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah

Recreational Access and Conservation - Conservation and Public Service Activities

Dedicated to conservation and multiple use of public lands for recreation opportunities.

Edited by: John Stewart

Public Comment: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah

Dear Public Lands Stakeholder:

Recreation is an important part of the economic base of this country. Additionally, it is widely recognized that the human benefits of outdoor recreation are substantial. In recent years the demand for recreational opportunities in Utah has increased dramatically. Along with that increase has come the concern about how this use can potentially adversely impact the public lands. The following proposed recreation guidelines have been developed by the Utah Bureau of Land Management (BLM) Resource Advisory Council (RAC) to help the BLM in Utah achieve the "Standards for Public Land Health" in its recreation management activities and programs. BLM’s mission is to sustain public lands and their productive capacity for present and future use; these standards for health are one of several key tools to achieve that end.

The intent of these guidelines is to minimize and prevent adverse impacts that could damage or destroy the natural and cultural elements of Utah’s public lands including historic and archaeological sites, soils, water, air, vegetation, scenery, wildlife habitats, riparian areas, endangered or threatened species, wilderness areas and affected communities. These guidelines will help assess the potential impact of recreation use on health of the land standards. BLM managers are responsible for using these guidelines in partnerships with stakeholders to ensure public land health.

Once the public’s comments have been reviewed and incorporated into the recreation guidelines, field managers will begin implementing these guidelines in their day-to-day work, within constraints of existing workloads and available staffing. BLM acknowledges that full implementation will require additional on-the-ground recreation management capability, and we will continue to pursue additional on-the-ground recreation funding to ensure that the outstanding recreation opportunities and health of the land on Utah’s public lands are sustained for the future.

The following three letters were perpared from information provided by BlueRibon Coalition. Please cut and paste and add your comments or select the letter and provide your name and address and e-mail your letter to the BLM Outdoor Recreation Planner.

Letter #1:

Outdoor Recreation Planner
Bureau of Land Management
Salt Lake Field Office
2370 S. 2300 W.
Salt Lake City, UT 84119

RE: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah.

Outdoor Recreation Planner:
Please accept these comments to your Recreation Management Standards and
Guidelines. I have been reviewing the process of your Recreation Management
Standards and Guidelines and believe they are overshadowed by the BLM
National Recreation Strategy. As such, this duplication creates an unnecessary
burden on the recreational users of public lands to abide by the "correct" set of rules.

If, in fact these BLM Standards and Guides are more important for the state of
Utah and they establish absolute standards by which all recreation management
must abide; then, they are implementation OF the National Strategy in Utah -
before the Strategy has been finalized.

Most of the Standards and Guides (5 pages) are fairly reasonable. However, I
have identified significant problem areas:

In the Introduction:

1. "The resources of these lands include not only timber, minerals, soils, riparian
areas, water, air, and vegetation, but also beauty, opportunity for quiet and solitude,
historical and archaeological sites, wildlife habitats, threatened and endangered
species habitats and wilderness."

This general statement of introduction inappropriately commingles physical
features (timber, soils, water), values (quiet and solitude), and legal requirements
(t&e species, wilderness). The implication is that these diverse aspects of public
land are the same, and should be given equal weight in management.

The introduction should discuss these separately and explain the agency's legally
mandated mission for each. For example, values like "quiet and solitude" should
not be equated with physical resources. They are the subjective perceptions of a
segment of the community and no standard exists to define their meaning.

2. "The following guidelines for recreational use of the public lands are intended
to assist in meeting not only the Rangeland [ecological] Health Standards but also to
minimize harm to public land values as listed above."

They seem to be saying here that all of the public land attributes listed above are
VALUES, when clearly they are not. It seems to be elevating, once again, the values
they've listed to something concrete and absolute when they are actually subjective
and associated with Wilderness. The mixing of "values" with"features" creates and
unreasonable burden on the recreational user to understand the guidelines.

Physical attributes (wildlife habitat) equated with legal obligations (t&e habitat and
historical sites) and subjective values. They are not the same, they have different
mandates, yet this Standard implies that they are equal and that they will be managed
equally. The Standards and Guides must address them differently and manage them
separately.

Subjective values such as beauty, solitude, and quiet have nothing at all to do with
the condition of upland soils. This should be deleted.

Sincerely,

Letter #2

Outdoor Recreation Planner
Bureau of Land Management
Salt Lake Field Office
2370 S. 2300 W.
Salt Lake City, UT 84119

RE: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah.

Outdoor Recreation Planner:
Please accept these comments to your Recreation Management Standards and
Guidelines. I have been reviewing the process of your Recreation Management
Standards and Guidelines and believe they are overshadowed by the BLM
National Recreation Strategy. As such, this duplication creates an unnecessary
burden on the recreational users of public lands to abide by the "correct" set of rules.

If, in fact these BLM Standards and Guides are more important for the state of
Utah and they establish absolute standards by which all recreation management
must abide; then, they are implementation OF the National Strategy in Utah -
before the Strategy has been finalized.

Most of the Standards and Guides (5 pages) are fairly reasonable. However, I have
identified significant problem areas:

Rangeland Health Standard 3 contains some dangerous language within a general
statement that is fairly benign:
"DESIRED SPECIES, INCLUDING NATIVE, THREATENED, ENDANGERED, AND SPECIAL
STATUS SPECIES, ARE MAINTAINED AT A LEVEL APPROPRIATE FOR THE SITE
AND SPECIES INVOLVED."

There are problems with #2 (a):
"Maintaining interconnecting wildlife travel corridors and, to the extent practical,
avoid fragmentation of areas used by wildlife"

This statement enshrines, within this Standard, the island biogeography philosophy
of Wildlands founder Reed Noss' claims that animals need tracts of wilderness
connected by undisturbed corridors to thrive. This flies in the face of common sense.
We know that animals use roads and trails to move from place to place. In fact, man
has adapted many of these game trails for his own use. Roads and trails do NOT
fragment habitat. In fact, some can argue that they can ENHANCE habitat by
facilitating movement. Studies that purport to confirm Noss' theory assume that
if animals (elk and grizzly bear, specifically) are observed to be displaced
from a roaded area, that they are displaced 100% of the time. In fact, they are only
displaced during times of traffic and actually use the roads when traffic is absent,
for example, at night.

There are problems with #3:
"Where necessary, control recreational use by kind of activity, season, intensity,
distribution, and/or duration in order to protect plant and animal communities,
especially those containing threatened, endangered, or candidate species."

Controls should not be imposed unless there is evidence that recreational use is
negatively impacting these communities. Candidate species should not be given
identical status as threatened or endangered species.

Sincerely,

Letter #3

Outdoor Recreation Planner
Bureau of Land Management
Salt Lake Field Office
2370 S. 2300 W.
Salt Lake City, UT 84119

RE: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah.

Outdoor Recreation Planner:
Please accept these comments to your Recreation Management Standards and
Guidelines. I have been reviewing the process of your Recreation Management
Standards and Guidelines and believe they are overshadowed by the BLM
National Recreation Strategy. As such, this duplication creates an unnecessary
burden on the recreational users of public lands to abide by the "correct" set of rules.

If, in fact these BLM Standards and Guides are more important for the state of
Utah and they establish absolute standards by which all recreation management
must abide; then, they are implementation OF the National Strategy in Utah -
before the Strategy has been finalized.

Most of the Standards and Guides (5 pages) are fairly reasonable. However, I
have identified significant problem areas:

In the Introduction:

"The following guidelines for recreational use of the public lands are intended to
assist in meeting not only the Rangeland [ecological] Health Standards but also to
minimize harm to public land values as listed above."

They seem to be saying here that all of the public land attributes listed above are
VALUES, when clearly they are not. It seems to be elevating, once again, the
values they've listed to something concrete and absolute when they are actually
subjective and associated with Wilderness. The mixing of "values" with "features"
creates and unreasonable burden on the recreational user to understand the guidelines.

This line of thought finds further expression in the first Rangland Health Standard
which begins in a benign way:

"UPLAND SOILS EXHIBIT PERMEABILITY AND INFILTRATION RATES THAT SUSTAIN OR
IMPROVE SITE PRODUCTIVITY, CONSIDERING THE SOIL TYPE, CLIMATE, AND LANDFORM"

"Designate areas for intensive recreational use or cross-country motorized travel
where disturbance of soil and vegetation is acceptable, either because impacts are
insignificant and/or temporary or because the value of intensive use of the land
outweighs whatever ecological changes may occur."

So far-so good. Here's the kicker in the next sentence:

"Decisions on such designations should take into account conflicts with other users
as well as adverse effects on archaeological or historical sites or Native American
values, threatened or endangered species habitat, wildlife habitat, or visitor
experiences regarding beauty, solitude, and quiet."

Physical attributes (wildlife habitat) equated with legal obligations (t&e habitat
and historical sites) and subjective values. They are not the same, they have
different mandates, yet this Standard implies that they are equal and that they
will be managed equally. The Standards and Guides must address them differently
and manage them separately.

Subjective values such as beauty, solitude, and quiet have nothing at all to do
with the condition of upland soils. This should be deleted.

I believe that "Native American values" should be replaced with something like
"sites significant to Native Americans" if archaeological sites don't cover it.
If this sentence remains, it virtually assures that NO general BLM lands can be
designated as this standard intends.

Sincerely,