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This is very important to comment by Friday July 28, 2006.
I suggest we look this over a draft a template letter for comment. Points to look for:

-The normal and current parking stage area is to be moved to the Feed Lot area.
This is bogus. The BLM needs to make the parking area at the trail head. Their reasoning for moving to the feed lot is for wild horse perservation.

-They plan on closing Renolds Creek - Becks Wall (China Wall) to MTBs.
No one hikes this. We need to comment on this. The resoning is to preserve the Historical resource. How can it be preserved if we also can not experience it?

The BLM Owyhee Field Office is soliciting comments on a draft
environmental assessment (EA) for the Wilson Creek Subunit Travel Management Plan. This area has become increasingly popular with mountain bicyclists over the last
several years.

You can download the EA from this page:
http://www.id.blm.gov/owyhee/nepa/wilsoncreek/index.htm

Comments are due by close of business, Friday, July 28, 2006.

Take a look and post comments here for the letter template or send in your own comments.

TIA<
Howley
 

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Do you have a link, or the file, for the Owyhee Resource Management Plan
(ORMP)/EIS issued in December, 1999? I'd like to read that so I can draft comments of a substantive nature. I would also like to know how long mtbs have been out there, which trails, and how often they are used. I know some people who have been riding out there forever (MarkV, Fred & Piltdown, Buddah).

I remember when I was the one writing the EA....
 

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Ummm....yes they are building a new staging area but they are retaining the existing unloading area (and a turnout I didn't include below) as follows:

"The existing user-defined staging areas about 1 mile further south on the Wilson Creek Road in T.1S., R.3W., Section 8, NE1/4NW1/4SE1/4 would be retained, but they would receive only minor improvements, including perimeter delineation by constructing berms and signing with Carsonite posts, gravelling, correction of drainage problems, and regulatory and information signing (Staging Area 2 on Map 5)."

The main concern is the loss of the China Wall along Reynolds, but I think I have a way to address the mitigation measure which recommends closure using the Marion document they reference with the predecisional EA. I'll have a draft template up within the next 2 days.
 

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Yup, I'll keep the one eye out for those types of errors. Though, I'm gonna try to incorporate "spackle" somehow.

Other than the Reynolds Creek/China Wall trail closure, I couldn't find anything adverse about alternative 2. Alternative 2 is the measure that seems to fit best for the mtb crowd. I may try to work out some language that would set forth a process for the construction of future trail....based on the EA format BLM has presented with this EA.
 

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my preliminary comment

Dear Mitch and Ryan,

I am contacting you in reference to the Wilson Peak EA. I have a number of concerns related to the EA and have broken them out below.

1) Closure of the Reynolds Canyon Entirely to Mountain Bikers
Mountain Bikers have been riding on Beck's Ditch and Caldwell Ditch for well over 10 years now and many riders have observed that the condition of both Ditches are in better shape than in years past. Since it was Mountain Bikers that first pointed the Ditch out to the BLM staff, it is Mountain Bikers who have a much better perspective on the condition of the Ditch. Both Ditches have drainage issues and the continued growth of plants on the ditch is causing the displacement of rocks and the structure of the ditch. I would recommend that the maintenance and supervision of ditch be turned over to the Mountain Bikers who can then seek RTP grants and other grants to shore up and care for the Ditches.

Another issue at hand is the conclusion that the impacts of Mountain Bikers on the soil and wildlife in the canyon are greater than hikers. This fact has been disproved and reference material and research can be found here: http://www.imba.com/resources/science/impact_summary.html
If hikers are allowed to use the trails in the canyon then so should Mountain Bikers, especially since we have been the dominant user of the canyon. If a user needs to be eliminated from the Canyon to reduce the overall impacts it should instead be hikers.

A route out of the canyon at the top of the existing trail should also be constructed to provide a loop opportunity for the enjoyment of mountain bikers. Additionally on the upper stretch of the trail the trail should be rerouted around the pre-historic site and an interpretive display should be added. Additionally it might be wise to fence off the prehistoric site since there is the possibility of wild horses destroying the historical site.
2) Location of the parking lot.
The location of the parking lot is very poorly chosen since the vast majority of users will prefer the old parking facility. The existing parking lots exist for two main reasons. The first reason is the fact that they are more sheltered from the wind during the winter months when usage is at its highest. The second is the reduction of the odor coming from the nearby feedlot. By placing the parking lot closer to the feedlot, the odor problem and high winds will push people to the existing parking lots. The argument that the wild horse herds will be drastically affected by the parking lot is completely unfounded. Having spent a great deal of time in the area, I have seen more wild horses in the vicinity of the proposed parking lot as opposed to the much better sited existing parking lot.
3) Inclusion of the Northwest Passage Trail:
I noticed that the Northwest Passage Trail has not been included on the trail map, we would like to see it included as it is one of the most popular mountain biking routes and provides and excellent loop opportunity.
4) Retention of the trail coming off of the Saddle from Stewart Gulch.
The trail on descending from the Saddle of Stewart Gulch towards Wilson Creek should remain open and the dirt road ascending Stewart Gulch should be closed to everything except administrative usage.
5) An assertion in the EA that future mountain bike trails can be constructed in the Wild Horse Herd Management Zones.
The Wild Horse Herds in the Wilson Peak area have not been detrimentally affected by Mountain Bike usage and this should not prevent the future development of Mountain Bike trails. The horse herds have not been affecting by Mountain Bike usage in the area and have instead become very habituated to the usage of bikes.
 

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Frank Jenks
US Dept. of Interior/BLM
Owyhee Field Office
20 First Avenue West
Marsing, ID 83639

RE: Comments on Environmental Assessment ID130-2006-EA-1927, Wilson Creek Subregion Travel Management Plan

Dear Mr. Jenks:

Thank for the opportunity to comment on Environmental Assessment ID130-2006-EA-1927, Wilson Creek Subregion Travel Management Plan (EA). I, (your Full name), would like to be contacted regarding the decision record pertaining to the EA.

My comments are as follows:

Comment Pertaining To Alternative 2 and 3: Designation of Beck and Caldwell ditches as hiking only is unacceptable.

Alternatives 2 and 3 should retain Beck and Caldwell ditches as a mountain biking trail. Conversion of the 4 miles of non-motorized routes upon the cultural resource on Beck and Caldwell ditches to hiking-only trails as proposed in section 3.7.2.2 of the Environmental Assessment ID-130-2006-1927, Wilson Creek Subregion Travel Management Plan (EA) is unacceptable because the justification for the proposed action contradicts information presented in section 3.10.2.2 of the EA and item 3 of the Management Actions and Allocations of objective RECT 5 of the Owyhee Resource Management Plan (OMRP). The justification for the proposed action states that the action "would eliminate the harmful effects of mechanized and equestrian use and should afford some protection to the cultural properties from accelerated deterioration." This justification contradicts the information regarding soil erosion presented on p. 44 of section 3.10.2.2 of the EA which shows that soil loss from bike trails is 0.8% less than hiking trails. Designationof the Beck and Caldwell ditches to hiking-only trails in order to mitigate soil erosion as a result of biking would not reduce soil erosion because , as presented in the EA, hiking causes more erosion than biking. It should also be noted that because moderate and controlled speeds are necessary to navigate the trail features on Beck and Caldwell ditches degradation and soil displacement are mitigated. This claim is substantiated by the last complete paragraph of p. 44 of the EA.

Conversion of the 4 miles of non-motorized routes upon cultural resource on Beck and Caldwell ditches to hiking-only trails as proposed is unacceptable because the justification for the proposed action contradicts information presented in item 3 of objective RECT 5 of the OMRP. Objective RECT 5 specifically states the following: "Develop a trail system that provides a range of motorized and non-motorized recreation opportunities for the public's enjoyment of primitive, semi-primitive non-motorized, semi-primitive motorized, and roaded natural settings." Item 3 of the Management Actions and Allocations of Objective RECT 5 specifically states "Develop a mountain bike trail program utilizing existing dirt roads and trails." Alternative 2 should retain Beck and Caldwell ditches as a mountain biking trail in order to comply with the ORMP.

Comment Pertaining to Alternatives 2 and 3: EA for the travel management does not address all non-motorized trails within Wilson Creek Subregion.

Alternative 2 and 3 of the EA for the travel management should state that all existing trails not addressed by the EA shall not be closed in order to retain and develop a mountain bike trail program utilizing existing trails, in accordance with item 3 of the Management Actions and Allocations of objective RECT 5 of the Owyhee Resource Management Plan (OMRP). Key value assessment on similar trails within the area justify keeping these trails upon to non-motorized users.

Comment Pertaining to Alternative 2 and 3: EA for the travel management does not address a standard procedure for the evaluation, development , expansion, or modification of existing non-motorized trail systems to further public opportunities to safely enjoy recreational settings (i.e. mountain biking).

In accordance with item 5 of the Management Actions and Allocations of objective RECT 5 of the OMRP, alternative 2 and 3 of the EA for the travel management should contain language for the development, or directly contain within it, a standard procedure for the evaluation, development , expansion, or modification of existing non-motorized trail systems to further public opportunities to safely enjoy mountain biking.​

Thank you again for the opportunity to comment.

Sincerely
(Your Full Name)
(Address)
(Email Address)
 

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Time to write

Using "Spackle Boys" as a starting point and going from there. Hope others are busy writing responses. It would be ashamed to get stuck smelling cow sh*t and getting cut out of some of the best riding in the area.

Time to get busy only a few days left!
 

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Another reponse to comments

If you ride in the Owyhee/Wilson Creek area, you should take a look at the EA and comment. We could miss out on some of the trails we are currently riding. Much like voting, if you don't you shouldn't *****. So those that ride out there get off the couch.

Below is my response to the Wilson Creek EA. Please feel free to cut and paste but make it your own. Form letters don't weigh in as heavy as individual responses. So please make it your own.

*****************************************************

Frank Jenks
US Department of Interior
Owyhee Field Office
20 First Ave. West
Marsing, ID 83639

RE: Response to Wilson Creek Subregion Travel Management Plan and Environmental Assessment ID 1320-2006-EA-1927

Dear Mr. Jenks:

I would like to thank you for this opportunity to comment on the Environmental Assessment for the Wilson Creek Subregion Travel Management Plan (ID-130-2006-EA-1927). My name is Mike Edwards and I live at 2068 Parkside Drive, Boise, ID 83712 and would like to be contacted concerning the decisions relating to this EA. I would also like to be included on any mail lists or informational outreach related to this area.

In general I support alternative 2 and 3 with some modifications. The modifications and inclusions discussed below may require additional study and expansions of the Wilson Creek Travel Management Environmental Assessment in order for the EA not to be in conflict with itself and other BLM documents relating to this area.

My comments related to this EA are as follows:

Comment Pertaining to Alternatives 2 and 3: The closure of trails and roads in the Steward Gulch Wilson Creek area and closure of historic trails not identified by BLM is not acceptable. Alternatives 2 and 3 of the EA states that, "Under this alternative both mountain bikers and equestrians would be restricted to designated travel routes." p. 44 and p. 45-46

As the Wilson Creek Travel Management Plan points out, "Along the corridor of the Owyhee Front, recreational OHV use predominates. Wilson Creek is unique among the areas with the 261, 487-acre Owyhee Front SRMA (Snake River management Area) because until recently, it alone has provided non-motorized recreation users, particularly horseback riders and mountain bikers, substantial single-track trial mileage, with little competing motorized use." (Wilson Creek TMP/EA p. 40) The need for non-motorized opportunities is further highlighted under Alternative 3 where it states, "Under this alternative, greater emphasis would be placed on non-motorized opportunities (hiking, biking, horseback riding) than under the Alternative 1 and somewhat greater emphasis on on-motorized opportunities than under Alternative 2. Non-motorized routes would more than double from 30 miles under the current situation to 77 miles under this alternative. The designation and signing of routes, coupled with public education and outreach efforts would help provide protection for non-motorized routes and reduce the probability that they would be appropriated and widened by motorized use, particularly ATV use." (Wilson Creek TMP/EA p. 45)

It is particularly interesting that BLM understood user conflicts and the need to provide equestrians, hikers and mountain bikers recreational protection from the onslaught and expansion of the motorized trail use in the Wilson Creek area and Owyhee front and then didn't follow the BLM's "Owyhee Resource Management Plan". Under the Plan's Objective RECT 2, Rationale: It states, "Federal regulations (43 CFR 8300) authorize the BLM to designate administrative units known special recreation management areas (SRMAs) where there is a need to commit to a higher level of financial investment in recreational facilities and a higher level of managerial presence than is typical of most BLM lands. A SRMA designation signifies a long-term commitment to manage the physical, social, and managerial settings of an area to sustain specific activities and experience opportunities. The delineations are based upon administrative/managerial criteria that reflect congressional designations (such as National Wild, Scenic or Recreational rivers), similar or interdependent recreation values, homogenous or interrelated recreation uses, land tenure and use patterns, transportation systems, administrative efficiency, intensity of use, high resource values and public concern." (Owyhee Resource Management Plan p. 36) The Plan goes on to point out that there are specific monitoring needs to be determined during the preparation of the SRMA activities which include, "Establishment of baseline data and photo points to determine current impacts from recreational use and development of "limits of Acceptable Change" studies where suitable, to help determination appropriate levels and patterns of recreational use, and the influence of other resource uses." Owyhee Resource Management Plan p. 36)

It quickly becomes apparent when looking at the Map 4 of the Wilson Creek Travel Management Plan that BLM has failed to establish a "baseline" of historic uses which would be need to comprehensively make determinations whether environmental impacts or user conflicts exist and then identify the "Limits of Acceptable Change." In the upper reaches of Stewart and Wilson drainages there are numerous trails that have been used by equestrians, mountain bikers and hikers that do not appear on the map. Under Alternatives 2 and 3 these trails would be closed for future use even though they haven't received the full attention BLM requires under the Owyhee Resource Management Plan.

There are a number of recreational users that have repeatedly tried to assist BLM in the development of "baseline data" so the Wilson Creek Travel Management Plan EA could identify and study the "limits of acceptable change." In the spring of 2005 several us including **888 and 8888888, 8888888, 8888888, 888888, 8888888 and myself met with Jim Schmidt and other BLM staff at the BLM office near the airport to talk about historic use of the Wilson Creek area and identify areas we had been riding and parking since the early 1990's. Some of the group has been riding in the Wilson Creek area since the late 1980s. We even offered to ride the Wilson Creek trails so the BLM staff could learn some of the historic trails ridden by mountain bikers. During this meeting, we all looked at maps and pointed out areas we have been historically riding and parking during the winter months (November-April) and requested to be placed on a list in order to receive information on the EA and invited to future public meetings concerning the Wilson Creek area. Even after repeated e-mails to Mr. Schmidt and other BLM staff, none of the above mentioned individuals have been notified of public meetings or included as public citizens in the development of this Travel Management Plan/EA.

Mr. Schmidt and the BLM have relied upon Southwest Mountain Biking Association (SWIMBA) and Chris Cook as the SWIMBA President as the spokesman for all mountain bikers. We pointed out to Mr. Schmidt and others at BLM that Chris is relatively new to the area and BLM should look toward others in the equestrian and mountain bike community in order to fully understand the historic uses of the area.

Since the Maps for alternative 2 and 3 do not show the baseline trail network utilized by equestrians, hikers and bikers one is left to make general comments on the area. Map 7 for Alternative 3 does show some trail and road closures on the upper reaches of stewards gulch and trail closer coming out of Stewards gulch.

On page 44 of the Wilson Creek Travel Management Plan/EA there is some discussion and documentation on the impacts caused by equestrians and ATV use. The Marion study used for the Wilson Creek EA points out, "that single use ATV and equestrian trails were significantly more degraded than hiking and biking trails. He found mean cross sectional area soil loss of ATV trails at each trail transect sample point was 246 inches squared; 150 inches squared for horse trails; 19 in squared for hiking trails; 6 inches squared for bike trails. The proportion of trails with severe erosion measured in the study (> inches deep) is 24% for ATV trails, 9% for horse trails, 1.4% for hiking trails, and 0.6% for bike trials." (Wilson Creek TMP p. 44) This empirical evidence would suggest that mountain bikers cause the least amount of trail erosion.

The Vanderman 2004 study used for the Wilson Creek TMP/EA suggests, "mountain bikers are generally lower than those caused by ATV or equestrian uses, impacts to wildlife populations, and social impacts to other users can be more significant because mountain bikers can potentially cover longer distances at higher speeds than hikers or equestrians and encounter and potentially disturb more wildlife or wild horses during a typical outing." Since Alternative 2 and 3 of the EA does provide subjective evidence to the social impacts of OHV use to other users (see Wilson Creek TMP section 3.13.1) one is lead to believe Equestrians are excluded do to trail impacts and mountain bikes are excluded do to impacts on wild horse populations. Since hikers are not excluded from the closed areas one can conclude bikers are excluded do to impacts on wild horses since as the studies states, bikers in many instances cause less erosion than hikers.

However under "Cumulative Impacts Wild Horse" section seems to refute there has been any impact from biking in the Hard Trigger Horse Management Area. "Additionally, under the current situation, Hardtrigger HMA wild horses continue to be healthy and self-sustaining in nature (SEE Appendix 3). No current data or information exists to indicate that the current levels of recreational use in the Wilson-Hardtrigger area are having a negative impact on wild horse herd health, there sustainability, or free-roaming behavior and nature. As was discussed in the environmental consequences section of this alternative, a continuation of the current situation presently would not be expected to directly impact wild horse health conditions in the short term. However, in the foreseeable future, with the present trends regarding an increased demand for use in the Wilson Creek area and along with the recent increase of motorized use of trails previously motorized-free wild horse habitats, herd distribution and displacement would be expected to change and increase in the long term."(Wilson Creek TMP p. 54)

The BLM's assertion that the increase in demand from mountain bikes in the Wilson Creek would cause herd distribution and displacement and therefore necessitates trail closure is not substantiated. The Wilson Creek TMP/EA states in several sections that impacts from biking have not caused undue stress on wildlife.

• "The impacts of mountain biking on various species of wildlife have been reported by some researchers to be comparable to or even less than those associated with hiking." p. 28
• BLM wild horse and burro specialists have noted that increases (or changes) in recreational use activities have caused wild horses to move out of heavy use areas to search for more isolated and secluded ranges or habitats, but little or no harmful effect on the horses occurred as long as those secluded habitats were available." p. 32
• However with the exception of the few orphaned foal incidents which occurred prior to 2000, no data exists to conclude that the wild horses currently found within the parking/staging and trails areas of Wilson Creek are being adversely impacted or forced into other isolated areas." p. 32
• Observations on March 10 and April 14, 2006 indicate that wild horses continue to use the foaling areas and winter range currently identified within both pastures 1 and 2 of the Reynolds Creek Allotment." p. 32
• In some cases, BLM specialists have observed incidence where wild horses were oblivious to the noise and pressure and little movement occurred where recreation activities existed." p. 32
• For example, Alan Shepard-BLM Wyoming Wild Horse and Burro State Program Lead is currently experiencing a case in the McCullough Peaks HMA where the wild horses are being faced with a heavy increase of visitor use by tour vans loaded with wild horse enthusiasts wanting to observe and photograph the wild horses found within this particular HMA, and the horses seem to be unaffected by the increase in traffic and noise." p. 33

As long as Horse Race Ridge, Solider Cap, Wilson Peak and other areas exist where horses can escape recreational impacts and the herd numbers remain above the 98 horses (as identified in the Owyhee Resource Management Plan p. 22) there is no reason to close the existing trails to mountain bikes in the areas between Stewart Gulch and Wilson Creek.

Before mountain bikes are removed from the trails the BLM should take a serious look at grazing management plans and removing grazing from the Steward Gulch drainage. The water trough and creek areas near the trail proposed for closure (under Alternative 3) looks like a bovine bomb has gone off. One wonders if the local cows have been making "Kool-aid" in the water trough and doing the hippy dance to Jerry Garcia in the tributary creating a nasty smelling bacteria laden mud bog.

In summary, the trails and road on Map 7 Alternative 3 that are between Steward Gulch and Wilson Creek should remain open to mountain bike use. In addition, the historic trails that BLM has failed to identify in this area should remain open until BLM does a follow up study to determine the baseline and "limits of acceptable change" as instructed by the Owyhee Resource Management Plan. Until a process had been developed which identifies what the "limits of acceptable change" are for wild horses, the areas should remain open to mountain biking. If areas of sensitive plants exist in the area, they should be clearly identified on the map and trails should be routed accordingly.

Comment pertaining to Alternatives 2 and 3: Designation of Beck and Caldwell ditches as hiking only is unacceptable.

Alternatives 2 and 3 should allow mountain biking as an historic recreational use on the Beck Caldwell ditch and Reynolds Creek. Table 2-3 of the Wilson Creek Travel Management Plan converts 4 miles of non-motorized route to hiking-only trails to preserve Historic and Cultural Resources. Again, the Wilson Creek TMP/EA provides no evidence as to why hiking is allowed and biking is excluded. There is no justification given to exclude mountain biking in the Wilson Creek Travel Management Plan. As pointed out above Section 3.102.2 of the Plan actually points out that mountain biking causes less erosion than hiking.

"The Marion study used for the Wilson Creek Travel Management Plan states, "that single use ATV and equestrian trails were significantly more degraded than hiking and biking trails. He found mean cross sectional area soil loss of ATV trails at each trail transect sample point was 246 inches squared; 150 inches squared for horse trails; 19 in squared for hiking trails; 6 inches squared for bike trails. The proportion of trails with severe erosion measured in the study (> inches deep) is 24% for ATV trails, 9% for horse trails, 1.4% for hiking trails, and 0.6% for bike trials." (Wilson Creek TMP p. 44) Since this section is technical and relatively flat, mountain bikers will not be traveling at high rates of speed and will not causing excessive erosion due to heavy braking. This study provides empirical evidence that mountain bikers cause the least amount of trail erosion and should not be excluded.

Because of meterologic events last year, the trail did experience some erosion. Since mountain bikers in the Treasure Valley have been heavily involved in trail development and maintenance they are the likely candidates in providing future trail improvements and maintenance to the Reynolds Creek area. As BLMs budget remains stagnant, it would be ashamed to exclude the user group that more than likely would provide the maintenance.

General Comments:

BLM should rethink the current locations of the parking areas. The developed parking area as identified on Map 4 will receive very little use due to odors and flies! Having parked in that area over 15-years ago I can say, one will only park there once before figuring out the stench and flies are overwhelming. Although I have no quantifiable evidence for this, my nose knows. This is purely subjective but I don't think many people will a want to share their beer and cheese with the bovine pie flies after a long trail ride.

As a trail user in the Wilson Creek area for well over 15 years, I find it disappointing that the BLM has continually neglected to take public input on the Wilson Creek area seriously. It is apparent that BLM staff has not taken input on historic uses. The Map 5 should identify undeveloped parking just northeast of the feedlots since that is where we have meet several times with past and current BLM staff as well as point this area out on a map during an office visit mentioned above.

It is also apparent that BLM overlooked many of the trails currently in use and are not identified on Maps 4 and 7. Many of these trails have been used for over 15 years and should remain open until there is some rational and justification (Baseline and Limits of Acceptable Change) on why they should be closed following the Owyhee Management Plans directive under Objective RECT2, Rational and Monitoring requirements. (Owyhee Management Plan p. 36)

It would be advisable for the BLM to develop a public outreach process that is open and apparent to recreational users. As one who would have gladly participated in discussions in January and February 2006 and again in March and April of 2006, I am disappointed that BLM made little effort to announce the meeting. Unfortunately after requesting numerous times via trips to BLM office and through personal e-mails, none of the people listed above have been notified of any meetings or this Plan. I found out about the plan from the Idaho section of the MTBR.com website. A website the BLM could or should have announced progress on the plan and invited participation. The BLM could have posted meeting announcements and the plan on areas but didn't. Instead, BLM rushed to develop the plan without fully developing a comprehensive plan as directed by the Owyhee Resource Management Plan and then allowed very little time to comment.

As an environmental professional, I would gladly participate in any studies the BLM wishes to conduct on conflicts between wild horses and mountain bikers. I am also confident most of the individual listed above would be willing to participate in future studies, since many of them work for environmental organizations or agencies. These individuals are more than willing to forgo recreational activities in areas that will cause adverse environmental impacts. That is why it is so disappointing that BLM has overlooked participants that were willing and able to make the tough personal decision on when their activities should be curtailed. Unfortunately, this plan does little to provide empirical information and will require additional work.

Although some of the above comments may seem harsh, the BLM is to be commended on taking on the tough issue of user conflicts between the recreational users. Over the last 3 seasons, there has been a steady increase in ATV use which has dramatically increased the degradation to single track trails and caused an increase in noise and erosion. If this plan does nothing more than address the problems associated with ATV use, great leaps in progress have been made.

In closing I would like to thank you for the opportunity to comment. I would also like to receive a copy of responses to comment and participate in any future discussions or meetings on this area.

Sincerely,

Mike Edwards,
 
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