DRAMP/RAMP Comments

Comments and discussion on the ISDRA Draft EIS and Draft Rec Area Mgt Plan

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DRAMP/RAMP Comments

Post by Sloppyduner » Mon Mar 29, 2010 11:22 am

So its that time to get comments ready. It was a bit ago when I was talking to people about the best way to word comments. As I remember just putting "that is a bad idea and I dissagree" is NOT the best way to comment. Stating WHY it is bad is a much better way to comment. Also if I remember right a blanket comment isn't the best idea either. What I will wait to do is look over others comments just incase I don't see something that is important to me.

Important thing I DO remember is if you don't comment on it in the public comment period you can not protest it later on. So I want to make sure I get in all the points that matter to me.

I would appreceate a Doc or Jerry, Vince, or another persons, take on "how to make our comment effective."
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Re: DRAMP/RAMP Comments

Post by Mean Green » Mon Mar 29, 2010 3:38 pm

Sloppyduner wrote:So its that time to get comments ready. It was a bit ago when I was talking to people about the best way to word comments. As I remember just putting "that is a bad idea and I dissagree" is NOT the best way to comment. Stating WHY it is bad is a much better way to comment. Also if I remember right a blanket comment isn't the best idea either. What I will wait to do is look over others comments just incase I don't see something that is important to me.

Important thing I DO remember is if you don't comment on it in the public comment period you can not protest it later on. So I want to make sure I get in all the points that matter to me.

I would appreceate a Doc or Jerry, Vince, or another persons, take on "how to make our comment effective."

I would also like to know the best way to submit logical and factual comments that will support our cause without hindering it. Is the ASA going to come up w/ some sort of guidance on this? I remember last time they were trying to implement the old RAMP they had a public meeting in Yuma and it seemed that a lot of the duners comments were based off of emotion not fact or science. I will do my best to make one of the meetings but I would like to have written comments submitted beforehand that are worthwhile and don't get disregarded. Thank you ASA for any help and direction on this.

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Re: DRAMP/RAMP Comments

Post by Jerry Seaver » Mon Mar 29, 2010 5:19 pm

For sure the BLM is now on the fast track with the Draft Recreation Area Management Plan (DRAMP). The ASA will come out with suggestions and Sloppyduner is correct that emotional responses don't do much good. As far as telling the BLM what you would like to see, that had to happen at the scoping meeting that were held in 2008. This time it is commenting on what they have written. Comments need to point out in the DRAMP something that they have mis-stated or haven't used good data to support the action that they are stating in the document. It's not good enough to say we don't agree with the data they used. We need to show were their data is wrong or there is other studies or data that wasn't taken in consideration, that doesn't support the position they have taken in the DRAMP. Sometimes the data is already listed in the DRAMP or the Draft Environmental Impact Statement (DEIS) and doesn't support the position taken in the Alternatives or the Preferred Alternative. Sometimes outside studies or data is necessary.

Their is a 90 day comment period and the best start on how to formulate a comment is to attend one of the public meeting if possible. They say they will start them with a presentation, you need to ask questions on what they consider a valid comment. Take the opportunity to go to the stations that they will set up and ask questions about the preferred Alternative and the other Alternatives to see how they are different. Keep in mind the big picture and how this management plan will be used for a mim. of the next ten years.

The BLM has scheduled the following public meetings:
Tuesday, April 13th – San Diego, CA
Handlery Hotel
950 Hotel Circle North
San Diego, CA 92108

Wednesday, April 14th – El Centro, CA
Imperial Irrigation District William R. Condit Meeting Room
1285 Broadway
El Centro, CA 92243

Thursday, April 15th – Phoenix, AZ
Mountain Preserve Reception and Conference Center
1431 E. Dunlap Avenue
Phoenix, AZ 85020

All meetings will run from 6:00pm – 9:00pm

After attending the meetings the ASA will have some information to share. The ASA has already started reviewing the Drafts but it is too early for us to start making too many comments at this time. One comment I will make, it is my opinion that in the preferred Alternative #8, having Dune Buggy Flats (Gordens Well) closed to camping to "provide extraordinary protection" of the PMV if it hits a rainfall of 1.82 inches during the months of Oct., Nov., and Dec. sets a very dangerous precedent. Using extraordinay means instead of just what is necessary is a concern of mine.

The RAMP is very important and I'm glad to see some people are concerned and willing to get involved.

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Re: DRAMP/RAMP Comments

Post by BHenry » Tue Mar 30, 2010 8:20 am

Thanks for the perspective Jerry. Is there anyway someone could videotape one of the meetings for those of us who will be unable to attend?
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Re: DRAMP/RAMP Comments

Post by Mean Green » Tue Mar 30, 2010 5:15 pm

Thanks, Mr. Seaver. I know I have sat on the sideline way too long on this and its seems now that I have a chance to get in the game I have done little or nothing to prepare myself for it. I don't know if my opinions/comments matter to the BLM but I will submit something (just need help). I am sure that this is the case for many other duners also. Any word on whether or not the Manufacturers (Yamaha, Can-Am, Honda, the Rail companies), and any other coalitions are going to organize a full court press on this? I know it is still early in the DRAMP process but it seems that we really don't have much time (90 Days) and with only three public comment meetings it seems that the powers that be really need to have their ducks in a row.

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Re: DRAMP/RAMP Comments

Post by ChuckZilla » Tue Mar 30, 2010 8:17 pm

Mean Green wrote:Thanks, Mr. Seaver. I know I have sat on the sideline way too long on this and its seems now that I have a chance to get in the game I have done little or nothing to prepare myself for it. I don't know if my opinions/comments matter to the BLM but I will submit something (just need help). I am sure that this is the case for many other duners also. Any word on whether or not the Manufacturers (Yamaha, Can-Am, Honda, the Rail companies), and any other coalitions are going to organize a full court press on this? I know it is still early in the DRAMP process but it seems that we really don't have much time (90 Days) and with only three public comment meetings it seems that the powers that be really need to have their ducks in a row.

Historically manufacturers have not taken prominent positions in land use battles or issues. The donations of vehicles for the purpose of fund raising raffles for various orgs is common, but that's about as far as it goes, typically.
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Re: DRAMP/RAMP Comments

Post by Mean Green » Tue Mar 30, 2010 9:18 pm

ChuckZilla wrote:
Mean Green wrote:Thanks, Mr. Seaver. I know I have sat on the sideline way too long on this and its seems now that I have a chance to get in the game I have done little or nothing to prepare myself for it. I don't know if my opinions/comments matter to the BLM but I will submit something (just need help). I am sure that this is the case for many other duners also. Any word on whether or not the Manufacturers (Yamaha, Can-Am, Honda, the Rail companies), and any other coalitions are going to organize a full court press on this? I know it is still early in the DRAMP process but it seems that we really don't have much time (90 Days) and with only three public comment meetings it seems that the powers that be really need to have their ducks in a row.

Historically manufacturers have not taken prominent positions in land use battles or issues. The donations of vehicles for the purpose of fund raising raffles for various orgs is common, but that's about as far as it goes, typically.
Agreed. However, as of late it seems that more and more of the manufacturers are stepping up to the plate and are donating time, money and resources to keep riding areas open. Two examples that come to mind are Yamaha and Polaris. They have been giving millions of dollars in grants to keep OHV riding areas open and accessible to the OHV community. They have also supported in upgrading and maintaining trails on public lands for OHV use. It would be nice to see them pump some serious support into the ISDRA. I know Yamaha has been out at Glamis with their full factory OHV lineup offering Demo Rides to the public and sponsoring weekend events at the ISDRA. I am not trying to open up a can of worms just saying that the manufacturers have realized that if we don't have anymore open riding areas then they don’t have any more business. I know that I am preaching to the choir on this. Sorry for being long winded.

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Re: DRAMP/RAMP Comments

Post by DuneRookie » Wed Mar 31, 2010 3:47 pm

I don't need details but please tell me that our legal council is also reviewing this for an official response. :?:

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Re: DRAMP/RAMP Comments

Post by Doc » Wed Mar 31, 2010 3:52 pm

DuneRookie wrote:I don't need details but please tell me that our legal council is also reviewing this for an official response. :?:
Absolutely

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Re: DRAMP/RAMP Comments

Post by PWR MAD » Thu Apr 01, 2010 11:27 am

Please forgive me if it's already been posted, a quick search revealed nothing I could use. Is there a template of sorts to use for comments at the upcoming meetings or to be sent in to the BLM for those of us who aren't quite eloquent in public speaking? Any help would be much appreciated.

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Re: DRAMP/RAMP Comments

Post by Doc » Thu Apr 01, 2010 12:22 pm

PWR MAD wrote:Please forgive me if it's already been posted, a quick search revealed nothing I could use. Is there a template of sorts to use for comments at the upcoming meetings or to be sent in to the BLM for those of us who aren't quite eloquent in public speaking? Any help would be much appreciated.

The ASA will have some formats and instructions for generating quality comments.

We are working on that now and should have the templates available soon.

For now you should read the document making notes of things you think should be changed and how they should be changed. I have found that some of my questions were answered later in reading the document.

It is important to have reasonable solutions to your concerns. Just saying you don't like something without an alternative will not be very effective.

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Re: DRAMP/RAMP Comments

Post by PWR MAD » Fri Apr 02, 2010 6:27 am

I have been reading it, but must admit I'm not of the legal and/or scientific mind set to be able to decipher it all to my satisfaction. I thought perhaps those that are much brighter than I wouldn't mind sharing their thoughts, perhaps I was mistaken. Please forgive my ignorance, I will try harder in reading it again.

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Re: DRAMP/RAMP Comments

Post by gelwell » Fri Apr 02, 2010 9:13 am

The BLM has changed the meetings days here is the new schedule:

Tuesday, April 22nd (6pm to 8pm)
Handlery Hotel
950 Hotel Circle North
San Diego, CA 92108
(619) 398-8333

Wednesday, April 23rd (6pm to 8pm)
Mountain Preserve Reception and Conference Center
1431 E. Dunlap Avenue
Phoenix, AZ 85020
(602) 943 – 2656

Thursday, April 24th (6pm to 8pm)
Imperial Irrigation District William R. Condit Meeting Room
1285 Broadway
El Centro, CA 92243
(760) 339-9422

I just got this off the website today. Please plan accordingly. We need to have a large presence at these meetings and voice your preference to the plan and alternate.
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Re: DRAMP/RAMP Comments

Post by Rick Bowen » Fri Apr 02, 2010 9:16 am

The days and date do not align (Tuesday April 22nd?). Should that be Tuesday April 20th and so on?
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Re: DRAMP/RAMP Comments

Post by WoodIsGood » Fri Apr 02, 2010 9:31 am

gelwell wrote:The BLM has changed the meetings days here is the new schedule:
.
(snip)
.
I just got this off the website today. Please plan accordingly. We need to have a large presence at these meetings and voice your preference to the plan and alternate.
Not sure where on the BLM website you saw that, but here it still lists the meetings as April 13, 14, and 15.

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Re: DRAMP/RAMP Comments

Post by Doc » Fri Apr 02, 2010 10:35 am

gelwell wrote:The BLM has changed the meetings days here is the new schedule:

Tuesday, April 22nd (6pm to 8pm)
Handlery Hotel
950 Hotel Circle North
San Diego, CA 92108
(619) 398-8333

Wednesday, April 23rd (6pm to 8pm)
Mountain Preserve Reception and Conference Center
1431 E. Dunlap Avenue
Phoenix, AZ 85020
(602) 943 – 2656

Thursday, April 24th (6pm to 8pm)
Imperial Irrigation District William R. Condit Meeting Room
1285 Broadway
El Centro, CA 92243
(760) 339-9422

I just got this off the website today. Please plan accordingly. We need to have a large presence at these meetings and voice your preference to the plan and alternate.

Those were the dates of the 2008 scopeing meetings.

The meetings are still the 13th - 14th and 15th as scheduled.

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Re: DRAMP/RAMP Comments

Post by sticksand » Tue Apr 06, 2010 10:23 am

How can the dunes be used for geothermal energy?? Are they going to put solar panels right in the center of a bowl??
The wind would rake havoc on the panels the sand shifts so much I have no Idea how they would be held up in the sand.

I don't like the way this is looking. Can some one clue me in on why the ISDRA is a good place for Geothermal Energy
BRRRRAAAAAP!!

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Re: DRAMP/RAMP Comments

Post by Doc » Tue Apr 06, 2010 10:55 am

sticksand wrote:How can the dunes be used for geothermal energy?? Are they going to put solar panels right in the center of a bowl??
The wind would rake havoc on the panels the sand shifts so much I have no Idea how they would be held up in the sand.

I don't like the way this is looking. Can some one clue me in on why the ISDRA is a good place for Geothermal Energy
Some of the alternatives have a component for geothermal leasing and others do not.

The preferred alternative does not allow Geothermal, solar or wind leasing. While there are some issues with other aspects of the preferred alternative it does not allow any renewable leasing in the dunes proper.

In order for this RAMP to get through the courts the BLM has to address all the possible scenarios that will affect the area even if they are something that has a very low probability of happening.

There are probably geothermal resources below the dunes and there are geothermal plants to the west of the dunes in the east mesa. There are hot springs in the east mesa so there are many geothermal resources in the area.

In reality the dunes would not support renewable development for many reasons not the least of which has been mentioned and that is the poor surface topology which would make development cost prohibitive

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Re: DRAMP/RAMP Comments

Post by sticksand » Tue Apr 06, 2010 11:12 am

Thank you education is the key
BRRRRAAAAAP!!

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Re: DRAMP/RAMP Comments

Post by Woodglue » Tue Apr 06, 2010 12:12 pm

I can see our CBD friends leasing the sand for Geothermal and Wind or Solar and putting a fence around the land and never using it.
I can see Geothermal companies leasing the sand and put a fence around the land to reserve it for use in the future.
For this reason Geothermal is BAD :evil:
For this reason Alts 1,2,4 & 7 are BAD! :evil: Geothermal Leasing in ALL the ISDRA
For this reason, Alts 5 & 6 are BAD! :evil: Geothermal Leasing over Oldsmobile area between Gecko and Wash Rd.

For the reason of Massive OHV closures, Alt 3 is BAD! :evil: (refer to my Avatar & Signature)

For the reason of closed camping areas, Alt 8 is BAD! :evil:

...sitting here trying to figure out which end of a short stick I want... the BLM has done our community a HUGE DISSERVICE by proposing these 8 alternatives!!!

](*,)
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Re: DRAMP/RAMP Comments

Post by sticksand » Tue Apr 06, 2010 12:37 pm

I think I already know the answer to this but can the ASA's legal team write an alternative??? or just the BLM???
BRRRRAAAAAP!!

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Re: DRAMP/RAMP Comments

Post by Woodglue » Tue Apr 06, 2010 12:52 pm

sticksand wrote:I think I already know the answer to this but can the ASA's legal team write an alternative??? or just the BLM???
[-o< Alternative number 9! =D>
Take the Geothermal access of Alt 8 and Combine it with the OHV and Camping access of Alt 2.

That's pretty much what we have on the ground out there right now!
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Re: DRAMP/RAMP Comments

Post by Doc » Tue Apr 06, 2010 1:19 pm

Woodglue wrote:
sticksand wrote:I think I already know the answer to this but can the ASA's legal team write an alternative??? or just the BLM???
[-o< Alternative number 9! =D>
Take the Geothermal access of Alt 8 and Combine it with the OHV and Camping access of Alt 2.

That's pretty much what we have on the ground out there right now!
Why in the world would you want to keep the closures that are Alt. 2. That is what we have been working to get rid of for 10 years. The CBD would just love to make these closures permanent. That is what they have proposed numerous times to us and we have always said no to that.

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Re: DRAMP/RAMP Comments

Post by Doc » Tue Apr 06, 2010 1:21 pm

Woodglue wrote:I can see our CBD friends leasing the sand for Geothermal and Wind or Solar and putting a fence around the land and never using it.
I can see Geothermal companies leasing the sand and put a fence around the land to reserve it for use in the future.
For this reason Geothermal is BAD :evil:
For this reason Alts 1,2,4 & 7 are BAD! :evil: Geothermal Leasing in ALL the ISDRA
For this reason, Alts 5 & 6 are BAD! :evil: Geothermal Leasing over Oldsmobile area between Gecko and Wash Rd.

For the reason of Massive OHV closures, Alt 3 is BAD! :evil: (refer to my Avatar & Signature)

For the reason of closed camping areas, Alt 8 is BAD! :evil:

...sitting here trying to figure out which end of a short stick I want... the BLM has done our community a HUGE DISSERVICE by proposing these 8 alternatives!!!

](*,)

Do a little research on the ability and costs to lease areas for renewable resources. No one is going to lease land and sit on it. For one they have to develop it within a certain time frame and go through the NEPA process. The cost to some of the solar projects I have been following are in the millions of dollars to just start the process. The list of approvals to even start the process is staggering and only very well funded companies will attempt a renewable project in California.

For the RAMP process to be successful the BLM has to be able to get a favorable biological opinion as well as get this through the courts so they have to have a range of alternatives. Without a full range of alternatives the courts will say they did not look at enough different alternatives and to go back and look at some more. This was one of the issues with the 2003 RAMP that was invalidated by the court.

As for another alternative this is exactly what your comments need to focus on. You need to present good data on why an item should not be in the plan and what the alternative to that should be. There probably will be a plan 9 and it will encompass parts of all these. It just has to be defendable to the court and to the FWS.

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Re: DRAMP/RAMP Comments

Post by Woodglue » Tue Apr 06, 2010 1:53 pm

Doc wrote: No one is going to lease land and sit on it. For one they have to develop it within a certain time frame and go through the NEPA process. The cost to some of the solar projects I have been following are in the millions of dollars to just start the process. The list of approvals to even start the process is staggering and only very well funded companies will attempt a renewable project in California.
Regardless of IF the leased land will be used or not, I personally am not in favor of having any Geothermal access granted to the ISDRA. And, I would not like to see the ASA endorsing Alternative's 1,2,4 or 7 (in it's current form) for this reason.

I do understand that the RAMP needs to to encompass all of the options of use for the land. That said, I still do not want to see any GeoThermal wind or Solar access granted in our RAMP. I agree that it's unlikely that a wind or solar farm would be built on a sand dune, but I don't want there to even be the option for such an occurance to take place in the future! [-(
Doc wrote: It just has to be defendable to the court and to the FWS.
This is a bit daunting, but I think 'we' are up for it.
The most realistic ideal for Alt 9 (for me) would be Alt 8 ammended as follows:
:arrow: to allow camping Wash25 to Wash69 and,
:arrow: to allow camping North of Grays Well.
:arrow: to allow the closure around the Critical Habitat in Alt 8 (ref map 2-26) to take on a more realistic rectangular shape. This will allow duners on the ground to better understand where the closure is and isn't located.

Contesting the reasoning behind this would require why the BLM wants the camps closed.
Now, I have not yet found why these camping areas are being closed off. Maybe I just havn't reached that point in the DRAMP yet, but I'm starting to wonder if it's there.
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Re: DRAMP/RAMP Comments

Post by Mean Green » Tue Apr 06, 2010 9:14 pm

Some food for thought....and I know this is one very small aspect of the entire DRAMP but how can the BLM even consider getting any of the other alternatives through the court(s) when only Alternatives 3,5, and 8 prohibit motorized use within the PMV Critical Habitat (Chapter 2, Table 2-5, P. 2-29)? To me, that would mean these are the only three alternatives that have the potential to be implemented by the court(s) and 3 is definately not an option for the duning community.

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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 07, 2010 8:40 am

Thanks for bringing your thoughts here Mr. Green. I'd like to see more doing the same.
I see what you're talking about as Table 2-5 spells is out plain and simple. I beliee there are certain things like this (motorized use in PMVCH, Geothermal Access, etc) that are intentionally laced into all the Alternatives to get 'us' and 'them' to gravitate towards the BLM preferred Alt 8.
Mean Green wrote:...only Alternatives 3,5, and 8 prohibit motorized use within the PMV Critical Habitat (Chapter 2, Table 2-5, P. 2-29)
Alt 3, forget about it.
Alt 5 is very similar to Alt6. Olds swath of land between gecko & wash road is granted Geothermal access. However Alt 5 closes portions of the South Dunes including Patton Valley where Alt 6 keeps these open.
Alt 8 is nice but it closes a lot of camping area.
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Wed Apr 07, 2010 10:14 am

Mean Green wrote:Some food for thought....and I know this is one very small aspect of the entire DRAMP but how can the BLM even consider getting any of the other alternatives through the court(s) when only Alternatives 3,5, and 8 prohibit motorized use within the PMV Critical Habitat (Chapter 2, Table 2-5, P. 2-29)? To me, that would mean these are the only three alternatives that have the potential to be implemented by the court(s) and 3 is definately not an option for the duning community.
Well, now, this is a question I can actually answer.

All those ‘alternatives’ are in there so the BLM, hopefully, won’t lose another lawsuit from either the Eco’s or the OHV community. One of major reasons the last RAMP was thrown out was because the CBD sued, claiming that the BLM did not consider the current ‘Temporary Closure’ as an ‘alternative’. Judge Illston agreed with them. So now the BLM has gone overboard, listing quite a range of alternatives, to ‘fix’ that part of the RAMP. Yes, it is obvious that several of those, if chosen, would not survive in court. Opening everything back up is one. The Eco-Nazis will sue. And most likely win. Closing it all down is another. The OHV’ers will sue. And most likely win.

An alternative that can be shown as a workable compromise is what will survive in court. Remember, this RAMP is not just a management plan, it also must survive a court challenge.
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Re: DRAMP/RAMP Comments

Post by gelwell » Wed Apr 07, 2010 4:38 pm


Well, now, this is a question I can actually answer.

All those ‘alternatives’ are in there so the BLM, hopefully, won’t lose another lawsuit from either the Eco’s or the OHV community. One of major reasons the last RAMP was thrown out was because the CBD sued, claiming that the BLM did not consider the current ‘Temporary Closure’ as an ‘alternative’. Judge Illston agreed with them. So now the BLM has gone overboard, listing quite a range of alternatives, to ‘fix’ that part of the RAMP. Yes, it is obvious that several of those, if chosen, would not survive in court. Opening everything back up is one. The Eco-Nazis will sue. And most likely win. Closing it all down is another. The OHV’ers will sue. And most likely win.

An alternative that can be shown as a workable compromise is what will survive in court. Remember, this RAMP is not just a management plan, it also must survive a court challenge.
Or give up a little piece of the elephant until the next lawsuit. It cant be what we had or else suit or it cant be all closed or lawsuit. So compromise and give up more riding area one bite at a time until the next eco-nazi suit.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 07, 2010 4:59 pm

I spent most of the day reading the DRAMP... and I'm still trying to find out why Alt8 is closing the camping areas.
Woodglue wrote:Contesting the reasoning behind this would require why the BLM wants the camps closed.
Now, I have not yet found why these camping areas are being closed off. Maybe I just havn't reached that point in the DRAMP yet, but I'm starting to wonder if it's there.
I'm still wondering. :?
If anyone has found this, please point me in the right direction.
Thanks,
-M.
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Re: DRAMP/RAMP Comments

Post by WoodIsGood » Wed Apr 07, 2010 5:48 pm

Mean Green wrote:Some food for thought....and I know this is one very small aspect of the entire DRAMP but how can the BLM even consider getting any of the other alternatives through the court(s) when only Alternatives 3,5, and 8 prohibit motorized use within the PMV Critical Habitat (Chapter 2, Table 2-5, P. 2-29)? To me, that would mean these are the only three alternatives that have the potential to be implemented by the court(s) and 3 is definately not an option for the duning community.
I'd have to argue that PMV critical habitat and OHV use need not be mutually exclusive. Maybe I missed something, but I've never seen it officially stated that the management plan must exclude OHV use in the PMV CH. Yes, the habitat is critical to the survival of the PMV, but if leaving it open to OHV use does not have significant detrimental effects on the PMV there's no reason to close it. Certainly the greens want it closed, but that's not necessarily what they should get.

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Re: DRAMP/RAMP Comments

Post by Mean Green » Wed Apr 07, 2010 6:08 pm

Woodglue wrote:I spent most of the day reading the DRAMP... and I'm still trying to find out why Alt8 is closing the camping areas.
Woodglue wrote:Contesting the reasoning behind this would require why the BLM wants the camps closed.
Now, I have not yet found why these camping areas are being closed off. Maybe I just havn't reached that point in the DRAMP yet, but I'm starting to wonder if it's there.
I'm still wondering. :?
If anyone has found this, please point me in the right direction.
Thanks,
-M.
Woodglue,
I don't know if this section really outlines the answer to your question but it is all that I can find as of now.

Chapter 4, P 4-65 (4.14 Impacts on Recreation Program)

Management of special status species could affect recreation through habitat improvements and land-use restrictions. Controlling surface-disturbing and disruptive activities to minimize adverse impacts on critical habitat, applying BMP to avoid or reduce habitat fragmentation, and prohibiting surface-disturbing activities within occupied and suitable habitat would all help to improve ecosystem conditions and the aesthetic values of these areas. Such actions could indirectly enhance the recreation experience for those seeking natural landscapes by improving the setting in which non-motorized recreational activities take place. Such actions, however, could also constrain the development of recreation facilities, as well as diminish OHV recreational experience and opportunity.

4.14.1 Differences between Alternatives

Motorized camping opportunities would be increased or decreased by alternative, depending on the location of closed OHV management areas and campground closures in the microphyll woodlands as well as the Dunebuggy Flats campground closure when rainfall thresholds for PMV are met. The closure of certain OHV management areas would likely result in the displacement of visitors and adversely impact their experience. Potential campground closures would have a direct adverse impact on visitors in areas where overcrowding could occur due to displaced visitor migration within the Planning Area. Other displaced visitors could be more likely to seek alternative recreation opportunities outside the Planning Area. Under Alternatives 1, 2, 4, 5, 6, and 7, camping would continue to be allowed within the microphyll woodlands between SR 78 and I-8, and within the Dunebuggy Flats campground. Under Alternative 3, there would be the potential for campgrounds in the Dunebuggy Flats and Gecko areas to be closed. Under Alternative 8, campgrounds south of Wash 25 and north of Wash 69, as well as the Dunebuggy Flats campground would be closed to camping but open to OHV use.

And…Under Alternative 8, the closure of the Dunebuggy Flats campground may lead to the need for development of additional recreational facilities in surrounding campgrounds to accommodate displaced visitors.
An increase or decrease in travel routes

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Re: DRAMP/RAMP Comments

Post by ChuckZilla » Wed Apr 07, 2010 6:42 pm

Being a Gordons regular, option #8 could affect me should rainfall totals reach the prescribed amount. Since rainfall is what is being recognized as a major determiner for PMV germination, my question is, if especially heavy rainfalls produce a very large germination event throughout the dunes, is it written into the plan that a prescribed number of PMV living within the dunes would make the Dune Buggy Flats rainfall closure moot? More simply, if we get a germination event that yields 5 times the average number of PMV for a given year, is it still necessary to close DBF's?
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Re: DRAMP/RAMP Comments

Post by Vincent J Brunasso » Wed Apr 07, 2010 7:01 pm

WoodIsGood wrote:I'd have to argue that PMV critical habitat and OHV use need not be mutually exclusive. Maybe I missed something, but I've never seen it officially stated that the management plan must exclude OHV use in the PMV CH. Yes, the habitat is critical to the survival of the PMV, but if leaving it open to OHV use does not have significant detrimental effects on the PMV there's no reason to close it. Certainly the greens want it closed, but that's not necessarily what they should get.
Some things to consider:
1) There's no science to support closing the PMV CH - studies show it grows more densely in open OHV areas. PMV in the currently open areas are doing as well as, if not better than, the PMV in the currently closed areas.
2) There's no legal requirement that CH must be closed to OHV activity.
3) Many CH's across the country remain open to OHV activity with little effect to the species in it.
4) Studies at the ISDRA that are quoted numerous times in the DRAMP state that less than 1% of the PMV are damaged by OHV activities.
5) PMV grows where it is unpleasant to operate an OHV. Generally, we don't ride in the depressions where it grows.
6) It is easy to spot and avoid: especially when it is flowering.
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Re: DRAMP/RAMP Comments

Post by Mean Green » Wed Apr 07, 2010 8:00 pm

Thank you Vincent and Wood for clearing that up for me. I did not know that it was possible to allow motorized use in CH for the PMV.

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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 8:16 am

Mean Green wrote:
Woodglue wrote:I spent most of the day reading the DRAMP... and I'm still trying to find out why Alt8 is closing the camping areas.
Woodglue wrote:Contesting the reasoning behind this would require why the BLM wants the camps closed.
Now, I have not yet found why these camping areas are being closed off. Maybe I just havn't reached that point in the DRAMP yet, but I'm starting to wonder if it's there.
I'm still wondering. :?
If anyone has found this, please point me in the right direction.
Thanks,
-M.
Woodglue,
I don't know if this section really outlines the answer to your question but it is all that I can find as of now.

Chapter 4, P 4-65 (4.14 Impacts on Recreation Program)

Management of special status species could affect recreation through habitat improvements and land-use restrictions. Controlling surface-disturbing and disruptive activities to minimize adverse impacts on critical habitat, applying BMP to avoid or reduce habitat fragmentation, and prohibiting surface-disturbing activities within occupied and suitable habitat would all help to improve ecosystem conditions and the aesthetic values of these areas. Such actions could indirectly enhance the recreation experience for those seeking natural landscapes by improving the setting in which non-motorized recreational activities take place. Such actions, however, could also constrain the development of recreation facilities, as well as diminish OHV recreational experience and opportunity.

4.14.1 Differences between Alternatives

Motorized camping opportunities would be increased or decreased by alternative, depending on the location of closed OHV management areas and campground closures in the microphyll woodlands as well as the Dunebuggy Flats campground closure when rainfall thresholds for PMV are met. The closure of certain OHV management areas would likely result in the displacement of visitors and adversely impact their experience. Potential campground closures would have a direct adverse impact on visitors in areas where overcrowding could occur due to displaced visitor migration within the Planning Area. Other displaced visitors could be more likely to seek alternative recreation opportunities outside the Planning Area. Under Alternatives 1, 2, 4, 5, 6, and 7, camping would continue to be allowed within the microphyll woodlands between SR 78 and I-8, and within the Dunebuggy Flats campground. Under Alternative 3, there would be the potential for campgrounds in the Dunebuggy Flats and Gecko areas to be closed. Under Alternative 8, campgrounds south of Wash 25 and north of Wash 69, as well as the Dunebuggy Flats campground would be closed to camping but open to OHV use.

And…Under Alternative 8, the closure of the Dunebuggy Flats campground may lead to the need for development of additional recreational facilities in surrounding campgrounds to accommodate displaced visitors.
An increase or decrease in travel routes
Thanks Mr. Green.
This is getting closer, but I still don't read the reason "Why".
I'll continure my Where's Waldo game today.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 8:24 am

Vincent J Brunasso wrote:
WoodIsGood wrote:I'd have to argue that PMV critical habitat and OHV use need not be mutually exclusive. Maybe I missed something, but I've never seen it officially stated that the management plan must exclude OHV use in the PMV CH. Yes, the habitat is critical to the survival of the PMV, but if leaving it open to OHV use does not have significant detrimental effects on the PMV there's no reason to close it. Certainly the greens want it closed, but that's not necessarily what they should get.
Some things to consider:
1) There's no science to support closing the PMV CH - studies show it grows more densely in open OHV areas. PMV in the currently open areas are doing as well as, if not better than, the PMV in the currently closed areas.
2) There's no legal requirement that CH must be closed to OHV activity.
3) Many CH's across the country remain open to OHV activity with little effect to the species in it.
4) Studies at the ISDRA that are quoted numerous times in the DRAMP state that less than 1% of the PMV are damaged by OHV activities.
5) PMV grows where it is unpleasant to operate an OHV. Generally, we don't ride in the depressions where it grows.
6) It is easy to spot and avoid: especially when it is flowering.
This is good stuff Vince. I'd like to include some of it in my formal comment to BLM. To do so, I'm thinking we need to reference the studies. Do you have this available?
In regards to item #5, I've witnessed much PMV growing in open OHV areas on the gradually sloping face (usually on the Eastern face) of a bowl where the bottom of the bowl is to the West with a inclining slip face beyond that to the West.

It's a little sad to learn that studies show PMV grows more densely in open OHV areas. I guess I imagined finding fields of purple PMV flowers when the closure was opened up. Kind of makes one ask what these closures have been all about... :?
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Re: DRAMP/RAMP Comments

Post by sticksand » Thu Apr 08, 2010 11:43 am

were in the DRAMP does is state that less than 1% of the PMV are damaged by OHV activities??

I'll point that out in the meeting in phoenix...
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 12:13 pm

sticksand wrote:
Vincent J Brunasso wrote:4) Studies at the ISDRA that are quoted numerous times in the DRAMP state that less than 1% of the PMV are damaged by OHV activities.
were in the DRAMP does is state that less than 1% of the PMV are damaged by OHV activities??

I'll point that out in the meeting in phoenix...
I don't think Vince was saying that was stated in the DRAMP, rather it's stated in one of the "Studies ... that are quoted numerous times in the DRAMP".

That said, it would be nice to point at this study in our comments. Hence my earlier post to Vince.
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Re: DRAMP/RAMP Comments

Post by Vincent J Brunasso » Thu Apr 08, 2010 12:49 pm

sticksand wrote:were in the DRAMP does is state that less than 1% of the PMV are damaged by OHV activities??

I'll point that out in the meeting in phoenix...
Dowload the DRAMP Vol II PDF - do a search on "less than" - it will bring up 3 instances.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 2:06 pm

=D> Thanks Vince!
Pages H-2, H-3 and H-6 in Appendix H have it!
This is a nice bullet to have in the arsenal.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 2:34 pm

Woodglue wrote:I spent most of the day reading the DRAMP... and I'm still trying to find out why Alt8 is closing the camping areas.
Woodglue wrote:Contesting the reasoning behind this would require why the BLM wants the camps closed.
Now, I have not yet found why these camping areas are being closed off. Maybe I just havn't reached that point in the DRAMP yet, but I'm starting to wonder if it's there.
I'm still wondering. :?
If anyone has found this, please point me in the right direction.
Thanks,
-M.
Found it on Page E-1 of Appendix E:
"The Preferred Alternative (Alternative 8) for recreation management includes several components: complete (100%) closure of PMV critical habitat to OHV recreation, a camping closure on the east side of the Planning Area to protect microphyll woodland habitats"
Now, I assume there must be evidence that "camping" harms the microphyll woodland habitat?
I think I've been camping in the microphyll woodland habitat for the last 10 years (in Wash10 and now in Wash24) and I can argue that "camping" does not harm the microphyll woodland habitat.
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Re: DRAMP/RAMP Comments

Post by sticksand » Thu Apr 08, 2010 2:36 pm

Can we get the PMV seed count study published on this site so Meeting goers can reference "best science" out there??
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Re: DRAMP/RAMP Comments

Post by sticksand » Thu Apr 08, 2010 2:49 pm

Here is a quote from page H-2 in the DRAMP (PDF Page #113)

In 2004, an estimated 286,374 PMV plants were found within seven management areas of the ISD SRMA. The estimated density of PMV was 13.5 plants/hectare. Densities were highest in the Ogilby and Gecko areas, with few plants found in the Buttercup and Mammoth Wash areas. As seen in 2003, the majority of plants encountered in 2004 were seedlings and juveniles (94 percent). Fewer plants were observed in the WA and Gecko areas in 2004 than in 2003, despite similar rainfall amounts and timing of surveys. The patterns seen in 2003 and 2004 were very different from those seen in previous years (1998 to 2002 monitoring). It was suspected that higher temperatures during germination than experienced in 2003 may account for the difference. Less than 1 percent of the PMV plants found showed evidence of vehicle damage (likely OHV) (BLM 2005d).

What are the seven management areas of the ISD...? is that the camp ares Buttercup, Gordons ECT.....
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 3:04 pm

I found this on GlamisOnLine:
PMV Report - June 2001

The May 2002 PMV Seed Bank Study link has been broken. :?

Looking in the Document Library on ASA's Website didn't find anything. :?
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 3:17 pm

sticksand wrote: What are the seven management areas of the ISD...? is that the camp ares Buttercup, Gordons ECT.....
I recall a map, wherin the ISDRA was broken into approx equal zones.
Without knowing where these 7 areas are, you can safely assume "an estimated 286,374 PMV plants were found within the ISD SRMA"
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Re: DRAMP/RAMP Comments

Post by Jerry Seaver » Thu Apr 08, 2010 3:20 pm

Here's some info on the PMV monitoring that ASA and BLM did. http://www.americansandassociation.org/ ... ?pageid=27

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Re: DRAMP/RAMP Comments

Post by sticksand » Thu Apr 08, 2010 3:39 pm

Um sorry to keep posting but is Dr.Phillips going to any of these meetings???
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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 3:58 pm

sticksand wrote:Um sorry to keep posting but is Dr.Phillips going to any of these meetings???
Concurrently, how about ORBA, CORVA, AMA 37, SDORC and California Association of 4WD Clubs?
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Re: DRAMP/RAMP Comments

Post by GlamisSandDuner » Thu Apr 08, 2010 4:19 pm

Woodglue wrote:
sticksand wrote:Um sorry to keep posting but is Dr.Phillips going to any of these meetings???
Concurrently, how about ORBA, CORVA, AMA 37, SDORC and California Association of 4WD Clubs?
They should attend their local meeting if the ASA financially supports their organization

If they don't show up and the ASA does support them, I think the ASA would then have to take another look at which outside organizations to support :-k
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