SAGE RIDERS MOTORCYCLE CLUB
oRESPONSE TO ALTERNATIVE E
oWILDERNESS CHARACTERISTICS DOCUMENTATION
November 22, 2007
EMERY/CARBON COUNTYPRICE BLM FIELD OFFICE
Lost Springs Wash
Never Sweat Wash
Eagle Canyon
Molen Reef
South Horn Mountain
Price River
San Rafael Reef
Muddy River-Crack Canyon
Desolation Canyon
Prepared by:
Wade Allinson, Sage Riders Public Lands Officer
Alan Peterson, Sage Riders Information Officer
Scott Wheeler, Club Member
Other members and associates
SAGE RIDERS MOTORCYCLE CLUB
PO BOX 585
FERRON, UTAH
84523
435-384-2711
Roger Bankert November 18, 2007
BLM Field Director
Price Field Office
COMMENTS CONCERNING ALTERNATIVE E
Roger,
WHY COMMENTS DIRECTED TO ROGER BANKERT
The Sage Rider’s Motorcycle Club is directing our comments directly to your attention. It has been our past experience that the data we have submitted concerning the RMP process has been misplaced or unable to be located.
DATA PROVIDED TO BE OUTLINED IN THIS DOCUMENT
We feel that the data that we are submitting is evidence of the noticeable impact and nature of human imprints that affect the wilderness characteristics as proposed in the areas that will be submitted within this document.
This report will contain our club position on Alternative E and comprehensive analysis of the WCs (Wilderness Characteristics) and travel routes that are contained in Alternative E. We feel that the data provided herein will be of most benefit in assisting the BLM in providing a manageable alternative for the Price Field Office. With our input we feel that the resource can be protected while providing a variety of opportunities for both recreation and economic reasons. Both of which are vital to the sustaining of our local economy.
The Sage Riders Motorcycle Club has spent hundreds of hours on the ground gathering documented facts that impact the wilderness character as described in the Wilderness Act and BLM Instructional Memorandum 2003-275.
SAGE RIDERS MOTORCYCLE CLUB INFORMATION
The Sage Riders Motorcycle Club (SRMC) is composed of members from throughout the State of Utah. The SRMC was founded in 1980. Some members are residents of Carbon or Emery Counties. The SRMC has a Volunteer Agreement with the Price Field Office for maintenance of singletrack trails in Emery County. These include The Waterfall Trail, Five Miles of Hell and The Temple Mountain Motorcycle Trail System. The SRMC are very active in maintenance, monitoring and protection of the current single track trail system as designated in the San Rafael Travel Plan 2003.
The SRMC holds at least two off road competitive events (races) annually. The SRMC has a vested interest in the lands administered by Price Field Office in that we have received Special Recreation Permits (SRP) to hold races specifically within the Never Sweat and Lost Springs Wash areas. These are both "Citizen Proposed Wilderness Characteristic Areas". SRMC has held races in these areas since1982 with each race having been issued a SRP by the Price Field Office. In addition to the Environmental Analysis (EA) done by Price Field Office for each of these events, the SRMC also hired a BLM approved Archaeological Firm to conduct Level III Cultural & Archeological Inventories in both of these areas. The cumulative sum paid to the firm (Baseline Data) by SRMC & Bookcliff Rattlers M/C was $30,000.00. As you can see, we have a vested interest in these areas and plan to continue promoting off road events as we have done for the last 25 years.
CLUB OPINION IN REGARDS TO LANDS WITH WILDERNESS CHARACTERISTICS
Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. Congress instructed the agency to inventory all of their lands, identify which were definitely not of wilderness quality and then to begin an intensive inventory and analysis to determine which of the remaining lands would be recommended for inclusion into the National Wilderness Preservation System.
The process was completed in 1991. All stakeholders (including Wilderness Advocacy Groups) have exhausted the protest and appeal options. After 10 years the "603 Process" left Utah with approximately 3.2 million acres designated as Wilderness Study Areas. Of those, approximately 1.9 million acres were deemed "suitable and manageable" and were recommended to Congress for Wilderness designation. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for inclusion in the National Wilderness Preservation System, subject to existing uses.
There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
When formulating land use plans and considering opportunities for solitude and unconfined recreation, the BLM must consider all other resource values and uses and attempt to balance the competing uses and values using the Multiple Use/Sustained Yield paradigm.
CLUB POSITION ALTERNATIVE E
The Sage Riders Motorcycle Club does not support Alternative E. As previously stated the Sage Riders supports Alternative D with the trail system as provided by this club to the BLM.
The WCs as proposed in the South Horn Mountain, Molen Reef, Eagle Canyon, Never Sweat Wash, Lost Springs Wash, Price River, San Rafael Reef, Muddy Creek-Crack Canyon and Desolation Canyon are not substantiated on the ground as proposed in Alternative E. The documentation and evidence of this will be included in this document.
The Never Sweat Wash WC and the Lost Spring WC as proposed in Alternative E contains several roads, 52 inch trail and single track trail systems, referred to as the “Chimney Rock Trail System”. A comprehensive route system will be included with this report detailing this trail system that is contained in Alternative E, specifically within the proposed Never Sweat and Lost Spring WCs. The Sage Riders would ask that the trail system as submitted by this organization (see attached) be included in the final draft of the OHV route designation, referred to as the “Chimney Rock Trail System”.
Alternative E also eliminates 250 miles of trails and roads as contained in the San Rafael Travel Plan 2003. It was our understanding from conversations with present and previous Field Office Management, that the no roads or trails would be added, nor deleted from the San Rafael Travel Plan until after the RMP had been completed. Apparently the BLM office has found a way around this directive; therefore, we would oppose the deletion of the 250 miles of trails and roads as specified in Alternative E (within the San Rafael Travel Plan) and would ask that the following trails (the accumulative sum of approximately 50 miles) within the San Rafael management area be added to the OHV route designation in the RMP final and approved alternative:
a) VJ Trail: Located within the Temple Mountain Trail System.
b) Purple Trail: Located within the Temple Mountain Trail System.
c) Cottonwood Wash: Located on the east side of Highway 24.
d) June’s Bottom: Located on the Lower San Rafael Road.
WILDERNESS CHARACTERISTICS DESCRIBED IN ALTERNATIVE
E THAT ARE NOT SUBSTANTIATED
As a club we regret that we did not have the time to ground proof all of the proposed WCs. Due to the shortness of time and resources available only about 35% of the proposed areas were covered. We feel that if more time was afforded significant human impacts would be found and noted on the other proposed WCs that were not analyzed by this club.
The SRMC will only address the following proposed WC areas: Lost Spring, Never Sweat, Eagle Canyon, Molen Reef, South Horn Mountain, Price River, San Rafael Reef, Muddy River-Crack Canyon and Desolation Canyon.
General Observations:
In the areas analyzed by SRMC we observed and documented the imprint of significant human disturbances to include:
Full-size vehicle routes, including Emery County roads.
52” ATV double track.
24” Singe track motorcycle trails.
Active railroad track lines.
Abandoned railroad grades.
Utility corridors including power transmission lines and fiber optic cables.
Grazing allotment fences.
Stock ponds.
Water service ponds.
Drill sites
Corrals, water troughs and feed barrels.
Mining claim markers.
Abandoned mines.
Exploratory excavation sites.
Seismic lines.
Abandoned home sites and homesteads.
Campsites.
Paved roads.
Solitude:
The above mentioned significant human impacts affect the opportunity of solitude. Each of the proposed WC areas and their opportunity for solitude are impacted by the following paved roads:
a) Interstate 70
b) State Highway 10
c) State Highway 6
d) State Highway 24
e) Miller Canyon Cut Off (county road)
f) Moore Cut Off Road (county road)
Numerous full-sized roads, ATV two track and motorcycle single track trails. In addition permitted activities such as grazing, mineral extraction and oil and gas exploration will also have impact on opportunity for solitude.
The Denver and Rio Grande Western Railroad also impacts the opportunity for solitude.
Data Collection, Recording and Interpretation:
The data and observations were facilitated by hiking (foot), full-size vehicles, motorcycles, mountain bikes, ATVs and aerial photos.
Waypoints, location recording was done with the use of a Lowrance GPSr unit using North American Datum 1983.
Photographic evidences were georeferenced to or near the location they were taken; some of the aerial images are approximations and could have some deviations; however, the other images will be within a ten-meter tolerance. These georeferenced photographs will prove that the following proposed areas for Wilderness Characteristics are significantly dominated by human imprint and do not qualify for such designation or status:
1) Lost Spring Wash
2) Never Sweat Wash
3) Price River
4) Eagle Canyon
5) Molen Reef
6) San Rafael Reef
7) South Horn Mountain
8) Muddy River-Crack Canyon
9) Desolation Canyon
The included table depicts (types) of disturbances and a level of disturbance to the area (class). The class or level of disturbance shown in this table is for reference purposes only and is solely to assist anyone reviewing these images; “1” being least significant to “5” the most significant.
The CD accompanying this table contains the images and an Arc GIS file linking them to a location.
Never Sweat Wash
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but are not limited to the following:
1) The documented georeferenced evidence shows this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved), ATV trails (two track, 54”) and single track motorcycle trails (24” trails). The Green River Cutoff Road (Emery County Road EM401), which serves as the southern boundary for this proposal, is a major travel route. The volume of traffic on the Green River Cutoff Raod will impact the visual aspect as well as the solitude aspect of the proposal. Many visitors to the San Rafael Swell will use this road to access Utah Highway 10 and Utah Highway 6 between the cities of Castle Dale and Green River.
2) The northeast section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Bill Barrett Corporation currently has several leases and has recently engaged in exploratory drilling in this area.
4) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment (bulldozers) are found in the proposed area.
5) Several historic homesteads and home sites are found within this proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds (constructed and maintained by bulldozers) are found within this area.
8) The Denver and Rio Grande Railroad has an active line and in some instances forms the border of this proposed area. On a daily basis several trains pass through this area. Noise and site impairments impact the solitude factor.
9) This proposed area is adjacent to or within 10 "school sections" which are owned and managed by the State Institutional Trust Lands Administration (SITLA) of the state of Utah. SITLA has a management plan that is significantly different than that of the BLM, especially if this area was managed as having wilderness characteristics. Four SITLA Sections are completely surrounded by the proposed action.
10) BLM permitted competitive motorcycle races where held in this area in 1982, 1983, 1985, 1986, 1996, 1997, 1998, 2002 and 2003. The SRMPs for these races included EAs completed by Price Field Office and allowed for the competitive event and associated logistical considerations such as latrines, marking the course and camping. Each of these events had averaged approximately 250 participants.
Lost Springs Wash
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1. The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved), ATV trails (two track, 54”) and single track motorcycle trails (24” trails). The Green River Cutoff Road (Emery County Road EM401), which serves as the northern boundary for this proposal, is a major travel route. The volume of traffic on the Green River Cutoff Raod will impact the visual aspect as well as the solitude aspect of the proposal Many visitors of the Swell will use this road to access the Green River area and State Highway 6.
2. The southeast section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3. Numerous mining claims are found within this area.
4. Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
5. Several homesteads and home sites are found within this proposal.
6. Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7. Service ponds are also found within this area.
8. The Denver and Rio Grande Railroad has an active line adjacent to the proposal. On a daily basis several trains pass through this area. Noise and site impairments impact the solitude factor.
9. This proposed area is adjacent to or within 8 State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Five State Trust Land Sections are completely surrounded by the proposed action.
10.BLM permitted competitive motorcycle races where held in this area in *****ALAN PETERSON. The permit allowed for the competitive event and associated logistical considerations such as latrines, marking the course and camping. Each of these events had averaged approximately 250 participants.
Price River
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved), ATV trails (two track, 54”) and single track motorcycle trails (24” trails).
2) The northeast section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Bill Barrett Corporation currently has several leases in this area.
4) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
5) Several homesteads and home sites are found within this proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds are also found within this area.
8) The Denver and Rio Grande Railroad has an active line in close proximity. On a daily basis several trains pass through this area. Noise and site impairments impact the solitude factor.
9) This proposed area is adjacent to or within at least 14 State Trust Land sections, which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. 10 State Trust Land Sections are completely surrounded by the proposed action.
10) Several tracts of private property border the proposal in several areas. Private property to a large extent is managed according to the desires of the landholder and in most cases will not be consistent with wilderness characteristics management. This will also impact the visual and solitude aspects of any adjacent proposals for wilderness characteristics.
Eagle Canyon
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories) and jeep roads (non-improved). Dutch Flat Road (Emery County Road EM705) is the northern boundary and the Moore Cutoff Road (Emery County Road EM803) is the southern boundary of this proposal. The volume of traffic on these two roads will impact the visual aspect as well as the solitude aspect of the proposal. The Moore Cutoff Road is currently under construction and will be paved by the fall of 2008. The Moore Cutoff is high traveled vehicle route.
2) Interstate 70 is within eye view of the proposal. This interstate is a major commerce and travel route. High volume of traffic impacts this corridor. Travel noise from the vehicles using this interstate can be heard for over five miles inside of the proposed area. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Mining leases are located near the southeastern boundary of the proposal.
4) An active gypsum mine is located in south of the boundary. Heavy mining machinery extracts the mineral. On a daily basis, diesel trucks haul out the mineral to Sever County for processing. Noise from this activity can be heard within the proposed boundary and will impact the solitude factor. In addition, dust and other associated activities with the mineral extraction will also impact visual factors as observed from the proposed area.
5) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds are also found within this area.
8) This proposed area is adjacent to or within nine State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Six State Trust Land Sections are completely surrounded by the proposed action.
Molen Reef
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories) and jeep roads (non-improved). The Moore Cutoff Road (Emery County Road EM803) is the northern boundary of this proposal. The Moore Cutoff Road is currently under construction and will be paved by the fall of 2008. The Moore Cutoff is high traveled vehicle route. The volume of traffic on this road will impact the visual aspect as well as the solitude aspect of the proposal.
2) Interstate 70 serves as the southern boarder of this proposal. The layout of this Interstate is in view of much of the proposed area. This interstate is a major commerce and travel route. High volume of traffic impacts this corridor. Travel noise from the vehicles using this interstate can be heard for over five miles inside of the proposed area. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Mining leases are located near the northern and western boundaries of the proposal.
4) An active gypsum mine is located southeast of the boundary. Although this mine is not within the area, the proximity of this operation needs to be taken into consideration. This mining activity can been seen and heard within the proposed area. Heavy mining machinery extracts the mineral. On a daily basis, diesel trucks haul out the mineral to Sever County for processing. Noise from this activity can be heard within the proposed boundary and will impact the solitude factor. In addition, dust and other associated activities with mineral extraction will also impact visual factors as observed from the proposed area.
5) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
6) Several homesteads and home sites are found within this proposal.
7) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
8) Service ponds are also found within this area.
9) This proposed area is adjacent to or within eight State Trust Land sections, which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Six State Trust Land Sections are completely surrounded by the proposed action.
10)Several tracts of private property border the proposal in several areas. Private property to a large extent is managed according to the desires of the landholder and in most cases will not be consistent with wilderness characteristics management. This will also impact the visual and solitude aspects of any adjacent proposals for wilderness characteristics. Active mineral and coal mining is currently taking place on the private property adjacent to or near the proposal.
San Rafael Reef
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved) and single track motorcycle trails (24” trails, Temple Mountain Single Track Trail System). The Temple Mountain Cutoff Road (Emery County Road EM332, EM1033, EM1012, EM1200) serves as the western boundary of this proposal. This is a major travel route for recreational users and cattlemen from Interstate 70 to the Temple Mountain and surrounding areas. The volume of traffic and associated sound and dust from this road will impact the visual aspect as well as the solitude aspect of the proposal.
2) Interstate 70 serves as the northeastern boarder of this proposal. This interstate is a major commerce and travel route. High volume of traffic impacts this corridor. Travel noise from the vehicles using this interstate can be heard for over five miles inside of the proposed area. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
4) Several home sites are found within this proposal.
5) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
6) Service ponds are also found within this area.
7) This proposed area is adjacent to or within eleven State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Six State Trust Land Sections are completely surrounded by the proposed action.
South Horn Mountain
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have several full-sized roads (including Class B and D roads). Rock Canyon Road (Emery County Road EM603) serves as the northern boarder of this proposal. This a highly used road for access to the Rock Canyon ATV trailhead and for cattleman servicing ponds and stock ponds. In addition this road provides access to mineral claims that are located adjacent to and not within the proposed area. A canal service road is found within the unit near the southeast boarder. This service route is frequently used to inspect and repair the canal that provides water for farms and for the Hunter Power Plant. The volume of traffic on the Rock Canyon primarily and the canal service road secondary will impact the visual aspect as well as the solitude aspect of the proposal Many visitors of the Swell will use this road to access the Green River area and State Highway 6.
2) State Highway 10, which is a major (high volume) traffic corridor for Emery County is within sight and hearing distance of this proposed area. Coal trucks pass by this area every two minutes. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) There is at least one active developed well site with in this proposal.
4) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
5) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
6) Service ponds are also found within this area.
7) This proposed area is adjacent to or within two State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. One State Trust Land Sections are completely surrounded by the proposed action.
8) Millesite Reservoir provides the southwest boarder of this proposal. Millsite Reservoir is managed by the Utah State Parks and is highly used park for swimming, fishing, boating and watercraft. Engine noise from water skiing boats, fishing boats and fishing boats can be heard in several areas. The view of these crafts and engine noise impacts the solitude of the area.
Muddy River-Crack Canyon
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain the, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved) and the Waterfall single track motorcycle trail (24” trail).
2) Several Emery County Roads either travel within or provides a boarder for much the proposal. The roads include, but not limited to EM1012, EM1016, EM1021 and EM1019. These county travel routes are heavily traveled by users accessing Wild Horse Mesa, Hidden Splendor Mine, Tomsich Butte, Keesle Country, the Hondu,McKay Flat and Behind the Reef. The volume of traffic on theses roads will impact the visual aspect as well as the solitude aspect of the proposal.
3) Numerous mining, oil and gas claims are found within this area.
4) Significant and noticeable impacts from past mining and drilling activities are evident that involved the use of heavy mechanized equipment that are found in the proposal.
5) Several homesteads and home sites are found within this proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds are also found within this area.
8) This proposed area is adjacent to or within 29 State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. 12 State Trust Land Sections are completely surrounded by the proposed action.
9) This proposal is also within the vicinity of the Goblin Valley State Park. Goblin Valley State Park attracts thousands of visitors each year. These visitors will impact the solitude of the proposal.
Desolation Canyon
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain the, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories) and jeep roads. The Green River Cutoff Road, which serves as the southern boundary for this proposal, is a major travel route. The western section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
2) Numerous mining, oil and gas claims are found within this area. Bill Barrett Corporation currently has several leases in this area.
3) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
4) Several homesteads and home sites are found within this proposal.
5) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
6) Service ponds are also found within this area.
7) The Denver and Rio Grande Railroad has an active in the vicinity of this proposed area. On a daily basis several trains pass through this area. Noise and sight impairments impact the solitude factor. Noise from the trains and the visibility of the trains can be seen from within the proposed area.
8) This proposed area is adjacent to or within 12 State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Five State Trust Land Sections are completely surrounded by the proposed action.
CARFULL OBEJECTIVE ANALYSIS NEEDED
It is interesting to note that in the WC proposals found in Alternative E, there have been “cherry stemmed” out or not to be included roads, stock ponds and drill sites. These “cherry stemmed” areas are proof that the WCs as proposed do not qualify. It makes little or no management sense to state that an area has Wilderness Characteristics except for areas that have been drawn out or excluded. This is especially true when considering that any wilderness consideration should revolve around 5,000 continuous acres. The BLM has a history in the Emery County/Carbon County areas of not accurately conducting objective analysis of areas for special designations. Often these areas did not meet specified criteria thus making the area impossible to manage under the specific mandate.
CONCLUSION
After conducting an exhaustive and in-depth analysis of Lost Spring, Never Sweat, Eagle Canyon, Molen Reef, South Horn Mountain, Price River, San Rafael Reef, Muddy River-Crack Canyon and Desolation Canyon, we find that substantial noticeable human imprints are prevalent thus disqualifying these areas for a designation of having wilderness characteristics.
As a club we regret that we did not have the time to ground proof all of the proposed WCs. We feel that if more time was afforded significant human impacts would be found and noted on the other proposed WCs that were not analyzed by this club.
oRESPONSE TO ALTERNATIVE E
oWILDERNESS CHARACTERISTICS DOCUMENTATION
November 22, 2007
EMERY/CARBON COUNTYPRICE BLM FIELD OFFICE
Lost Springs Wash
Never Sweat Wash
Eagle Canyon
Molen Reef
South Horn Mountain
Price River
San Rafael Reef
Muddy River-Crack Canyon
Desolation Canyon
Prepared by:
Wade Allinson, Sage Riders Public Lands Officer
Alan Peterson, Sage Riders Information Officer
Scott Wheeler, Club Member
Other members and associates
SAGE RIDERS MOTORCYCLE CLUB
PO BOX 585
FERRON, UTAH
84523
435-384-2711
Roger Bankert November 18, 2007
BLM Field Director
Price Field Office
COMMENTS CONCERNING ALTERNATIVE E
Roger,
WHY COMMENTS DIRECTED TO ROGER BANKERT
The Sage Rider’s Motorcycle Club is directing our comments directly to your attention. It has been our past experience that the data we have submitted concerning the RMP process has been misplaced or unable to be located.
DATA PROVIDED TO BE OUTLINED IN THIS DOCUMENT
We feel that the data that we are submitting is evidence of the noticeable impact and nature of human imprints that affect the wilderness characteristics as proposed in the areas that will be submitted within this document.
This report will contain our club position on Alternative E and comprehensive analysis of the WCs (Wilderness Characteristics) and travel routes that are contained in Alternative E. We feel that the data provided herein will be of most benefit in assisting the BLM in providing a manageable alternative for the Price Field Office. With our input we feel that the resource can be protected while providing a variety of opportunities for both recreation and economic reasons. Both of which are vital to the sustaining of our local economy.
The Sage Riders Motorcycle Club has spent hundreds of hours on the ground gathering documented facts that impact the wilderness character as described in the Wilderness Act and BLM Instructional Memorandum 2003-275.
SAGE RIDERS MOTORCYCLE CLUB INFORMATION
The Sage Riders Motorcycle Club (SRMC) is composed of members from throughout the State of Utah. The SRMC was founded in 1980. Some members are residents of Carbon or Emery Counties. The SRMC has a Volunteer Agreement with the Price Field Office for maintenance of singletrack trails in Emery County. These include The Waterfall Trail, Five Miles of Hell and The Temple Mountain Motorcycle Trail System. The SRMC are very active in maintenance, monitoring and protection of the current single track trail system as designated in the San Rafael Travel Plan 2003.
The SRMC holds at least two off road competitive events (races) annually. The SRMC has a vested interest in the lands administered by Price Field Office in that we have received Special Recreation Permits (SRP) to hold races specifically within the Never Sweat and Lost Springs Wash areas. These are both "Citizen Proposed Wilderness Characteristic Areas". SRMC has held races in these areas since1982 with each race having been issued a SRP by the Price Field Office. In addition to the Environmental Analysis (EA) done by Price Field Office for each of these events, the SRMC also hired a BLM approved Archaeological Firm to conduct Level III Cultural & Archeological Inventories in both of these areas. The cumulative sum paid to the firm (Baseline Data) by SRMC & Bookcliff Rattlers M/C was $30,000.00. As you can see, we have a vested interest in these areas and plan to continue promoting off road events as we have done for the last 25 years.
CLUB OPINION IN REGARDS TO LANDS WITH WILDERNESS CHARACTERISTICS
Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. Congress instructed the agency to inventory all of their lands, identify which were definitely not of wilderness quality and then to begin an intensive inventory and analysis to determine which of the remaining lands would be recommended for inclusion into the National Wilderness Preservation System.
The process was completed in 1991. All stakeholders (including Wilderness Advocacy Groups) have exhausted the protest and appeal options. After 10 years the "603 Process" left Utah with approximately 3.2 million acres designated as Wilderness Study Areas. Of those, approximately 1.9 million acres were deemed "suitable and manageable" and were recommended to Congress for Wilderness designation. Section 603 requires the BLM to manage WSAs in such a manner so as to not impair the suitability of such areas for inclusion in the National Wilderness Preservation System, subject to existing uses.
There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources.
When formulating land use plans and considering opportunities for solitude and unconfined recreation, the BLM must consider all other resource values and uses and attempt to balance the competing uses and values using the Multiple Use/Sustained Yield paradigm.
CLUB POSITION ALTERNATIVE E
The Sage Riders Motorcycle Club does not support Alternative E. As previously stated the Sage Riders supports Alternative D with the trail system as provided by this club to the BLM.
The WCs as proposed in the South Horn Mountain, Molen Reef, Eagle Canyon, Never Sweat Wash, Lost Springs Wash, Price River, San Rafael Reef, Muddy Creek-Crack Canyon and Desolation Canyon are not substantiated on the ground as proposed in Alternative E. The documentation and evidence of this will be included in this document.
The Never Sweat Wash WC and the Lost Spring WC as proposed in Alternative E contains several roads, 52 inch trail and single track trail systems, referred to as the “Chimney Rock Trail System”. A comprehensive route system will be included with this report detailing this trail system that is contained in Alternative E, specifically within the proposed Never Sweat and Lost Spring WCs. The Sage Riders would ask that the trail system as submitted by this organization (see attached) be included in the final draft of the OHV route designation, referred to as the “Chimney Rock Trail System”.
Alternative E also eliminates 250 miles of trails and roads as contained in the San Rafael Travel Plan 2003. It was our understanding from conversations with present and previous Field Office Management, that the no roads or trails would be added, nor deleted from the San Rafael Travel Plan until after the RMP had been completed. Apparently the BLM office has found a way around this directive; therefore, we would oppose the deletion of the 250 miles of trails and roads as specified in Alternative E (within the San Rafael Travel Plan) and would ask that the following trails (the accumulative sum of approximately 50 miles) within the San Rafael management area be added to the OHV route designation in the RMP final and approved alternative:
a) VJ Trail: Located within the Temple Mountain Trail System.
b) Purple Trail: Located within the Temple Mountain Trail System.
c) Cottonwood Wash: Located on the east side of Highway 24.
d) June’s Bottom: Located on the Lower San Rafael Road.
WILDERNESS CHARACTERISTICS DESCRIBED IN ALTERNATIVE
E THAT ARE NOT SUBSTANTIATED
As a club we regret that we did not have the time to ground proof all of the proposed WCs. Due to the shortness of time and resources available only about 35% of the proposed areas were covered. We feel that if more time was afforded significant human impacts would be found and noted on the other proposed WCs that were not analyzed by this club.
The SRMC will only address the following proposed WC areas: Lost Spring, Never Sweat, Eagle Canyon, Molen Reef, South Horn Mountain, Price River, San Rafael Reef, Muddy River-Crack Canyon and Desolation Canyon.
General Observations:
In the areas analyzed by SRMC we observed and documented the imprint of significant human disturbances to include:
Full-size vehicle routes, including Emery County roads.
52” ATV double track.
24” Singe track motorcycle trails.
Active railroad track lines.
Abandoned railroad grades.
Utility corridors including power transmission lines and fiber optic cables.
Grazing allotment fences.
Stock ponds.
Water service ponds.
Drill sites
Corrals, water troughs and feed barrels.
Mining claim markers.
Abandoned mines.
Exploratory excavation sites.
Seismic lines.
Abandoned home sites and homesteads.
Campsites.
Paved roads.
Solitude:
The above mentioned significant human impacts affect the opportunity of solitude. Each of the proposed WC areas and their opportunity for solitude are impacted by the following paved roads:
a) Interstate 70
b) State Highway 10
c) State Highway 6
d) State Highway 24
e) Miller Canyon Cut Off (county road)
f) Moore Cut Off Road (county road)
Numerous full-sized roads, ATV two track and motorcycle single track trails. In addition permitted activities such as grazing, mineral extraction and oil and gas exploration will also have impact on opportunity for solitude.
The Denver and Rio Grande Western Railroad also impacts the opportunity for solitude.
Data Collection, Recording and Interpretation:
The data and observations were facilitated by hiking (foot), full-size vehicles, motorcycles, mountain bikes, ATVs and aerial photos.
Waypoints, location recording was done with the use of a Lowrance GPSr unit using North American Datum 1983.
Photographic evidences were georeferenced to or near the location they were taken; some of the aerial images are approximations and could have some deviations; however, the other images will be within a ten-meter tolerance. These georeferenced photographs will prove that the following proposed areas for Wilderness Characteristics are significantly dominated by human imprint and do not qualify for such designation or status:
1) Lost Spring Wash
2) Never Sweat Wash
3) Price River
4) Eagle Canyon
5) Molen Reef
6) San Rafael Reef
7) South Horn Mountain
8) Muddy River-Crack Canyon
9) Desolation Canyon
The included table depicts (types) of disturbances and a level of disturbance to the area (class). The class or level of disturbance shown in this table is for reference purposes only and is solely to assist anyone reviewing these images; “1” being least significant to “5” the most significant.
The CD accompanying this table contains the images and an Arc GIS file linking them to a location.
Never Sweat Wash
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but are not limited to the following:
1) The documented georeferenced evidence shows this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved), ATV trails (two track, 54”) and single track motorcycle trails (24” trails). The Green River Cutoff Road (Emery County Road EM401), which serves as the southern boundary for this proposal, is a major travel route. The volume of traffic on the Green River Cutoff Raod will impact the visual aspect as well as the solitude aspect of the proposal. Many visitors to the San Rafael Swell will use this road to access Utah Highway 10 and Utah Highway 6 between the cities of Castle Dale and Green River.
2) The northeast section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Bill Barrett Corporation currently has several leases and has recently engaged in exploratory drilling in this area.
4) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment (bulldozers) are found in the proposed area.
5) Several historic homesteads and home sites are found within this proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds (constructed and maintained by bulldozers) are found within this area.
8) The Denver and Rio Grande Railroad has an active line and in some instances forms the border of this proposed area. On a daily basis several trains pass through this area. Noise and site impairments impact the solitude factor.
9) This proposed area is adjacent to or within 10 "school sections" which are owned and managed by the State Institutional Trust Lands Administration (SITLA) of the state of Utah. SITLA has a management plan that is significantly different than that of the BLM, especially if this area was managed as having wilderness characteristics. Four SITLA Sections are completely surrounded by the proposed action.
10) BLM permitted competitive motorcycle races where held in this area in 1982, 1983, 1985, 1986, 1996, 1997, 1998, 2002 and 2003. The SRMPs for these races included EAs completed by Price Field Office and allowed for the competitive event and associated logistical considerations such as latrines, marking the course and camping. Each of these events had averaged approximately 250 participants.
Lost Springs Wash
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1. The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved), ATV trails (two track, 54”) and single track motorcycle trails (24” trails). The Green River Cutoff Road (Emery County Road EM401), which serves as the northern boundary for this proposal, is a major travel route. The volume of traffic on the Green River Cutoff Raod will impact the visual aspect as well as the solitude aspect of the proposal Many visitors of the Swell will use this road to access the Green River area and State Highway 6.
2. The southeast section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3. Numerous mining claims are found within this area.
4. Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
5. Several homesteads and home sites are found within this proposal.
6. Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7. Service ponds are also found within this area.
8. The Denver and Rio Grande Railroad has an active line adjacent to the proposal. On a daily basis several trains pass through this area. Noise and site impairments impact the solitude factor.
9. This proposed area is adjacent to or within 8 State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Five State Trust Land Sections are completely surrounded by the proposed action.
10.BLM permitted competitive motorcycle races where held in this area in *****ALAN PETERSON. The permit allowed for the competitive event and associated logistical considerations such as latrines, marking the course and camping. Each of these events had averaged approximately 250 participants.
Price River
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved), ATV trails (two track, 54”) and single track motorcycle trails (24” trails).
2) The northeast section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Bill Barrett Corporation currently has several leases in this area.
4) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
5) Several homesteads and home sites are found within this proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds are also found within this area.
8) The Denver and Rio Grande Railroad has an active line in close proximity. On a daily basis several trains pass through this area. Noise and site impairments impact the solitude factor.
9) This proposed area is adjacent to or within at least 14 State Trust Land sections, which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. 10 State Trust Land Sections are completely surrounded by the proposed action.
10) Several tracts of private property border the proposal in several areas. Private property to a large extent is managed according to the desires of the landholder and in most cases will not be consistent with wilderness characteristics management. This will also impact the visual and solitude aspects of any adjacent proposals for wilderness characteristics.
Eagle Canyon
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories) and jeep roads (non-improved). Dutch Flat Road (Emery County Road EM705) is the northern boundary and the Moore Cutoff Road (Emery County Road EM803) is the southern boundary of this proposal. The volume of traffic on these two roads will impact the visual aspect as well as the solitude aspect of the proposal. The Moore Cutoff Road is currently under construction and will be paved by the fall of 2008. The Moore Cutoff is high traveled vehicle route.
2) Interstate 70 is within eye view of the proposal. This interstate is a major commerce and travel route. High volume of traffic impacts this corridor. Travel noise from the vehicles using this interstate can be heard for over five miles inside of the proposed area. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Mining leases are located near the southeastern boundary of the proposal.
4) An active gypsum mine is located in south of the boundary. Heavy mining machinery extracts the mineral. On a daily basis, diesel trucks haul out the mineral to Sever County for processing. Noise from this activity can be heard within the proposed boundary and will impact the solitude factor. In addition, dust and other associated activities with the mineral extraction will also impact visual factors as observed from the proposed area.
5) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds are also found within this area.
8) This proposed area is adjacent to or within nine State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Six State Trust Land Sections are completely surrounded by the proposed action.
Molen Reef
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories) and jeep roads (non-improved). The Moore Cutoff Road (Emery County Road EM803) is the northern boundary of this proposal. The Moore Cutoff Road is currently under construction and will be paved by the fall of 2008. The Moore Cutoff is high traveled vehicle route. The volume of traffic on this road will impact the visual aspect as well as the solitude aspect of the proposal.
2) Interstate 70 serves as the southern boarder of this proposal. The layout of this Interstate is in view of much of the proposed area. This interstate is a major commerce and travel route. High volume of traffic impacts this corridor. Travel noise from the vehicles using this interstate can be heard for over five miles inside of the proposed area. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Numerous mining, oil and gas claims are found within this area. Mining leases are located near the northern and western boundaries of the proposal.
4) An active gypsum mine is located southeast of the boundary. Although this mine is not within the area, the proximity of this operation needs to be taken into consideration. This mining activity can been seen and heard within the proposed area. Heavy mining machinery extracts the mineral. On a daily basis, diesel trucks haul out the mineral to Sever County for processing. Noise from this activity can be heard within the proposed boundary and will impact the solitude factor. In addition, dust and other associated activities with mineral extraction will also impact visual factors as observed from the proposed area.
5) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
6) Several homesteads and home sites are found within this proposal.
7) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
8) Service ponds are also found within this area.
9) This proposed area is adjacent to or within eight State Trust Land sections, which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Six State Trust Land Sections are completely surrounded by the proposed action.
10)Several tracts of private property border the proposal in several areas. Private property to a large extent is managed according to the desires of the landholder and in most cases will not be consistent with wilderness characteristics management. This will also impact the visual and solitude aspects of any adjacent proposals for wilderness characteristics. Active mineral and coal mining is currently taking place on the private property adjacent to or near the proposal.
San Rafael Reef
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved) and single track motorcycle trails (24” trails, Temple Mountain Single Track Trail System). The Temple Mountain Cutoff Road (Emery County Road EM332, EM1033, EM1012, EM1200) serves as the western boundary of this proposal. This is a major travel route for recreational users and cattlemen from Interstate 70 to the Temple Mountain and surrounding areas. The volume of traffic and associated sound and dust from this road will impact the visual aspect as well as the solitude aspect of the proposal.
2) Interstate 70 serves as the northeastern boarder of this proposal. This interstate is a major commerce and travel route. High volume of traffic impacts this corridor. Travel noise from the vehicles using this interstate can be heard for over five miles inside of the proposed area. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
4) Several home sites are found within this proposal.
5) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
6) Service ponds are also found within this area.
7) This proposed area is adjacent to or within eleven State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Six State Trust Land Sections are completely surrounded by the proposed action.
South Horn Mountain
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain, but not limited to the following:
1) The documented georeferenced evidence with show this area to have several full-sized roads (including Class B and D roads). Rock Canyon Road (Emery County Road EM603) serves as the northern boarder of this proposal. This a highly used road for access to the Rock Canyon ATV trailhead and for cattleman servicing ponds and stock ponds. In addition this road provides access to mineral claims that are located adjacent to and not within the proposed area. A canal service road is found within the unit near the southeast boarder. This service route is frequently used to inspect and repair the canal that provides water for farms and for the Hunter Power Plant. The volume of traffic on the Rock Canyon primarily and the canal service road secondary will impact the visual aspect as well as the solitude aspect of the proposal Many visitors of the Swell will use this road to access the Green River area and State Highway 6.
2) State Highway 10, which is a major (high volume) traffic corridor for Emery County is within sight and hearing distance of this proposed area. Coal trucks pass by this area every two minutes. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
3) There is at least one active developed well site with in this proposal.
4) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
5) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
6) Service ponds are also found within this area.
7) This proposed area is adjacent to or within two State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. One State Trust Land Sections are completely surrounded by the proposed action.
8) Millesite Reservoir provides the southwest boarder of this proposal. Millsite Reservoir is managed by the Utah State Parks and is highly used park for swimming, fishing, boating and watercraft. Engine noise from water skiing boats, fishing boats and fishing boats can be heard in several areas. The view of these crafts and engine noise impacts the solitude of the area.
Muddy River-Crack Canyon
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain the, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories), jeep roads (non-improved) and the Waterfall single track motorcycle trail (24” trail).
2) Several Emery County Roads either travel within or provides a boarder for much the proposal. The roads include, but not limited to EM1012, EM1016, EM1021 and EM1019. These county travel routes are heavily traveled by users accessing Wild Horse Mesa, Hidden Splendor Mine, Tomsich Butte, Keesle Country, the Hondu,McKay Flat and Behind the Reef. The volume of traffic on theses roads will impact the visual aspect as well as the solitude aspect of the proposal.
3) Numerous mining, oil and gas claims are found within this area.
4) Significant and noticeable impacts from past mining and drilling activities are evident that involved the use of heavy mechanized equipment that are found in the proposal.
5) Several homesteads and home sites are found within this proposal.
6) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
7) Service ponds are also found within this area.
8) This proposed area is adjacent to or within 29 State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. 12 State Trust Land Sections are completely surrounded by the proposed action.
9) This proposal is also within the vicinity of the Goblin Valley State Park. Goblin Valley State Park attracts thousands of visitors each year. These visitors will impact the solitude of the proposal.
Desolation Canyon
Georeferenced photographic evidence attached to the accompanying CD will clearly show substantial human disturbances that would not substantiate this area as meeting the criteria outlined and defined by the Wilderness Act and BLM Instructional Memorandum 2003-725. Significant human disturbances that have been georefrenced contain the, but not limited to the following:
1) The documented georeferenced evidence with show this area to have numerous full-sized roads (including Class B and D categories) and jeep roads. The Green River Cutoff Road, which serves as the southern boundary for this proposal, is a major travel route. The western section of this proposed area is adjacent to State Highway 6, which is a major (high volume) traffic corridor for the State of Utah. Noise from this traffic corridor will impact the solitude factor of this area as well as the visual aspect.
2) Numerous mining, oil and gas claims are found within this area. Bill Barrett Corporation currently has several leases in this area.
3) Significant and noticeable impacts from past mining and drilling activities including several capped well sites that involved the use of heavy mechanized equipment around found in the proposal.
4) Several homesteads and home sites are found within this proposal.
5) Several active grazing permits are found within this area, which also includes stock ponds, corals, gates, cattle guards and fencing.
6) Service ponds are also found within this area.
7) The Denver and Rio Grande Railroad has an active in the vicinity of this proposed area. On a daily basis several trains pass through this area. Noise and sight impairments impact the solitude factor. Noise from the trains and the visibility of the trains can be seen from within the proposed area.
8) This proposed area is adjacent to or within 12 State Trust Land sections which are owned and managed by the State Utah with said management being significantly different than that of the BLM especially if this area was managed as having wilderness characteristics. Five State Trust Land Sections are completely surrounded by the proposed action.
CARFULL OBEJECTIVE ANALYSIS NEEDED
It is interesting to note that in the WC proposals found in Alternative E, there have been “cherry stemmed” out or not to be included roads, stock ponds and drill sites. These “cherry stemmed” areas are proof that the WCs as proposed do not qualify. It makes little or no management sense to state that an area has Wilderness Characteristics except for areas that have been drawn out or excluded. This is especially true when considering that any wilderness consideration should revolve around 5,000 continuous acres. The BLM has a history in the Emery County/Carbon County areas of not accurately conducting objective analysis of areas for special designations. Often these areas did not meet specified criteria thus making the area impossible to manage under the specific mandate.
CONCLUSION
After conducting an exhaustive and in-depth analysis of Lost Spring, Never Sweat, Eagle Canyon, Molen Reef, South Horn Mountain, Price River, San Rafael Reef, Muddy River-Crack Canyon and Desolation Canyon, we find that substantial noticeable human imprints are prevalent thus disqualifying these areas for a designation of having wilderness characteristics.
As a club we regret that we did not have the time to ground proof all of the proposed WCs. We feel that if more time was afforded significant human impacts would be found and noted on the other proposed WCs that were not analyzed by this club.
