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

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Edited by: John Stewart

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

The following letters was perpared from information provided by BlueRibon Coalition. Please provide your name and address and e-mail this letter to the BLM Outdoor Recreation Planner.

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Outdoor Recreation Planner Bureau of Land Management Salt Lake Field Office 2370 S. 2300 W. Salt Lake City, UT 84119 RE: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah. Outdoor Recreation Planner: Please accept these comments to your Recreation Management Standards and Guidelines. I have been reviewing the process of your Recreation Management Standards and Guidelines and believe they are overshadowed by the BLM National Recreation Strategy. As such, this duplication creates an unnecessary burden on the recreational users of public lands to abide by the "correct" set of rules. If, in fact these BLM Standards and Guides are more important for the state of Utah and they establish absolute standards by which all recreation management must abide; then, they are implementation OF the National Strategy in Utah - before the Strategy has been finalized. Most of the Standards and Guides (5 pages) are fairly reasonable. However, I have identified significant problem areas: Rangeland Health Standard 3 contains some dangerous language within a general statement that is fairly benign: "DESIRED SPECIES, INCLUDING NATIVE, THREATENED, ENDANGERED, AND SPECIAL STATUS SPECIES, ARE MAINTAINED AT A LEVEL APPROPRIATE FOR THE SITE AND SPECIES INVOLVED." There are problems with #2 (a): "Maintaining interconnecting wildlife travel corridors and, to the extent practical, avoid fragmentation of areas used by wildlife" This statement enshrines, within this Standard, the island biogeography philosophy of Wildlands founder Reed Noss' claims that animals need tracts of wilderness connected by undisturbed corridors to thrive. This flies in the face of common sense. We know that animals use roads and trails to move from place to place. In fact, man has adapted many of these game trails for his own use. Roads and trails do NOT fragment habitat. In fact, some can argue that they can ENHANCE habitat by facilitating movement. Studies that purport to confirm Noss' theory assume that if animals (elk and grizzly bear, specifically) are observed to be displaced from a roaded area, that they are displaced 100% of the time. In fact, they are only displaced during times of traffic and actually use the roads when traffic is absent, for example, at night. There are problems with #3: "Where necessary, control recreational use by kind of activity, season, intensity, distribution, and/or duration in order to protect plant and animal communities, especially those containing threatened, endangered, or candidate species." Controls should not be imposed unless there is evidence that recreational use is negatively impacting these communities. Candidate species should not be given identical status as threatened or endangered species. Sincerely,

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