SRMC Scoping Comments

The Salinas Ramblers have filed the following comments with the BLM:

May 28, 2003

Dear Mr. Beehler,

I am submitting these comments regarding the EA Plan Amendment process the Bureau of Land Management (BLM) recently initiated on behalf of the Salinas Ramblers Motorcycle Club (SRMC), a 70+ member organization whose members frequently recreate in the Clear Creek Management Area.

I would like to start by expressing our concern that this entire process is a sham and that the results of this process have already been predetermined by the BLM. I base this opinion on several indicators.

First, the BLM has initiated this process during the summer months when, historically, off road vehicle (OHV) user interest and usage in Clear Creek is low. The BLM has done little to notify the public that this process has commenced. There is no reference to it on the BLM State Office web page and it was not until May 14^th that the BLM sent out a letter to Technical Review Team (TRT) members that mentioned the start date of the EA process.

Second, according to the Federal Register Notice, "Documents pertinent to this proposal may be examined at the Hollister Field Office.." The Club requested a copy of these documents and as of the date of this writing, none have been provided. I also understand that another member of the TRT stopped by the HFO, asked to see the "pertinent documents" and was told that there were none. Further, he was told that the scoping had been completed previously through the TRT and that the HFO did not feel that the public would have any new issues to raise. So much for encouraging public comment.

Third, in documents previously released to the TRT, the BLM has indicated that they have predetermined the outcome of this planning. The first was a fencing grant request that showed a portion of the boundary of the San Benito Mountain Research Natural Area that you intend to fence. This area included a route and barrens that the OHV community has demanded be left open since to start of the EIS process in 1990. This issue is well documented on the Salinas Ramblers web site at the following URL: http://salinasramblersmc.org/fence%20grant%20comments.htm .

Another indication that the results have been predetermined are the dozens of "Closed Area" signs that the HFO has posted throughout Clear Creek without having gone through a NEPA process to allow the public an opportunity to comment.

Finally, an early draft of the trails EA indicated that the BLM planned to redefine the term "Limited Use Area". Today, the Record of Decision (ROD) states "Approval of the plan includes my decisions to designate the Clear Creek Management Area a "Limited Use" area, meaning that motor vehicles and off road vehicles must remain on existing routes…" The aforementioned document indicates the BLM’s desire to make the CCMA a designated route system area.

It is unfortunate that the HFO has never acknowledged this facet of the ROD nor attempted to implement it. You have never posted a sign in Clear Creek to that effect. In fact, you have posted numerous signs throughout the management area indicating that Clear Creek was in fact a designated route system area. A copy of my comments on this draft EA is attached and are a part of the SRMC comments.

I certainly hope that the BLM will confine the scope of this EA to identifying the criteria for evaluating routes, barrens and the boundaries of the SBMRNA. Any attempt to change the decisions favorable to the OHV community that are contained in the ROD will create a controversy that cannot be addressed by a mere Environmental Assessment.

Thank you for your consideration of these comments.

Sincerely,

Ed Tobin

Vice President

Events: The route system, as it exists today, supports two major off-road motorcycle events each year. While I can’t speak for the Timekeepers philosophy, the SRMC alters or varies the routes that we use each year for our event. This practice of rest and rotation has allowed the route system to sustain thirty years of events with little or no maintenance to the enduro routes. In order to continue to support the current quality of events and levels of use, the SRMC believes that a minimum of 400 miles of single track and jeep road are necessary. This would be in addition to any major road network that the BLM would deem necessary to administer and disperse use throughout Clear Creek.

Duplicate Trails: It has been mentioned at TRT meeting that one of the criteria to be used to evaluate routes will be whether a route is a duplicate, meaning that a route serves the same purpose as another route. It is my experience that there are very few routes that are duplicates. While it is hard to find a spot in Clear Creek that can not be driven to from more than one direction, many routes support different forms of OHV recreation and levels of skills. Both trail difficulty and intended use, i.e. jeep, quad, single-track motorcycle, must be included as a part of the trail evaluation criteria.

Areas Open for OHV Use: The SRMC supports the protection of riparian corridors and threatened and endangered species habitat. We also support the protection of OHV recreation opportunity. The ROD states: The barren areas will be managed so as to encourage use on designated numbered and/or signed barrens (play areas), and to allow use on all other barren areas which are not physically and/or signed closed. With the approval of this ROD there will be approximately 937 acres of barrens where use will be encouraged or allowed. These barrens will be shown on a user map." It also states that one third of the barrens in Clear Creek will remain open for OHV use: "The BLM recognizes both the inherent biological uniqueness of the barrens and the conflicting yet valuable recreational experience that the barren areas provide in the CCMA. By excluding vehicle use from two-thirds of the barren areas, and allowing use on those barrens located outside of the most ecologically sensitive areas, the BLM will achieve some measure of balanced use which can be evaluated for success in meeting resource condition objectives."

In recent meetings the BLM has been using the words "up to" instead of "approximately" and the SRMC finds this very troubling. The OHV community and SRMC will not settle for less than the 937 acres mentioned in the ROD

Cost of Fencing: A factor that should be included in the analysis of the barren areas is the cost of fencing to prevent trespass. The SRMC does not believe that signs alone will prevent trespass and that fencing must be erected to prevent access into protected barrens.

Barrens Study: The Dynamac study that the BLM commissioned is flawed in its analysis and should not be used in its present form to rate the barren areas. It is flawed because of the heavy weighting was given to OHV use. The data should be reanalyzed after excluding the score for OHV use. This score, however, should be used to identify those areas where use indicates high levels of recreation opportunity that should be preserved.

Routes: Since the San Benito Mountain Research Natural Area (SBMRNA) is encroaching on heavily used OHV areas, many of which are used each year for our national enduro, it is imperative that all of the major routes in any area considered for expansion remain open. This includes but is not limited to the Brushy Trail, the contour trail that parallels the North Ridge route (R010) and the routes around San Carlos Peak.

Also, all routes currently open for use within the SBMNRA must remain open for the following reason: this piece of land acts as a barricade, blocking user access to the route system to the east where a previous study recommended that use be encouraged. If access through the SBMRNA is not maintained, the OHV traffic would have to be funneled through a limited number of routes to the south, increasing the chances for head-on collisions between OHV users.

Barrens: From the outset of planning in the early 1990’s the OHV community has recommended that the barrens between R010 and the contour trail as well as the Bowl remain open for use. At one point you promised the OHV community that the Bowl would remain open and it was shown as an encouraged use area on a BLM map. The Bowl has very good attributes to sustain OHV use, as the Dynamac study indicates. It is one of the most popular destinations for Clear Creek campers to ride to and one fork of the Brushy Trail starts in the Bowl.

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