DRAMP/RAMP Comments

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

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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 08, 2010 5:13 pm

I 100% agree.
Of that group, SDORC was the only ORG to submit a letter to the BLM in regards to the DRAMP Scoping last year.
I don't think that the ASA is financially supporting those orgs (at least I hope not) , but the ASA is helping them / publically backing them on Hard Pack issues (via partnership with EcoLogic). Given such, I would certainly expect them to at least pen a letter and attend a meeting on our 'Sand Issue of the decade' here.
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Re: DRAMP/RAMP Comments

Post by Vincent J Brunasso » Thu Apr 08, 2010 5:51 pm

Woodglue wrote:I 100% agree.
Of that group, SDORC was the only ORG to submit a letter to the BLM in regards to the DRAMP Scoping last year.
I don't think that the ASA is financally supporting those orgs (at least I hope not) , but the ASA is helping them / publically backing them on Hard Pack issues (via partnership with EcoLogic). Given such, I would certainly expect them to atleast pen a letter and attend a meeting on our 'Sand Issue of the decade' here.
Ecologic will make comments via Dave Hubbard - that will cost a few dollars - dollars that come from all the orgs involved. So, yes, our sister orgs are supporting ASA RAMP efforts.
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Fri Apr 09, 2010 8:59 am

The Orange County ATV Association will be represented at the San Diego meeting. :wink:
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Re: DRAMP/RAMP Comments

Post by Woodglue » Fri Apr 09, 2010 10:10 am

Vincent J Brunasso wrote:Ecologic will make comments via Dave Hubbard - that will cost a few dollars - dollars that come from all the orgs involved. So, yes, our sister orgs are supporting ASA RAMP efforts.
It seems that these Orgs were much more involved in the past. For example, to provide a uniform comment on the 2002 DRAMP & DEIS, the ASA, CORVA, SDORC, AMA, ORBA and Calif Assoc of 4wd Clubs formed a consortium and employed a facilitator to conduct workshop sessions. In addition to each of the Orgs providing their own individual comments, a uniform comment letter was furnished to the BLM by the consortium in efforts to provide a single voice from the OHV Community. Is this not occuring again?

Vince, at a minimum, in addition to throwing some bones to EcoLogic, can the ASA express an expectation that the EcoLogic Partner Orgs to pen a letter to the BLM on the DRAMP?

I will personally do the same thing within the next week.
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Re: DRAMP/RAMP Comments

Post by sticksand » Fri Apr 09, 2010 11:52 am

:?: is the ASA going to make an official statement before the meeting(s) next week???
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Re: DRAMP/RAMP Comments

Post by gelwell » Fri Apr 09, 2010 11:56 am

sticksand wrote::?: is the ASA going to make an official statement before the meeting(s) next week???
My guess is probably not. But those of us that are going perhaps we should PM each other to see what we want to say.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Fri Apr 09, 2010 12:02 pm

sticksand wrote::?: is the ASA going to make an official statement before the meeting(s) next week???
From the mass e-mail that the ASA sent out yesterday afternoon:
The Draft Imperial Sand Dune Recreation Management Plan

COULD CHANGE DUNING

Forever!

Since its inception, the ASA has toiled toward the goal of reopening the 49,000 acres of temporary closures.

8 Alternatives were considered: 2 through 8 are all less favorable when compared to Alternative #1 (the baseline 1987 RAMP before the PMV listing). It is difficult for the ASA to recommend any other than #1 without calling for significant changes to the rest.

ASA has contracted with recreation and biological professionals to review the DRAMP. Once we have their recommendations and professional opinions, they will be made available to our members. We expect them in approximately 30 days. Shortly after, we will issue the consolidated ASA comments that will contain our final recommendation.

The BLM has scheduled the following public meetings.

You Must Attend To Learn What Is PROPOSED and how to make meaningful comments!
In the Preferred Plan (Alternative #8) we get:

INCREASED PERMANENT CLOSURES
DECREASED CAMPING ACREAGE
POTENTIAL RESTRICTED CAMP AREA USE
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
BLM will make a 10-minute PowerPoint presentation about the plan. BLM will then be available to take your questions.
You will be able to make official comments at the meetings.

The complete DRAMP documents can be found at the following location:

Link to BLM ISDRA DRAMP Documents

These will be the ONLY meetings
offered by the BLM.
I don't plan to make my comments at the meeting, rather in a letter prior to the Jun24 deadline.

I am penning a letter on behalf of my family dune group.
Question:
Is it better to have one letter with 5 people's signatures, or 5 separate letters that all say the same thing?
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Re: DRAMP/RAMP Comments

Post by Vincent J Brunasso » Fri Apr 09, 2010 12:10 pm

I don't plan to make my comments at the meeting, rather in a letter prior to the Jun24 deadline.

I am penning a letter on behalf of my family dune group.
Question:
Is it better to have one letter with 5 people's signatures, or 5 separate letters that all say the same thing?
In 2002, we were told that numbers counted. Recently, I heard that 1 letter on behalf of many counted the same but I'm not recommending we take any chances. IMHO 100 letters that all say the same thing carries more weight than a single letter signed by 100 people or one that says it speaks for 100.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Fri Apr 09, 2010 12:28 pm

Thanks.
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Re: DRAMP/RAMP Comments

Post by sticksand » Fri Apr 09, 2010 1:57 pm

my apologies I did get that E-mail and I will send a letter to the BLM after the ASA has stated its thoughts on the matter.

But I think it’s going to be hard to stay quiet at this meeting
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Re: DRAMP/RAMP Comments

Post by Woodglue » Fri Apr 09, 2010 3:04 pm

sticksand wrote:But I think it’s going to be hard to say quiet at this meeting
You can just vaguley state your position on the Alts ("I dont' see anything as good as what we currently have being offered to the OHV community in anyone of the Alts, cant endorse any Alt without substantial revisions, etc") and ask questions.
And, let me predict the future a bit:
CBD's Ileene Anderson will stand up and read something off a napkin that she wrote on the drive to San Diego stating that they are concerned about the "threatened PMV and the flat-tailed hill-billy lizard habitat". She will "endorse the dune closures of Alt3, and seek the camping closures of Alt8". She will depart before the meeting is over.

Bring your popcorn... it'll be fun! \:D/
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Re: DRAMP/RAMP Comments

Post by Mark@STU » Fri Apr 09, 2010 5:12 pm

Mr. Seaver

Has the facilitators format with respect these meetings been made public yet? I seem to remember the first RAMP run through a number of years ago started off with a one 2-minute commit period only and you couldn’t commit again regardless of how much time was left for the meeting. The facilitator change the format after the Long Beach meeting in part because some fool in the crowd of over 700 got upset and became a little loud :oops: because he had only one 2-minute commit with another, and another commit to make. He became frustrated that they were calling the meeting over, when we had over an hour left on the clock with much more to commit about.

Thanks for what you do everybody =D>

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Re: DRAMP/RAMP Comments

Post by Sandcock » Sat Apr 10, 2010 8:43 am

I'm a simple man and relatively new to the sport. Trying to understand all the history, studies, data produced by those studies, lawsuits, past RAMPs and the new DRAMP, for me is overwhelming. I will participate at the SD meeting with open ears and hopefully, from that experience, info from my duning friends, and managing to digest as much of the DRAMP as possible, I will put together a letter.

With that said, and the fact that I am a simple man, my common since tells me that the BLM needs to show the burden of proof, e.g. the supporting data, that supports alternatives 2-8. It is of my opinion that if the ISDRA OHV community has been coinciding with the natural habitat as it exists now where the duning experience can be enjoyed by all and no further negative impact to the habitat has occurred, then a DRAMP should be developed around that. Don’t reinvent the wheel, find better management solutions with what we have now to make the experience at the ISDRA enjoyable for all. I definitely would like to see the middle closure go away at Glamis.

It definitely would be beneficial to provide thoughts and ideas to those of us that struggle trying to understand the position of dealing with this issue.

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Re: DRAMP/RAMP Comments

Post by Vincent J Brunasso » Sat Apr 10, 2010 1:11 pm

Sandcock wrote: It definitely would be beneficial to provide thoughts and ideas to those of us that struggle trying to understand the position of dealing with this issue.scotty
ASA will have a meeting on May 15 at one of our supporting member's shops. The location is easy to get to and within an easy drive for 1000's of our members in OC & LA counties. So as not to steal anyone's thunder, time & place TBA soon. Speaker and guest speaker TBD.

For those of you that are new to this game since the last DRAMP meetings, topics covered will be:
1) Define the DRAMP & DEIS and the process for implementing them
2) Define valid comments & the comment process
3) Impart why the above should be of interest to duners
4) Explain the new RAMP & its major issues/contents in a general way
5) Suggest & Solicit useful comments
6) Make clear the deadline for making comments
7) Q&A

For starters, my comments are starting to shape up as follows but more reading is called for.
1) Closure of DB Flats according to rain fall - no supporting science for this action - large impact on visitors camping experience & large economic impact to nearby businesses & vendors
2) Closure of micrphyll woodlands to camping - no supporting science for this action - closure includes many acres that are not woodland - camping is already limited by nature of area
3) Closure of all PMV CH - no directly supporting science & science that says opposite. No legal requirement to close CH.
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Re: DRAMP/RAMP Comments

Post by Jerry Seaver » Sun Apr 11, 2010 4:52 pm

Mr. Seaver

Has the facilitators format with respect these meetings been made public yet? I seem to remember the first RAMP run through a number of years ago started off with a one 2-minute commit period only and you couldn’t commit again regardless of how much time was left for the meeting. The facilitator change the format after the Long Beach meeting in part because some fool in the crowd of over 700 got upset and became a little loud because he had only one 2-minute commit with another, and another commit to make. He became frustrated that they were calling the meeting over, when we had over an hour left on the clock with much more to commit about.

Thanks for what you do everybody

Mark@stu



Mark,
Neil will be the meeting facilitator and he told us that BLM will hand out cards for the commenter’s to sign in. Each speaker will be allowed 3 minutes. The meetings are scheduled from 6-9 pm. If time remains after all speakers he will allow anyone who did not finish in 3 minutes to continue with their comments or questions until the meeting close at 9 pm.
A few of us know who helped to establish this format over the old one, sometimes not being a shrinking violet pays off. Thanks Mark.

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Re: DRAMP/RAMP Comments

Post by Mean Green » Tue Apr 13, 2010 11:59 pm

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.[/quote]

Woodglue,
I have been racking my brain about this too for the past couple of days and the only logical thing I can come up with (in my own mind) is that the BLM wants to reduce the camping area so that they can better manage the visitors at the ISDRA. Theoretically, by putting up a “NO VACANCY” sign on major holiday/visitation weekends they can better control and document the amount of visitors. They can subsequently appropriate funds and personnel more effectively with fewer visitors due to limited camping areas. Hindsight now is 20/20 but the BLM had no intention of allowing camping past Wash 25 when they built the new Wash Road. I hope I am way off base.

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Re: DRAMP/RAMP Comments

Post by RobC » Wed Apr 14, 2010 8:52 am

Regardless of how often this happens, THIS PART OF THE PREFERRED ALTERNATIVE IS NOT GOOD!!

From page E-1 of Volume 2:

In years where the rainfall threshold is met and 1.82 inches of rain falls in the Planning Area from October 1 through December 31, the Dunebuggy Flats campground would be closed to camping for the duration of the PMV growing season (January 15 through June 30). The Dunebuggy Flats campground would again be open to camping beginning July 1 and remain open until the rainfall threshold is again met.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 9:09 am

Yes, and the same problem is present in the same Alternate (#8) with a camping closure stretching from Wash25 to Wash69.

During last night's San Diego meeting, BLM (Erin Dryfus) stated that based upon the rain records, they forecast the DB Flats closure to occure once every 7 or 8 years. Shortly thereafter, a woman spoke and disagreed with this frequency that BLM (ED) stated. The woman referenced historicals in the DRAMP and noted "in the past 24 years that 9 rain events had exceeded 1.82" which would mean a closure once every 4 or 5 years". I have not looked into this yet, but this might be another place where Erin was incorrect in last night's meeting.

Fact Reamains, there is no PMV Critical Habitat in the DB Flats area. So, why close it? Even when it does rain alot.
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Re: DRAMP/RAMP Comments

Post by crash » Wed Apr 14, 2010 10:31 am

I attended the BLM meeting last night in San Diego and came away with only a couple things.

1) The BLMs path has already been chosen, and we were one of the least considered factors in crafting "alternatives".

2) This was the first meeting I have been at where people, many people, were asking for mitigation for any lost access to OUR resources. THAT WAS GREAT!!! Something a couple people had been screaming about on this BBS years ago.

3) That eco Weiner was completely delusional...and lying when she said she enjoys walking accross the middle of the dunes.

4) This just kinda hit me this morning. I know it would be a HUGE amount of work, but has anyone considered a path were a privately owned "duning company" acquired a lease to the sand dunes? I mean if geothermal and mining interests can come into a BLM area and essentially close off all public access that doesn't go by their guidelines, why can't duners do the same? Apply for a land lease for THE ENTIRE DUNE SYSTEM FROM THE 78 TO THE BORDER. If it is acceptable for private energy and mining companies to COMPLETELY reshape the land and leave it NOTHING like it was before, surely what we do can be permitted MUCH easier.

I know there are a lot of hurdles to this idea and most of us, unfortunately, have much bigger problems to deal with right now than a project as complex as this would be, but I think I am thinking outside the box here and the idea COULD have some merit.

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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Wed Apr 14, 2010 10:35 am

I haven’t looked at the data yet, either, so it is possible that Erin is incorrect, however, I’m will to be she is not. (anyone care to wager??? How about a 6 pack of ones favorite ICB?. I’ll bet on Erin.)

We have to remember that the 1.82” rain event has to happen between Oct and Dec 31. Rain that happens after Dec 31 is not counted. I suspect that the lady who disagreed with Erin did not ‘do the math’ properly for Oct through Dec.

Doc has posted on Glamis Dunes.com that in the last 44 yrs, there has been 9 events that qualify and ONCE in the last 10 yrs. We should also keep in mind that once approved, this RAMP is up for review in 10 (or 15, not sure) yrs. As an FYI, this year, for Oct to Dec, there was only .40” of rain and the season total of rain so far for this year does not equal 1.82”.

To answer your question, and this is my opinion, because BLM has not stated; the reason to close Dune Buggy Flats camping is that with no close by camping, that Critical Habitat area of high PMV concentration would see a substantially reduced OHV use during the prime PMV growing season.

The one thing that we cannot lose sight of, and it was somewhat well summarized by Mark Harms late in the meeting: ANY alternative that the BLM ‘prefers’ and wishes to implement, MUST pass muster with Fish and Wildlife. If not, then it won’t go. Period. This is a constraint that BLM has to meet. Yes, I understand the concerns of closing the Dune Buggy Flat’s camping area IF a rain threshold is met. And, no, I haven’t finished reading the document yet, so comments by me are somewhat premature, but if we can find a solution for mitigating the ‘Flats’’ closure, then Alternative 8, IMO, is a reasonable deal.

I’m sure there is more to come.
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Wed Apr 14, 2010 11:09 am

Yes, crash, that idea has been considered and discussed before, here and elsewhere. Yes, it is an ‘outside the box’ idea. My comments below are meant for discussion, not ridicule or insulting. IMO, all ideas are valued and need to be discussed.


1. Private companies leasing public lands are still, AFAIK, required to abide by the Endangered Species Act. So, even if such a company were interested in the ISDRA, and had the resources (read that MAJOR $$$$) to undertake the project they would STILL be required to go through this RAMP process because the PMV is a listed species. A plan would have to be in place, approved by the Fish and Wildlife service. And that plan would have to survive all the legal challenges from the CBD. Is there a private company out there that is willing to assume this risk?

2. Right now, the costs for monitoring the PMV, which by its self amount to a few million dollars every few years or so, are borne by ALL the taxpayers. User fees under FLERA are not to be used for ESA mandated endangered species monitoring. Who would pay for such REQUIRED monitoring under a private lease agreement?

3. We currently are not happy with the amount of $$$ we pay in Fee Taxes. (read that Permits) I personally, don’t feel we should have to pay a DIME. It’s public land. But lets also keep in mind that the $$$ we pay now, by no means, equal the ENTIRE budget the BLM has to run the place. They get State Green Sticker Grants and federal appropriations ($$$ from Washington) and sometimes locals funds as well as our user fees. Are we willing to pay more (and, IMO it would be a minimum of 10, but more likely 100 times more) then we are now? Remember, a private company MUST make a profit. All of their income would HAVE to be generated by the users. That means US.

Yeah, I don’t like the user fees. But, as I’ve posted else where, for this year, I purchased one season pass. I’ve gone to the dunes less this year then any of the last 5 years---17 days. For me, that’s $5.29/day. Most private camping I know of starts around $40/day. (And that’s dirt cheap. Dockweiler Beach is charging $55/day. )For me, that would have been $680. Looked at that way, even though I complain, it’s not such a bad deal, is it?

That’s just (3) major hurdles I can think of off the top that would need to be addressed by a private company takeover project.

Is it doable? I don’t know. I know that if I hit the lottery and had millions to burn, I personally wouldn’t throw it away on such a project.

What say you?
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Re: DRAMP/RAMP Comments

Post by crash » Wed Apr 14, 2010 11:20 am

Truthfully, I think the biggest hurdle would be the insurance that would have to be held for the operation.

We're already paying for all the studies and other BS, so why shouldn't we have a bigger say in what actually happens on the land like a lease holder would?

We were already told last night, straight out, that no one was consulted initially when forming alternatives from the OHV community. What is wrong with THAT picture? Maybe that would change as a lease holder?

If it was no longer under the control of the government, but rather a private enterprise, would there be any need for green stickers? I know many years ago, I was not required to license anything that I kept strictly upon and operated upon my private property. Is that still the case? If so, there's $250+ that I wouldn't have to spend already and could put toward a private enterprise, not to mention the $90 per support vehicle fees. Now there's talk of an extra $25 fee per night? Looks like the cheap camping is getting right on par with other places to camp to me.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 11:22 am

L&L Corvairs wrote:... but if we can find a solution for mitigating the ‘Flats’’ closure, then Alternative 8, IMO, is a reasonable deal.
Lloyd, Are you not concerned about the "Wash25~Wash69’’ closure???
To me, DB Flats and Wash Road camping closures are BAD news, as it will crowd other camping areas. More safety issues, more deaths, more congestion, more ppl upset with closer camp neighbors, camp racers, etc. I can imagine "Camping Rage" (like Road Rage) becomming a common place in our limited use camping areas if these restrictions occur!

In an efforts to compromise on Alt 8, I can give up Wash 44~Wash69 (the currently closed camping area) IF we can keep Wash 25~Wash43 AND DB Flats open to camping.
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Re: DRAMP/RAMP Comments

Post by Glamisbound » Wed Apr 14, 2010 11:29 am

OK, this is a repeat post I made in the other thread...seems more appropriate here FWIW

Well, the guys above covered the meeting pretty well, including the court reporter, who I'd personally like to thank! :mrgreen: I didn't even notice she was on the phone like Lloyd pointed out... :shock:

My take on the meeting was that it was marginally worth it. Now I don't want to throw people down for making comments, especially since I chose not to....but I really feel compelled to. I do it in hopes that people attending the next meeting will learn from this, because it really is a waste of time for everyone, when people say really stupid things that are unsupported and unrelated to the matter at hand.

For those that weren't there, one greenie in the audience spoke about particulates air pollution and whether or not the BLM would be installing air monitors....Let me tell you, I'm all for giving the other side their chance to speak, but this BS was totally unrelated to what we were there for. And that pissed me off. She also expressed her interest to hiking in the dunes but was not willing to hike in the closed area north of the 78 because there is no where to park over there....like it's a really long walk from Gecko... #-o

One thing I think we really need now are stats on is how many times, in say the last 20 years, did Gordon's Well meet the rainfall threshold that would trigger closing Dune buggy flats to camping. If it's every three years, that would be a lot different than once or twice in the last 20 years.
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Wed Apr 14, 2010 11:32 am

Woodglue wrote:
L&L Corvairs wrote:... but if we can find a solution for mitigating the ‘Flats’’ closure, then Alternative 8, IMO, is a reasonable deal.
Lloyd, Are you not concerned about the "Wash25~Wash69’’ closure???
To me, DB Flats and Wash Road camping closures are BAD news, as it will crowd other camping areas. More safety issues, more deaths, more congestion, more ppl upset with closer camp neighbors, camp racers, etc. I can imagine "Camping Rage" (like Road Rage) becomming a common place in our limited use camping areas if these restrictions occur!

In an efforts to compromise on Alt 8, I can give up Wash 44~Wash69 (the currently closed camping area) IF we can keep Wash 25~Wash43 AND DB Flats open to camping.
As I said, I haven't read it all yet, and haven't come up with my 'Final Answer'. Yes, I'm concerned about Wash 25 to 69. I have not yet assertained how many people this will displace. I've camped at DB flats, and have a fairly decent perception of how many people that might displace. I will reiterate that DB Flats ONLY closes when there is a 1.82" Rain Event between Oct 1 and Dec 31, which has happened once in the last 9 years.

At the end of the day, I'll probably submit my own 'Alternative', just for the hell of it.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 11:41 am

L&L Corvairs wrote:At the end of the day, I'll probably submit my own 'Alternative', just for the hell of it.
That is my plan as well, including my own Geothermal and OHV / Camping Access Maps.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 11:41 am

To avoid that we have duplicate posts all over the place:

I propose that we use the DRAMP/RAMP Comments thread for comments to the BLM about the RAMP / DRAMP.

And that we use the BLM RAMP Meetings thread for discussing the plans and outcomes (inclusive of any interesting sightings :wink: ) of the BLM RAMP Meetings.
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Re: DRAMP/RAMP Comments

Post by sticksand » Wed Apr 14, 2010 1:46 pm

Alternative 8 would suck for anyone who camps at Gordons well =(
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 2:01 pm

sticksand wrote:Alternative 8 would suck for anyone who camps at Gordons well =(
Indeed, but when you consider the Geothermal aspects that all the other Alts have... Alt#8 sucks the least.
I recommend that we all compose our own Alt, using 8 as the basis, showing camping / dune closures only where you'd like to see them and submit it to BLM as our comment.
Pie in the sky for us, is to have no closures anywhere. However, there are limitations on how practicle that is when you consider that this RAMP will have to go through court, with the BLM and USFWS backing it.
So, I'm thinking that some form of management of all PMV Critical Habitat needs to be included. Given that there is no law that PMV CH needs to be closed, I don't think the BLM needs to go to that extreme.
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Re: DRAMP/RAMP Comments

Post by sticksand » Wed Apr 14, 2010 3:58 pm

Alt 7 witn no geothermal would be prime I think for everyone IMO
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 4:20 pm

sticksand wrote:Alt 7 witn no geothermal would be prime I think for everyone IMO
I agree, except....
Last nights meeting, I learned that Patton Valley is not in the PMV CH.
The irregular shape of the closure in Alt8, keeps much of Patton Valley open.
The polygon shaped closure of Alt7 closes Patton Valley.

BLM confirmed that showing the Closure on the ground is going to be done the same way as it is now (with stakes). I was concerned about being able to know where you are in this jig-jog pattern of open & closed dunes. I was in favor of a more regular shape for this reason... until I learned that it would close Patton Valley.

I've never been to Patton Valley, but I know it has great value to many who frequent the South Dunes.
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Re: DRAMP/RAMP Comments

Post by sticksand » Wed Apr 14, 2010 4:25 pm

Outstanding!! what did thay say about I-8 Hill anything on that??? also the camping closure form wash 25?? why?
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Wed Apr 14, 2010 4:33 pm

Mike,

I think we are forgetting the FWS. Closing the CH is what the BLM is doing to get FWS to buy off on it. Agreed, there is no LAW that says the CH must be closed, but if FWS does not accept a plan unless it has closures for the CH, what do we do? Take FWS to court and argue what? How? That FWS doesn’t know what it’s doing? They may not, but I think we would hard pressed to prove it. AND, while we battle them in court, we are still stuck with the current situation, Alt-2 for how many more years? Also, what happens if, after all that time, the judge sides with FWS?

Here is where us, the general public IS at a disadvantage and where I agree with the one speaker from last night. We can’t sit with FWS and discuss a new Alternative, call it the Woody-Corvair Compromise, and get an idea of what they would approve.
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Re: DRAMP/RAMP Comments

Post by gelwell » Wed Apr 14, 2010 4:36 pm

sticksand wrote:Outstanding!! what did thay say about I-8 Hill anything on that??? also the camping closure form wash 25?? why?
The I8 hill aka Test appears to be OK with alt 8.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Wed Apr 14, 2010 4:58 pm

sticksand wrote:Outstanding!! what did thay say about ... the camping closure form wash 25?? why?
As is stated in the DRAMP, it's being proposed in Alt#8 as closed to camping (but not OHV traffic) to protect the Micro Woodfil habitat (sp?) (i.e. the bushes that we all stay away from).
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Re: DRAMP/RAMP Comments

Post by Mean Green » Thu Apr 15, 2010 3:31 pm

The El Centro meeting for a lack of a better word seemed pretty useless to me. There were only about 35 people present and I think 8 total speakers. The meeting only lasted till 7:30p. They gave each speaker 2 five minute sessions to speak. I had q's and comments for both times I spoke. They are pretty much set on ALT 8. I don't know what it will take other than litigation to get them to revamp the proposed camping area closures and the closing off of the PMV CH for OHV use in Alt 8. I don't know how much weight our comments will be given. A couple of speakers commented on the Air Particulate from the dust over the dunes affecting the asthma rates in Imperial County and a couple of people spoke about implementing a day use fee in the DRAMP. I sure hope the Phoenix turnout is better and the meeting is more productive.

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Re: DRAMP/RAMP Comments

Post by Woodglue » Thu Apr 15, 2010 3:43 pm

Thanks Mr. Green.
There is some additional information about your meeting in the BLM RAMP Meetings thread.
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Fri Apr 16, 2010 9:14 am

Thanks, Mr Green for attending. Your cointinued participation is appreciated.
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Re: DRAMP/RAMP Comments

Post by Sloppyduner » Fri Apr 16, 2010 10:56 am

Thanks to everybody going to these meetings and posting the info here. Alt 8 gives us alot to work with, but theres still lots of work to be done tweeking it... or trying to. I'm sure it"ll come out during the May 15th meeting, but since it looksw like Alt 8 is the one the BLM is leaning does that mean we have to put in comments on all other alts or just Alt 8. As I type this it hits me that duh ya. I'm guessing ALL alts need comments.

Also from the reading of the going ons at these meetings that Air Particulate is going to be a HUGE issue here in the future. Glamisbound posted something to the effect that the one lady was talking about it. I haven't read anything about it in the DRAMP but I do know that its going to affect us in the future and I would like to see a thread on it.
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Re: DRAMP/RAMP Comments

Post by Woodglue » Fri Apr 16, 2010 12:00 pm

Sloppyduner wrote:Also from the reading of the going ons at these meetings that Air Particulate is going to be a HUGE issue here in the future. ... I haven't read anything about it in the DRAMP but I do know that its going to affect us in the future and I would like to see a thread on it.
You are correct Slop, it can become a big issue.
The topic was posted on the public record at both the San Diego and El Centro Meetings.
One place in the DRAMP that you'll find Air Quality discussed is:
Section 2.3.2 on Pg 2-6 wrote:2.3.2 Air Resources ManagementThe FLPMA and the Clean Air Act (CAA) of 1970 and Amendments of 1977 and 1990 (42 USC 7401 et seq.) prohibit BLM or any federal land management agency from conducting, supporting, approving, licensing, or permitting any activity on federal land that does not comply with all applicable local, state, and federal air quality laws, statutes, regulations, and implementation plans. In support of these regulations, a program has been developed that provides benefits to air quality and other resources by decreasing air pollutant concentrations, increasing visibility, and decreasing atmospheric deposition. Adherence to air quality regulatory programs through coordination with other federal and state agencies is a key to air quality management success.
Other applicable regulations include:

Applicable National Ambient Air Quality Standards (NAAQS; Section 109)

State Implementation Plans (SIPs; Section 110)

Control of Pollution from Federal Facilities (Section 118)

Prevention of Significant Deterioration, including visibility impacts to mandatory Federal Class I Areas (Section 160 et seq.)
2.0 Description of Alternatives

Conformity Analyses and Determinations (Section 176(c))
In the San Diego Meeting, Terry Weiner of the Desert Protective Council stated that Imperial County is mandated by the EPA to comply with “Rule 800”. She noted that this was not listed as one of the applicable regulations in the DRAMP. I do not know if the Imperial County has been mandated by the EPA to comply with Rule 800, but she appears to be correct in stating that the DRAMP does not include Rule 800. T. Weiner also asked if Air Quality Meters would be installed. BLM confirmed that they will if requested to do so.
This is spelled out in the DRAMP, as follows:
Section 2.3.2.2 on Pg 2-7 wrote:2.3.2.2 Management Actions Common to All Alternatives

Comply with the State of California for all proposed actions that would contribute to particulate matter emissions in the air as a result of actions taken.

As needed, based on the Dust Control Plan (once approved by Imperial County Air Pollution Control District [ICAPCD]), treat the following access roads for dust control to reduce the impact of OHV activities on air quality, as personnel and funding levels allow: Wash Road adjacent to the Union Pacific Railroad (UPRR; from south of Glamis to the Clyde Overcrossing) and the entry road to Dunebuggy Flats Campground.

Install air meters for ozone and particulate matter less than 10 microns in diameter (PM10) in the Planning Area, if requested by ICAPCD or the Environmental Protection Agency (EPA).
Implement actions to mitigate for contributions to the non-attainment due to activities in the Planning Area, as requested by ICAPCD, and as personnel and funding levels allow.

Evaluate impacts of activities within the Planning Area to air quality non-attainment. Implement BLM dust control plan to improve air quality as required by the ICAPCD.
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Re: DRAMP/RAMP Comments

Post by Mean Green » Fri Apr 16, 2010 3:34 pm

L&L Corvairs wrote:Thanks, Mr Green for attending. Your cointinued participation is appreciated.
Thank You L&L, I am trying.
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Re: DRAMP/RAMP Comments

Post by Sandcock » Sun Apr 18, 2010 5:49 pm

I was looking to learn more about the situation the confronts us. I did learn somethings, but much of the commenting appeared to be individuals with there pet peeves, i.e. shooting off of illegal fireworks, less encroachment of LE, and the ranting and interruption of the same few.

What I did gather from Neal was that he thought Alt. 8 is what FWS would most likely go along with. Also, the proposed closure at DBF where they ride currently is heavily vegetated. If that is so, then the vegetation and off-raoding is co-existing well. So, why close an area?

In regards to the proposed closure of the microphyll woodlands south of W25, its not like there isn't an unsurmontable amount of microphyll woodlands on both sides of the dunes and throughout the desert. As WoodIsGood is alluding to that BLM needs to think out of the box. If FWS and the CC doesn't agree with it then legal challenges can take place.

As I've stated before, how do you eat an elephant? One bite at a time. That is exactly what is happening right now and we have not found a way to stop the bleeding.
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Re: DRAMP/RAMP Comments

Post by Sandcock » Mon Apr 19, 2010 4:38 am

I somewhat recall some training that I got in the military many moons ago. It kind of goes like this: You are in the heat of battle and your leader has planned a way to take the enemy with casualties. You as a subordinate see a better way so as not to lose as many casualties. It is incumbent of you to persuade the leader to take that position.

People, the new management plan will change your recreational experience. You need to take the time to comment. You also need to spread the word. I spoke to a few at Glamis this past weekend and not one them understood what was happening. What I got was: "oh, I remember when we could ride over there" and "I've been coming to the dunes since I was (you fill in the blank)."

The experience at the ISDRA is a part of your life and for many has been passed down to you from past generations. Take up the cause.

Another military expression that I often use is: Is this hill worth dying for? (Please don't take my expression of "dying literally, it is meant as worth fighting for) You need to ask yourself that question.

I am a Bible thumper and have read the Bible all the way through 4 times. Each time it took me a year. I’ve been a Christian for many years. The Bible is/can be a difficult read. I still need to be taught what is in it and what it means. The DRAMP is a difficult read and although June seems distant at this point, it will be upon us. Realistically, many will not be able to read through the document. With that said, and for the aSa leadership, there are many that need help in understanding the DRAMP and need guidance in providing meaningful comments. I realize that there is an aSa meeting in the works to help, but there will be many that will not be able to attend. Will there be help for those that need it?
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Re: DRAMP/RAMP Comments

Post by Rick Bowen » Mon Apr 19, 2010 7:46 am

If these questions has been previously answered, forgive me....

So I understand that comments will be taken until June 24th.

Does anyone know what the timeline will be beyond that?
FWS approval?
Return to court to get the Judge to accept?
Implementation of (whatever) alternative is selected?
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Re: DRAMP/RAMP Comments

Post by RobC » Mon Apr 19, 2010 9:18 am

From the meeting I was at, here is my understanding (IIRC):

BLM makes their selection.
Then it goes to the USFWS who has to agree that it is the right decision.
Then is goes back to the court (Judge Illston) for her approval.

The guy at the meeting said 6 - 8 months, which I kinda doubt. Especially if the enviros object to any of it. This is only my opinion though.
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Re: DRAMP/RAMP Comments

Post by jhitesma » Mon Apr 19, 2010 9:58 am

RobC wrote:From the meeting I was at, here is my understanding (IIRC):

BLM makes their selection.
Then it goes to the USFWS who has to agree that it is the right decision.
Then is goes back to the court (Judge Illston) for her approval.

The guy at the meeting said 6 - 8 months, which I kinda doubt. Especially if the enviros object to any of it. This is only my opinion though.
And then the new round of lawsuits start.

Honestly I see absolutely no reason to get involved in the comment BS again this time.

Why?

Reason 1: Past history has shown that the BLM won't really listen anyway. They'll include the comments and then dismiss them with BS responses that basically boil down to "We made our decision before the comment period which is just a required formality so live with it."

Reason 2: It really doesn't matter. The "Official" way that this is supposed to happen isn't how it will happen. Just like last time it won't be through the official scoping process that a RAMP is achieved, it will be through lawsuits brought by either our side, the enviros, or both. And only the lawyers will have a say in that. And frankly I have no reason to believe that the laywers on our side have my best interest in mind anymore, nor do I still believe there is any way for a mere member of the ASA to have their voice heard. So bottom line - there really is nothing the average duner can do other than donate money and then pray that the ASA BOD's thinking is in line with their own.

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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Mon Apr 19, 2010 10:20 am

Rick Bowen wrote:If these questions has been previously answered, forgive me....

So I understand that comments will be taken until June 24th.

Does anyone know what the timeline will be beyond that?
FWS approval?
Return to court to get the Judge to accept?
Implementation of (whatever) alternative is selected?
FWIW...

Rob, not meaning to disagree with you, and I might not remember correctly, but at the SD meeting, we hammered Erin fairly hard on this.

The BLM and FWS are not bound by any timelines beyond a few proscribed by law. They must have the 90 day comment period, which we have now. After that, they have as long as they like to produce the final RAMP and of course, FWS has to issue their opinion on it. At that point, there is a ‘protest period’ (which I think she said was 60 days’) Only those of us who have provided comments during this 90 days can file a ‘protest’ Protest means we can disagree with ‘The Plan’ at that point.

I honestly don’t remember how the BLM is to resolve the protests. Perhaps Woodglue can help me out there. But at some point after the protest period, the BLM will enter a Record of Decision (ROD) on the RAMP in the Public Register. It is at that point, when the lawsuits, if any, will begin.

Except for this 90 day comment period, and the 60 day protest period, there are no set time requirements. When pressed, Erin admitted that this is a 3yr process and we are about half way through. However, I am assuming that Erin’s comment does not include or consider delays due to legal proceedings.

As best as I can remember, it takes 1 to 2 yrs to get something through Illstons court. My personal prediction is we have another 3yrs to go, assuming that:

1. The ASA doesn’t file additional lawsuits….and…
2. The CBD loses it’s lawsuit and doesn’t get a stay granted while it appeals.

If the CBD (or the ASA) wins a lawsuit against either the BLM or the FWS or both, it is highly probably that we get to start over, in which case we could be looking at doing this yet again in 2016.
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Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Mon Apr 19, 2010 10:38 am

Jason, respectfully….dude…

What gives??? Had to look twice at the author. Sounds like something a defunct .org would write. The pessimism seems a bit extreme. Is everything ok in your world?

Sure, our comments might not make a difference, but they can’t make a difference if they are never submitted.
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Re: DRAMP/RAMP Comments

Post by jhitesma » Mon Apr 19, 2010 11:58 am

L&L Corvairs wrote:Jason, respectfully….dude…

What gives??? Had to look twice at the author. Sounds like something a defunct .org would write. The pessimism seems a bit extreme. Is everything ok in your world?

Sure, our comments might not make a difference, but they can’t make a difference if they are never submitted.
Just facing reality and learning from the past. I've never been one to hold back my true feelings. If I think something needs to be said I've never hesitated to say it.

I hate repeating history, learning from it is the only way to prevent that. And right now all I see is a lot of repeated motions that lead me to believe no one has learned.

As I sit here a month away from welcoming my first child into the world I do so knowing that she will never get to experience the dunes in the way I've spent the past 10 years of my life looking forward to sharing with her. It's not a position I ever wanted to be in, and it's one I've spent a lot of my life fighting to prevent.

The dunes I knew and loved are gone. And nothing in the RAMP would bring them back. No org is actively fighting to fix the existing issues with BLM managment and the new proposals only open the doors for more abuse and more duners being turned into criminals.

But bottom line hard reality is the input does not matter because the real decisions will not be made by following the rules and working within the system. They will be made in court. The system is broken beyond repair and we lack the resources to fix it - which means the imperfect court system is our only recourse. A court system which has shown repeatedly that it is not the unbiased bastion of justice it is meant to be and which places our side at a distinct disadvantage despite having plenty of evidence and proven science on our side thanks to activist judges who follow their heart rather than the facts of a case.

Frankly it's no different than the opinion I've had almost since day one. Working with the BLM is a waste of time as anything other than a temporary stop-gap measure. The real problems are higher up and where we need to be focusing our energy.

L&L Corvairs
ASA Board Member
ASA Board Member
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Location: Ontario, Calif.

Re: DRAMP/RAMP Comments

Post by L&L Corvairs » Mon Apr 19, 2010 1:34 pm

Wow. And wow again.

Obviously, Jason, you’ve given up. If I were to adopt your logic, then I should sell my toys and find a new pastime. It’s broken beyond repair, the courts are corrupt and there is nothing any of us as individuals can do, etc. It’s all up to the lawyer(s) that the ASA hires and the BLM has made it’s final decision. This is all a waste. Etc and more etc.

Sounds very defeatist to me. And that’s your choice. To be sure, you may very well be correct. Our comments may not have one whit of impact on the final RAMP. The process could be corrupt and the final decision will be made in a corrupt courtroom by a corrupt judge. However, THIS process is all we have. There isn’t another. Eventually, there WILL be a RAMP. Even you have to admit that, Jason. I can’t speak for Neil or Erin, and I’m sure they will never respond here, but I have spent some time talking with them. They are, IMO, earnestly trying to do the best job they can, and it is to Erin’s committee that our recommendations are going to be evaluated. Sure, the final product might be changed at the State or Federal level, but it will be changed based on what this committee produces. And I’ll be honest. I believe them when they tell us that they will look at every comment they get back. That doesn’t mean any of them will be incorporated. But that is the way the process works. We can’t fault the BLM, or it’s employees for running the ‘process’. We can’t fault the BLM for the process. Or the FWS. That was created by Congress. It’s taken us 10yrs to get HERE, with, in reality, very little $$$. I’m all for changing the ‘process’, for changing the ESA and for throwing out the supposedly corrupt people involved. Show me that plan and I’ll be the first to sign up. But there isn’t any such plan, nor any organized group to try it. And even it there was, how many years would it take and would it even be successful?

Yes, the dunes have changed a lot in 15yrs. Change is inevitable. Some of it we like, some of it we don’t, and what one likes or dislikes is very individual. No, the dunes won’t ever be the ‘way they were’. I’d be just as happy if the internet and cell phones had never been invented, either. Along with long travel, high horsepower sand cars. We can bemoan how bad it is. There are few people still involved that remember duning in what is now the Wilderness Area. And I’ve never personally ridden in the current ‘temporary;’ closure.

Danny Patterson once said, in response to being corrected that the current closures were ‘temporary’ that “If they are closed for as long as you live, it doesn’t matter what YOU call them”(sic). To be sure, that is the goal of the CBD.

But I’m not ready to give up or sell my toys. Yeah, I’m prepared to accept that we are not going to get every last inch back that was closed. Because like the internet and cell phones, that’s just the facts of life, folks. Should we quit trying because there is the possibility that it doesn’t matter? Jason’s same arguments can be used to justify not voting in the next election, too. Again, that’s a personal choice. For me, I can’t quit that easily. The last dog ain’t been hung yet, nor has the fat lady sung yet.

Guess that’s why I still vote in every election. My opinion is: If you ain’t participating, (like, say voting) then you don’t have a right to complain about the outcome. And right now, that participation is sending in data backed comments on the DRAMP. Hopefully, by doing as much as I can, my grandchildren, who are now 2, 4 and 5, will have the most open area in the ISDRA to ride in, when they are ready.
L&L
It is not ours to decide the times in which we live.
It is only ours to decide what to do with the time given us.

Make the most of your time.

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