Please send your personalized comments by October 24 to:
U.S. Department of the Interior
Bureau of Land Management
Monticello Field Office
435 North Main
Monticello, UT 84535
Recapture Canyon Environmental Assessment Comments
Great Old Broads for Wilderness finds none of the alternatives as proposed to be fully acceptable. We do not support Alternatives A, B, or C, as none of these Alternatives protect cultural sites or natural resources as required by BLM’s own route minimization criteria and in the purpose and need statement in the EA to “to minimize damage to cultural and natural resources”.
Broads supports a potential hybrid of Alternatives D, E, and F as follows. BLM should:
- Stabilize and restore ALL archaeological sites impacted by the 2005 illegally-constructed ATV trail (not just those in the route segments in the EA), as directed by the 2007 closure order. The closure order should not be lifted nor project implementation begun until this critical first step is accomplished.
- Not allow any public motorized vehicle use below the rim or in the bottom of Recapture Canyon.
– Rewarding the illegal route construction with an authorization for use after the fact sends the wrong message that scofflaws should simply take things into their own hands.
– Segments 2 and 6 should be permanently closed to ATV use as they are below the rim of Recapture Canyon. Additionally, these segments have sections that are steep and highly erodible and not suited for vehicular travel.
- Designate motorized use routes above the rim only, to concentrate existing use and minimize impacts to resources. Some use has occurred in these areas for decades.
- Designate a simple hiking trail through Recapture Canyon but minimize amenities and route construction. This will concentrate foot traffic and minimize duplicate trails/braiding.
– This trail will require erosion control, maintenance, and monitoring/patrols.
– Stabilize and obliterate unauthorized and undesignated routes and trails.
- Gate and lock Segment 1, the Water Conservancy District pipeline road, at a parking area below the dam/spillway to prevent unauthorized motorized use. Vehicle use should be restricted to that needed for administrative purposes only.
- Close Segments 1 and 2 to motorized use to limit potential cultural site damage and reduce impacts on riparian areas and wildlife. This will reduce recreational user conflicts and will provide for a safer user experience while better protecting cultural resources.
- Not issue any Right of Way (ROW) to San Juan County but retain all management and control within BLM. Recreational hiking and ATV trails are not necessary transportation as described within the Federal Land Policy & Management Act. The Bulldog to Blanding ATV trail already provides transportation between those locales and Title V ROWs are not appropriate for these public uses. San Juan County has not proven to be a trustworthy partner regarding ATV trails on public lands as they were complicit in the initial illegal construction of the Recapture Trail (an ATV stile built of scrap metal placed at the head of Browns Canyon) and a number of other trails on public lands without proper process or authorization.
- Allow camping in the bottom of Recapture Canyon with mitigation measures, such as designation of sites or campfire prohibition to reduce natural and cultural resource impacts. Camping along the rim should be allowed consistent with the Resource Management Plan.
- Limit group size (commercial and recreational) to 12 persons or ATVs (similar to restrictions in place on Cedar Mesa Special Recreation Management Area) to minimize impacts on the resources and other users. Group sizes of 24 ATVs is not appropriate in this setting and proximity to town and cannot be monitored or managed by the group leader.
With the limited resources BLM has in the Monticello Field Office, BLM should not be spending scarce resources on unneeded development of an ATV trail system or road improvements, parking areas and trails. Many places in the field office that see much higher levels of use are in dire need of proper management, maintenance and enforcement. Do not create burdens that BLM cannot manage within existing and projected ongoing resources.