BRC Gordy’s Hill in New Mexico Releases Environmental Assessment for Public Comment on BLM Lands

[Simone Griffin]

Our members previously engaged in this project through the Scoping period. The BLM has now released the second part to the planing process which is the Environmental Assessment (EA) and the public can submit comments on it up until August 30, 2022. You can read our previous post regarding the proposal here.

The EA released, covers a 10,514 acre area that will update the Travel and Recreation Management Plans. Three new alternatives are being proposed with alternative D being the “recreation friendly” alternative.

You can see from the chart above that Alternative D allows the most routes to be open (other than the current plan, Alt. A), with a total of 128.1 miles of routes but 54.1 of those routes will be limited use. BRC doesn’t believe this is a true recreation alternative because Alternatives A and C have elements we would like to see in a recreation alternative. We believe the BLM needs to analyze an alternative that expands upon the current recreation amenities, keeps the maximum number of routes open as possible, and only closes routes because of compelling needs to mitigate environmental impacts. The closure of routes do to limited use isn’t a good reason for permanently closing routes. Because of the acknowledged light use, the environmental impacts would be negligible, and there is no harm in keeping the routes open. Alternative A also proposed staging areas and other recreation amenities such as toilets, shades, campgrounds, etc. that should be included in a recreation alternative. Permits for events such as races and other special recreation permits would be unlimited through Alternative D, which is also an appropriate element for a recreation alternative. Even though the creation of new routes isn’t in the scope of this project, we hope that in the future the BLM will consider the construction of new routes based on this provision in the EA:

“The construction of new routes is not in the scope of this project; however, the possibility of future addition of new routes is part of the operation and management of the overall travel network (see Implementation Guide). As part of ongoing travel management associated with this Travel and Recreation Area Management Plan, route designations may be added or changed in the future to respond to growing public demand for access, rights- of-ways, or concerns of damage to resources”

https://eplanning.blm.gov/public_pr.../250070073/Johnson Hill EA_DRAFT_20220624.pdf pg. 14.

Although Alternative D closes the least amount of mileage to motorized use, BRC believes those routes still provide a purpose and need and should not be decommissioned. We understand there is always pressure within BLM offices while planning travel networks to close routes, but there is no legal justification for this impulse. It’s ok to leave routes open if they’re not hurting anything.

You can compare the maps of the alternatives below.

Continue reading...

 

[willis_racing]

'84 Bronco II Pinzguy

 

['84 Bronco II]

Alternative A (No action) is the only plan that doesn't suck. Just a bunch of arbitrary closures and use restrictions with the other plans. I don't care about the provisions for bathrooms, parking areas, and signage in the other alternatives as I don't see a need as far as my usage is concerned.

Typical BLM/USFS maps with inconsistencies and routes that don't actually exist mapped but real existing routes left off an therefore closed by default

Here's a link to the full resolution PDFs of proposed plans and the the digital interactive map (which doesn't match the PDFs ): EplanningUi

 

['84 Bronco II]

Some notable issues/closures Rock Crawling wise:

Alternative A

• Not supposed to be any closures, but the legend indicates almost all of the routes are closed I assume this is just a mistake.
• Cat Scratch not included
• Granite Canyon not included
• Corona Canyon not included
• Hell's Gate not included
• Jim's Jinx not included
• The exit for Arch is not included, but the upper part of the canyon Arch is in is included which I did not realize anyone had run before
• Bucket Canyon is included which I don't believe has been run yet

Alternative B

• Most of Arroyo de Los Pinos, Hidden Valley, and the Causeway are closed, leaving no access for Stooges which is still open Also makes Arch, Bad Hair Day, and Say What?! in and out trails that you have to run backwards then turn around and run the normal direction.
• The entrance and exit of Pucker Falls are single track only and the only way to get to Pucker Falls on the map from the South Boundary road doesn't actually exist. Even if it did, it would be an in and out trail that you would have to run backwards first. Oh, but they left the Great Escape open even through it dead ends into the closed causeway
• Upper Amado Canyon is singletrack only making Atajo a Chupadera in and out.
• Upper Arroyo de Los Pinos is closed which makes Doug's Dilemma and Secret Canyon in and out trails that you have to run backwards first.
• Edge Canyon closed
• Bucket Canyon closed
• Arroyo Del Coyote is UTV only
• All the trails in Alt. A are missing here too

Alternative C

• The end of Hidden Valley is closed making it and Say What?! an in and out trail and you have to run Say What?! backwards first.
• The entrance and exit of Pucker Falls are single track only and the only way to get to Pucker Falls on the map from the South Boundary road doesn't actually exist. Even if it did, it would be an in and out trail that you would have to run backwards first.
• Upper Amado Canyon is singletrack only making Atajo a Chupadera in and out.
• Arroyo Del Coyote is UTV only
• All the trails in Alt. A are missing here too

Alternative D

• The end of Hidden Valley is closed making it and Say What?! an in and out trail and you have to run Say What?! backwards first.
• The entrance and exit of Pucker Falls are single track only and the only way to get to Pucker Falls on the map from the South Boundary road doesn't actually exist. Even if it did, it would be an in and out trail that you would have to run backwards first.
• Upper Amado Canyon is singletrack only making Atajo a Chupadera in and out.
• Arroyo Del Coyote is UTV only
• All the trails in Alt. A are missing here too

 

['84 Bronco II]

Sceep do you know what the provenance of the original map was? I was under the impression it came from the old NMTORC working with the BLM. If that is the case, it is curious they made the following statement considering established routes that were left off the published maps were shown on this map over a decade ago:

Additionally, during Interdisciplinary Team review, some linear features were identified that are not, nor were ever, affirmed as a travel route by the BLM. BLM staff considered these linear features and determined that they were linear disturbances (see Glossary for definition); therefore, they are not included in any of the route network alternatives.

Oh, and their definition of "Linear Feature" and "Linear Disturbance"

Linear disturbance: A human-made linear travel or transportation related disturbance that is not part of the BLM’s transportation system or travel network. Transportation linear disturbances may include engineered (planned) but no longer needed features, as well as unplanned routes that have been identified for decommissioning and reclamation either passively or actively. Linear disturbances may also include permitted realty features (e.g., pipelines or power lines) that may or may not have travel routes maintained in association with them.

Linear feature: A linear ground disturbance that results from travel across or immediately over the surface of BLM-administered public lands. These features include engineered roads and trails, as well as user-defined, non-engineered routes, created as a result of public or unauthorized use. Linear features may also include permitted realty features (e.g., pipelines or power lines) that may or may not have travel routes maintained in association with them.

 

[willis_racing]

My notes from a dirt bike perspective are that Alt B shuts down the most traveled single track loop in the area, and all of them shut down one of the more challenging trails.

They also have a trail near coyote canyon listed as a keeper that is literally a random cow trail

As much as separation of use for certain trails would help alleviate some of my personal grievances with use of the area, turning that authority over to the BLM is NOT worth it.

I'll share some links to comment on the active Moto based facebook page as well. If the crawlers and dirt bikers can team up on this one I bet we could do some good.

 

['84 Bronco II]

I'll try to get my comments written up in the next day or two so I can share them on the NMOffroad and Rock Buggy Facebook groups as well as maybe put a post up in Chit Chat here to hopefully get a few more comments in.

 

[Sceep]

I beleive that map was put together by Werkmeister and NM4W back in the day.

Thanks for posting up.

I'll get comments submitted.

 

[Sceep]

WTF is wrong with the Alt A map? is it just me? EVERYTHING is closed per the legend. They cannot have a comment period with inaccurate resources like this. Include in your comments that they MUST extend the comment period to allow time to properly evaluate the maps.

 

[Sceep]

They also have a trail near coyote canyon listed as a keeper that is literally a random cow trail

Are you talking about the JH0053 that branches off of coyote hills? Thats actually a hell of a fun ST and needs to be kept on there.

 

[Sceep]

on the plus side... it looks like they have opened a lot of the MTB singletrack up to moto use in alt b.

Thats gonna piss off the guys that have been building and maintaining it a bunch though.

 

[willis_racing]

Are you talking about the JH0053 that branches off of coyote hills? Thats actually a hell of a fun ST and needs to be kept on there.

No, I actually ran that one like 2 weeks ago. That's a good'un. Though some tard in a buggy definitely followed the single track on the ridge line recently and screwed up a bunch of vegetation when he realized he couldn't go any further and had to turn around

That's my personal pet peeve in socorro. The amount of single tracks that get destroyed by side by sides and offroaders who "just want to see where it goes" sucks sometimes.


The one I was referencing is listed as JH0057.
Edit: you can find it right next to the ending of 0053

 

[willis_racing]

on the plus side... it looks like they have opened a lot of the MTB singletrack up to moto use in alt b.

Thats gonna piss off the guys that have been building and maintaining it a bunch though.

That is some funny shit actually.

Shut down the half of the single track that people actually ride, then open up the one trail that was actually signed and posted as non-motorized to motorized use.

 

[Sceep]

That's my personal pet peeve in socorro. The amount of single tracks that get destroyed by side by sides and offroaders who "just want to see where it goes" sucks sometimes.


The one I was referencing is listed as JH0057.
Edit: you can find it right next to the ending of 0053

yeah i was wondering what that JH0057 was. I'm not familiar with it.

while i get your frustration with the "see where it goes" attitude, I also have to read this thread and think "i haven't ever heard of half of these trails hes talking about". Those have been built in the last 10 years with exactly that attitude... Just saying.

 

[willis_racing]

yeah i was wondering what that JH0057 was. I'm not familiar with it.

while i get your frustration with the "see where it goes" attitude, I also have to read this thread and think "i haven't ever heard of half of these trails hes talking about". Those have been built in the last 10 years with exactly that attitude... Just saying.

Yeah I'm definitely not going to act like dirt bikers are patron saints of offroading
I hate hearing stories of how idiot kids on bikes treat staff at KoH.

Loop I'm referencing is JH0068. JH0067,JH0066, JH0065, JH0064, and JH0001-0005. Those were cut in I think by Jeff Porter and Paul Scroggie about 20 or 25 years ago. They don't have anything to offer to a trials rider unlike the stuff on the north side of the canyon. It's purely a flowy high speed desert single track.

And not like I'm against cutting of new trails in general either, I just really get my panties in a wad over ST getting blown out. I'm willing to admit that it's a selfish attitude though

 

[Sceep]

Loop I'm referencing is JH0068. JH0067,JH0066, JH0065, JH0064, and JH0001-0005. Those were cut in I think by Jeff Porter and Paul Scroggie about 20 or 25 years ago. They don't have anything to offer to a trials rider unlike the stuff on the north side of the canyon. It's purely a flowy high speed desert single track.

Hey I have a ST bike too, It's just collecting dust currently.

Thats a great loop. Having spent my time in the planning process in the past I'm guessing the reason they are slated to be cut is too close to residences. they are trying to push the noise and complaints away from homes. Not necessarily a bad thing in the long run as less complaints = less less reason to close more down. But, yeah, I dont wanna lose anything that is established either.

 

['84 Bronco II]

I beleive that map was put together by Werkmeister and NM4W back in the day.

Thanks for posting up.

I'll get comments submitted.

Thanks! If you are still in contact with anyone who was involved with the creation of the original map, I would really like to know whether that map was created in collaboration with the BLM or not.

yeah i was wondering what that JH0057 was. I'm not familiar with it.

while i get your frustration with the "see where it goes" attitude, I also have to read this thread and think "i haven't ever heard of half of these trails hes talking about". Those have been built in the last 10 years with exactly that attitude... Just saying.

All of the trails I named off are on the OG map with the exception of Stooges (JH0134), which ironically is open in all four Alternative maps

And not like I'm against cutting of new trails in general either, I just really get my panties in a wad over ST getting blown out. I'm willing to admit that it's a selfish attitude though

I am perfectly fine with them designating ACTUAL single tracks for single track use only, but the BLM wants to turn a bunch of established 2 track roads into single track which is just dumb and fragments access to the 4x4 trails that would still be left.

Specifically, the section of JH0012 between JH0007 and the start of JH0018 is the entrance to Pucker Falls, JH0026 is the exit of Pucker Falls and the entirety of Upper Amado Canyon. I am sure a few of those trails marked as single tracks in the northern part of the map are actually two tracks, but I am not familiar enough with that part of the area to say for certain.

EDIT: I got JH0033 and JH0034 confused. JH0033 is definitely a single track

 

[willis_racing]

I am perfectly fine with them designating ACTUAL single tracks for single track use only, but the BLM wants to turn a bunch of established 2 track roads into single track which is just dumb and fragments access to the 4x4 trails that would still be left.

Specifically, the section of JH0012 between JH0007 and the start of JH0018 is the entrance to Pucker Falls, JH0026 is the exit of Pucker Falls and the entirety of Upper Amado Canyon, JH0033 is the dropdown into Lower Arroyo De Los Pinos where everyone parks with their trailers. I am sure a few of those trails marked as single tracks in the northern part of the map are actually two tracks, but I am not familiar enough with that part of the area to say for certain.

We're 100% in agreement on that. I just didn't mention upper amado and pucker in my comments since you covered it.

Pucker>Causeway>upper amado was the very first "Hardcore" rock crawling run I ever experienced in my life. Turning all of that into singletracks is completely arbitrary and beyond absurd.

If they need help differentiating established singletracks from 4x4 trails and cow paths all they need to do is ask

 

['84 Bronco II]

If they need help differentiating established singletracks from 4x4 trails and cow paths all they need to do is ask

I really wish I could have been there when they were evaluating some of the routes I want to fully understand their thought process when they looked at some of these roads/trails and said, "Yup, this is definitely a single track despite the obvious tracks from 4x4s that you can see from Google Earth."

 

[Sceep]

Thanks! If you are still in contact with anyone who was involved with the creation of the original map, I would really like to know whether that map was created in collaboration with the BLM or not.

I am almost 100% certain there was no collaboration with BLM when that was created.
You can contact Mark through NMOHVA.

 

['84 Bronco II]

I am almost 100% certain there was no collaboration with BLM when that was created.
You can contact Mark through NMOHVA.

Thanks for the lead, sounds like it might be a dead end then.

 

[willis_racing]

Thanks for the lead, sounds like it might be a dead end then.

I think I've seen Ricky Rivera say that he did some working with the BLM for mapping when he was president of NMTORC.
His username on PBB was Risky Ricky but I don't think he's on Irate. Could try reaching out to him perhaps? not sure if you're familiar with him.

Edit: I saw him say that on a blm comment. He's already involved to some extent.

 

[Sceep]

Jake Scarborogh would have been involved waay back. Ricky took NMTORC over from Jake when Jake graduated. I can send you his number if you'd like. I might have rickys too. They are both on my FB if you want to stalk them that way.

 

['84 Bronco II]

I know of Ricky and follow him on Instagram, I'll give him a shout and see what he says.

 

['84 Bronco II]

I got in touch with Ricky. He says that Mark Werkmeister was working with the BLM when he created the original map I posted above. Ricky also said he worked with the BLM to re-map those trails while he was president of NMTORC. So it looks like the BLM's claim that the trails they left off the map were never affirmed as a travel route by them is bullshit

 

['84 Bronco II]

I heard back from Mark this morning, here is what he had to say about BLM involvement with the creation of the original map:

Yes, it is still my email address. And I did, indeed, create the map of the area that you included. The New Mexico Off Highway Vehicle Alliance (NMOHVA) was approached by Mr. Mike Bilbo who was with the Socorro BLM office at the time. I was on the Board of Directors of NMOHVA at the time. This would have been early to mid-2004. The situation is pretty well explained in the proposal I put to the local four wheel drive club of which I was a long-time member. I have attached a copy of that proposal. I and other members of the 4WD club (the New Mexico 4-Wheelers) eventually walked each and every arroyo, canyon, etc at Gordy’s Hill and identified all of the potential motorized recreation opportunities we found. After that, we started driving some of them (remember, the whole area was officially designated as “open” at the time). Trail development continued throughout 2005 and many of the challenge 4WD routes were first driven by I and NM4W and other small groups of friends.

<image002.png>

This photo was taken of my Jeep on the initial trip through Edge Canyon on Memorial Day weekend of 2005 – in 105 degree heat, no less.



The BLM’s assertion that "[Trails] were identified that are not, nor were ever, affirmed as a travel route by the BLM," is true but is obviously an disingenuous position. Since Gordy’s Hill was designated an “open” area that allowed cross country travel, there weren’t ANY such trails. The only exception to that would have been the routes that were being used by the desert racing series (motorcyles and ATV’s) that was operating at that time. That was the whole point. Collecting input for the eventual designation of such trails was the BLM’s (or at least Mike’s) purpose at the time. We are now almost twenty years later and the BLM is still “working” on that process. Unfortunately, as time has gone on, the personnel in the Socorro office have changed over many times and most were not nearly as open-minded or interested in providing opportunities for motorized recreation as Mr. Bilbo was. And yes, they didn’t like some of the “linear features” the new trails created as they dropped into or climbed out of some of the arroyos and canyons.



Please feel free to contact me with any other questions you have about the area and its history. I can also be reached at 505-321-3155.



Mark




PS. Mike Bilbo has long since retired from the BLM although I still see him from time to time. I most recently ran into him unexpectedly last November at Fort Stanton. Mike is truly a great guy!

 

[Sceep]

Mike was freaking awesome.

Sounds like Mark has you covered.

 

['84 Bronco II]

Here's the comment I submitted. Feel free to use it to help write your own comment, but DO NOT COPY AND PASTE, paraphrase anything you would like to use in your own words I had to attach my comment as a PDF because it exceeded the character limit of the comment box on the ePlanning website

EDIT: Apparently the character limit on Irate too

I am a frequent user of the Johnson Hill Special Recreation Management Area (SRMA) and visit with friends and family. I have guided out-of-state users and introduced several other people to the SRMA, many of whom have patronized lodgings and businesses in the community. We exclusively visit the area in modified 4x4 vehicles and enjoy the diversity and challenge of the terrain throughout the area as well as the quintessential southern New Mexico scenery. This is one of my favorite areas to visit and has a well-deserved reputation as one of the best rock-crawling locations in the state.

In the time I have been visiting the area, I have never witnessed a single conflict between user groups. In my experience, the southern and eastern portions of the SRMA are more heavily used by modified 4x4s while the northern and western portions are more heavily utilized by powersports users (motorcycle, ATV, and UTV); however, I have come across all motorized user groups throughout the SRMA. Non-motorized users seem to be a small minority and I have not seen many that stray far from the Quebradas Back Country Byway. Based on my personal experience, I do not see a legitimate need for use restrictions on two-track routes in the SRMA to avoid user conflict.

In section 1.3 (Purpose and Need) of the Johnson Hill Environmental Assessment (EA), it is stated that, “The purpose of this plan is to establish a framework that addresses current travel management and related recreation issues and improves existing recreation and OHV opportunities within the Project Area.” However, proposed Alternatives B, C, and D would drastically worsen OHV opportunities in the Project Area through seemingly arbitrary closures and use restrictions. It appears as though these proposed Alternatives were created by people who are not familiar with the established and named trails in the area and with little to no input from OHV user groups. Many of these proposed closures and use restrictions render popular, established 4x4 trails unusable due to inaccessibility and exclusion of the primary user group from the routes. Many of the route reports incorrectly classify routes as single track or “ATV Track” despite them being two track suitable for 4x4s. Examples include JH006; the portion of JH0012 between JH0007 and JH0018, which is the entrance used by 4x4s for JH0018 which is known as “Pucker Falls”; The entirety of JH0026 which is a 4x4 trail known as “Upper Amado Canyon”; the middle portion of JH0039 which is a rock crawling trail known as “Jim’s Jinx”; JH0060; JH0061 known as “Arroyo Del Coyote”; JH0070; JH085; JH0086; the majority of JH0091; JH0104; and JH0114.

Furthermore, there are rather egregious issues with the maps provided by the BLM that warrant an extension of the comment period until the BLM can rectify the issues and provide the public with accurate maps. For instance, the routes shown on the interactive online map do not match the routes shown on the PDF maps provided on the ePlanning website, and according to the legend of the Alternative A PDF, nearly all routes would be closed to motorized use despite Alternative A being the baseline/no change option. Additionally, all maps show routes that have never existed while simultaneously omitting many well-established routes that have been in use for many years.

In section 2.1.1 (Travel Management Plan Alternatives) of the Johnson Hill EA, the following statements are made: “Additionally, during Interdisciplinary Team review, some linear features were identified that are not, nor were ever, affirmed as a travel route by the BLM. BLM staff considered these linear features and determined that they were linear disturbances (see Glossary for definition); therefore, they are not included in any of the route network alternatives.” What criteria was used to classify these routes as “Linear Disturbances?” While the statement about the BLM’s affirmation of these paths as travel routes is technically true, it is rather disingenuous considering that the Johnson Hill SRMA used to have an “open” designation that permitted cross-country travel and the BLM was working in cooperation with private individuals and organizations to establish these trails that were excluded from the current maps in the EA. In fact, Mark Werkmeister, former member of the board of directors at the New Mexico Off-Highway Vehicle Alliance (NMOHVA), was approached by Mike Bilbo from the Socorro BLM office in 2004 to identify potential motorized routes in the SRMA for the purpose of designating trails within the area. Mr. Werkmeister worked with Mr. Bilbo and the New Mexico 4 Wheelers (NM4W) to map and establish these trails throughout 2004 and 2005. In fact, the NM4W club was awarded the BLM “Making a Difference” National Volunteer Award at a ceremony in Washington D.C. in May of 2005 per another Resource Management Plan written in 2008:

“The NM4W club alone logged over 2500 hours in the field during pre-development efforts at Gordy’s Hill for the Socorro office. Mike Bilbo, Recreation Planner, was so impressed with the motorized community’s efforts that he submitted an application for the BLM “Making a Difference” National Volunteer Award. The deciding committee was impressed also, and the award was granted to the NM4W and other participating motorized organizations for their work at Gordy’s Hill at a ceremony in Washington DC in May, 2005.”

Richard Rivera who served as the president of the New Mexico Tech Off Road Club (NMTORC) later worked with the BLM to re-map these same trails, so the BLM was previously aware of these routes and had given, at a minimum, implicit approval of the routes. Significant rock-crawling trails omitted from the maps in the EA include: the Arch Canyon exit, Catscratch, Corona Canyon, the Edge Canyon exit, Gates of Hell, and Granite Canyon. There were also other trails that were originally mapped by Mr. Werkmeister, but to my knowledge those have not been established.

 

['84 Bronco II]

Alternative A, the no action/baseline option, provides the most favorable outcome for OHV users (assuming that the red colorization of the routes on the map is a mistake). The closures and use restrictions in Alternatives B, C, and D far outweigh any perceived benefits from the proposed facility and infrastructure improvements as well as the improvements to the permit process which really only benefits event organizers and not the individual users. The only issue with the Alternative A plan as it stands is the omission of the routes mentioned in the preceding paragraph.

Alternative B, the resource protection option, is the least favorable option presented. In addition to the omitted trails, this option closes many of the most popular trails and access roads such as J0027 (The Causeway), J0030 (Lower Arroyo De Los Pinos), J0031 (Hidden Valley), JH0039 (Jim’s Jinx), JH0047 (Upper Arroyo De Los Pinos), JH0048 (Edge Canyon), and JH0125 (Bucket Canyon). In addition, the use restrictions on the section of JH0012 between JH0007 and JH0018 and JH0026 (Upper Amado Canyon) make JH0018 (Pucker Falls) inaccessible to anything other than motorcycles due to the inaccurate terminus of JH0018 that does not actually join JH0017. The closures make JH0134 (Stooges) inaccessible to OHVs of any type despite the route being designated “open.” Furthermore, the combination of closures and use restrictions make JH0024 (Bad Hair Day), JH0029 (The Great Escape), JH0129 (Doug’s Dilemma), JH0130 (Secret Canyon), JH0131 (Arch Canyon) JH0132 (Say What?!), and JH0133 (Atajo a Chupadera) all out and back trails. This doubles the impact of each vehicle on these trails and provides a much worse user experience. For instance, someone who wanted to run JH0020 (Squeeze Canyon), which has been restricted to 4x4 use, would have to drive back out JH0017, Bosquecito road, and the Quebradas Back Country Byway to reach any other trails. This Alternative also designates many routes UTV arbitrarily that can be driven by all vehicle types as well as what is currently singletrack, therefore making it two track (JH0097 for example).

Alternative C, the blended option, and Alternative D, the development option, have no meaningful difference in route designations and availability. Both Alternatives present essentially the same recreation opportunities despite the BLM’s claim that Alternative D supposedly, “emphasizes an expanded range of recreational and travel route use opportunities.” Both Alternatives close the last third of JH0031 (Hidden Valley), which is one of the most popular modified 4x4 trails in the area, and will inhibit access to other trails. This closure makes JH0031 (Hidden Valley) an out-and-back trail as well as JH0132 (Say What?!) which will double the impact of each vehicle using those trails. The access issues for JH0018 (Pucker Falls) are the same as previously mentioned for Alternative B, making the route unusable for 4x4s which is its designated use in Alternatives B, C, and D. As in Alternative B, many routes are incorrectly designated as single track, specifically the portion of JH0012 between JH0007 and JH0018, and JH0026 (Upper Amado Canyon) which is another very popular modified 4x4 trail. Similarly, as mentioned in my comments on Alternative B, there are routes designated for UTV use that are presently single track such as JH0097, or are suitable for use by all motorized vehicles (including 4x4s) such as JH0061 (Arroyo Del Coyote).

The management actions detailed in the EA are preferable in Alternative D compared to Alternative C, but development of the area does not add any value to the user experience. However, I can see where a parking area, camping facilities, and bathrooms would be attractive to powersports users (motorcycles, ATVs, and UTVs) since the sand near Competition Hill, where they typically stage from, is quite soft for tow vehicles and campers.

In summary, Alternatives B, C, and D all drastically reduce recreational opportunities for 4x4 users and would provide little to no benefit for these users compared to the current management and state of the SRMA represented in Alternative A. I believe all the issues identified in the EA can be addressed without significant closures or use restrictions of existing routes. In addition, restricting routes by user group does nothing to improve the experience of the various user groups and, in fact, would have a detrimental impact on user experiences. There seems to be no need whatsoever to restrict any route for UTV, or 4x4 use only. However, I would recommend and support the protection of existing single-track routes with use restrictions, but many 4x4 routes are presently incorrectly identified as single track in the route evaluations. An underlying issue with all the proposed Alternatives (including A) is that the BLM has erroneously classified many established routes as “linear disturbances” and excluded them from the route inventory despite documented support and collaboration from the BLM on the development and mapping of these routes. These routes should be properly mapped and added to the route inventory before proceeding with official designation of routes.

Alternatives B, C, and D are unacceptable and should be reconsidered by the BLM; Alternative D in particular since it is supposed to be the OHV-friendly alternative that should expand and improve recreational opportunities for OHV users. OHV users across the western United States are losing legal recreational opportunities at an alarming rate, especially for challenging technical rock-crawling opportunities like those prevalent in the Johnson Hill SRMA. It would be a great economic and recreational loss for the community if the BLM proceeds with Alternatives B, C, or even D. I have submitted supporting documentation with this comment.

 

['84 Bronco II]

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