Help Oppose Motorized Closures in the Organ Mountain Desert Peaks National Monument!

['84 Bronco II]

I'm cross posting this from the Land use Forum to try and get it some more visibility, see the original thread here: BRC - Organ Mountains-Desert Peaks National Monument in New Mexico Proposes New Management Plan

We need as many people as we can to submit comments opposed to closing additional portions of the monument to motorized recreation. Please submit your comments through the BRC website or both the BRC and BLM Website. The BLM has a track record of ignoring substantive comments opposed to prevailing management direction and delaying FOIA requests from the BRC making it harder for the BRC to submit legal challenges.

In southern New Mexico, near Las Cruces lies the Organ Mountains-Desert Peaks National Monument containing 496,330 acres. The Bureau of Land Management is updating the resource management plan that will direct the future of all uses throughout the entirety of the monument. The BLM has given Alternative A as the current management and 3 alternatives, B, C and D. Alternative D is the recreation alternative that actually expands areas that will allow OHV use by 1% depending on the area. Although we would like to see even more open as there are already restrictive management designations and laws protecting this area. It is refreshing to see the BLM look at expanding uses in some capacity once in awhile. Submit a comment to the BLM by July 5, 2024. If you have specific information or requests on this area please include them at the beginning of the letter that will be sent to elected officials as well as the BLM planning team.

Full Briefing:​

Alternative B: This is the most restrictive of the proposals. It will close areas to OHV use. It will designate three new ACEC’s, close areas to recreational shooting and portions of an allotment will be unavailable to grazing. It will undesignate an ACEC and an RNA but only because they are within Congressionally designated Wilderness already. Over 4,000 acres of the Broad Canyon ACEC would be designated. Over 9,000 acres would be designated as the East Potrillo Mountains ACEC and over 900 acres as the Picacho Peak ACEC. ACEC’s are area’s of critical environmental concern and historically restrict access for all users.

Alternative C: The “compromise” alternative and the BLM’s preferred alternative for this plan. It will close some areas to grazing and OHV travel. The same areas in Alternative B closed to recreational shooting will be closed under C as well except a smaller portion of the Dona Ana mountains. The ACEC and RNA will be undesignated just as in B.

Alternative D: All areas not closed to OHV use will be limited to designated roads. All ACEC’s will be undesignated. Dona Ana Mountains ACEC would be released as an ACEC also the Organ/Franklin Mountains ACEC which is currently over 54,000 acres. Under Alt. B this ACEC would be expanded and under Alt. C this ACEC would be reduced to 36,000 acres. Releasing these ACEC’s should be a priority.

Currently under Alternative A, 49% of the monument is closed to motorized use. Alternative D proposed to have 48% of the monument closed.

Camping at Sierra Vista and Baylor Canyon will be limited to a two day limit. Alternative B is proposing to close camping in these areas altogether.

Recreational target shooting will be restricted to specific areas.

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Continue reading...

 

['84 Bronco II]

Some Context for the current stage in the process:

Some tips from the BLM on writing comments that have value:

 

['84 Bronco II]

I read through the proposed Organ Mountains Desert Peaks National Monument (OMDPNM) Resource Management Plan (RMP), and here are the key take aways and points to address in comments as far as motorized use is concerned:

1. Alternatives B and C would close all forms of motorized recreation in most of the Doña Anas, all of Box Canyon and surrounding trails, Kilbourne hole, and Alternative B would additionally close all roads off Baylor Canyon Road in the foothills of the Organ Mountains.
2. All roads created after May 2014 (The date of the Executive Order establishing the monument) in the remaining areas open to motorized use are subject to immediate closure - Unclear how the BLM plans to determine this, likely through aerial and satellite imagery. The RMP and Analysis of the Management Situation both make allusions a proliferation of user made OHV routes in recent years implying that many of the trails have been made since May 2014, yet the vast majority of roads and trails on OMDPNM have existed long prior to the monument designation.
3. All roads within areas open to motorized use created between December 1993 (The implementation of the previous Mimbres RMP for the area) and May 2014 are subject to review and closure. It sounds like they want to close most routes that aren't access to a biking or hiking trail. It is particularly unclear how they are going to establish when roads were created for this period since high resolution satellite imagery wasn't readily available for most of this span of time. There likely hasn't ever been an exhaustive inventory of all the roads and trails in the area on the BLM's end.
4. The 2019 Dingell Act established 10 Wilderness areas within the monument despite the existence of historical roads, some of these roads are over 100 years old, as well as trails that were permitted for the Chile Challenge when it was still held in Las Cruces until 2013. Wilderness areas are supposedly areas of intact and roadless land which these are not.
5. The BLM claims only 1% of monument visitors engage in OHV use based on a sample size of 165 responses. Where/how did they survey visitors? OHV Use is arguably the Primary use in the Robledos/Sierra De Las Uvas, Doña Anas, and Potrillo Mountain portions of the monument where there are no visitor centers or developed amenities and no officially designated hiking trails. The Ruby and Modoc Mine roads were the only real motorized trails still existing in the actual Organ Mountain portion of the monument until they were closed by the Organ Mountain Wilderness. These trails were not accessed from the developed Dripping Springs and Aguirre Springs areas.
6. The BLM lists rock crawling is an "emerging" activity, despite a documented history of rock crawling/recreational four wheeling and off road racing in the area for over 60 years. The nationally-recognized Chile Challenge event put on by the Las Cruces Four Wheel Drive Club began in 1990 and featured trails throughout the monument area. Some of the earliest rock crawling competitions such as the 1998 BFG Rock Crawling Championship were also held within the monument area. Recreational four wheeling and rock crawling are arguably traditional/cultural uses of the area that predate both the Mimbres RMP of 1993 and the designation of the Organ Mountain Desert Peaks National Monument in 2014.
7. The BLM's "Use Value" based on the Oregon State University College of Forestry database associated with OHV recreation is wildly inaccurate. The "Use Value" is an attempt to correlate the economic impact of a given form/type of recreation in relation to alternatives. The value is meant to reflect the average amount of money an individual is willing to pay to engage in that particular recreational activity through fuel, equipment, etc. The OMDPNM Analysis of the Management Situation assigns a Use Value of $52.74 for OHV use, yet assigns a Use Value of $73.98 for Hiking, and $197.88 for mountain biking. The methodology for arriving at these figures isn't entirely clear, but when accounting for vehicle purchase price, fuel, modifications, maintenance, tow vehicles/trailers, camp/lodging fees, etc., it is hard to believe that any non-motorized form of recreation could have an economic value comparable to OHV recreation.
8. Both the Draft RMP and Analysis of the Management Situation for the OMDPNM attempt to justify closures of motorized areas by pointing out the nearby Aden Hills and Red Sands OHV areas. Both of the OHV areas are flat, featureless patches of desert that represent extremely low value recreation opportunities for OHV users in comparison to the high value opportunities that currently exist within the OMDPNM. Areas of the OMDPNM, which have never officially been designated as OHV areas, have always had much higher usage by OHVs than the designated OHV areas.

 

['84 Bronco II]

Some pictures of the areas under threat of complete closure to motorized vehicles:

Box Canyon

 

['84 Bronco II]

Spring Canyon (takes off from Box Canyon)

Kilbourne Hole

 

['84 Bronco II]

The Doña Anas

 

['84 Bronco II]

Some cool old pictures of the Jeep races in the Doña Anas during the '60s

 

['84 Bronco II]

My comment:

I am a native-born Las Crucen, and fifth generation southern New Mexican. I spent my youth exploring the lands within the Organ Mountain Desert Peaks National Monument (OMDPN) with my family and friends and it continues to be an integral part of my life to this day. For me, these lands aren’t just a place to visit, but a way of life. Access to these public lands is the greatest benefit to living in Las Cruces for me and my family.

My primary use has been motorized travel with stock and modified four wheel drive vehicles, but I have also engaged in extensive hiking, as well as target shooting and camping. Places I have visited within the monument include but are not limited to: the entirety of Broad Canyon, Box Canyon, Apache Canyon, Branson Canyon, Spring Canyon, the Robledo Slot Canyon, all of the “Chile Canyons” in the Robledo range, the Aden lava flow, Kilbourne Hole, Hunt’s Hole, the Aden Lava flow, Dripping Springs, Hermit’s Cave, the Modoc and Ruby mines, Soledad Canyon, the entire Doña Ana range, and the summits of Picacho Peak, Robledo Mountain, Lookout Peak, and the Organ Needle.

As a motorized user, I have seen the recreation opportunities around Las Cruces disappear at an alarming rate. Within the OMDPNM, the 2019 Dingell act has closed many roads that have been in use for decades including world class rock crawling trails such as “Off Broadway” (32°30’01.4”N 107°06’11.4”W) and “Upper Broad Canyon” (32°30’55.8”N 107°02’38.4”W) in the Sierra De Las Uvas/Robledo subunit. The Bureau of Land Management (BLM) had previously permitted these trails for use during the annual Chile Challenge event that once took place in the area surrounding Las Cruces. Other notable motorized trails closed by the wilderness areas established by the Dingell act include the Ruby (32°21’56.5”N 106°36’51.9”W) and Modoc (32°20’42.7”N 106°36’42.2”W) mine roads in the Organ Mountains subunit which have existed and been in use for over 100 years and provided spectacular views over the Mesilla Valley and access to historic sites. I urge the BLM to reconsider any action that further diminishes or marginalizes motorized recreation opportunities within the OMDPNM.

The draft Resource Management Plan and Environmental Impact Statement (RMP/EIS) grossly underestimates the value and prevalence of motorized recreation within the OMDPNM. Throughout the RMP/EIS, the BLM makes references to preserving traditional uses of the land within the OMDPNM, but clearly does not consider motorized recreation a traditional use and goes so far as to refer to “rock crawling” as an emerging activity. Recreational four wheeling and rock crawling are arguably traditional and cultural uses of the area that predate both the Mimbres RMP of 1993 and the designation of the Organ Mountain Desert Peaks National Monument in 2014. There is a documented history of over 70 years of rock crawling/recreational four wheeling and off-road racing in the area within the OMDPNM. The Las Cruces Jeep Club (a predecessor of the Las Cruces Four Wheel Drive Club) built many of the roads and motorized trails within the OMDPNM during the 1950s and 1960s. There were also organized Jeep races in the Doña Ana mountains during this time. The nationally-recognized Chile Challenge event put on by the Las Cruces Four Wheel Drive Club began in 1990 and featured trails in the Sierra De Las Uvas/Robledos and Doña Ana subunits of the monument until it was relocated to Sierra county in 2014. Some of the earliest professional rock crawling competitions such as the 1998 B.F. Goodrich Rock Crawling Championship were also held within the monument area.

The methodology of the recreational outcomes surveys performed by the BLM were flawed and biased the results in such a way as to under-represent the prevalence of motorized recreation. Efforts for visitor surveys were focused on the Aguirre Springs and Dripping Springs recreation areas and several hiking trail heads in the Organ Mountains subunit. Unsurprisingly, the results of these surveys indicated hiking to be the most prevalent activity since there are no opportunities for motorized recreation at the survey locations, and indicate a higher level of tourism from outside the local area than is actually representative for the monument as a whole. The BLM did not survey at the trailheads for the Modoc and Ruby mine trail heads where the only motorized recreation within the Organ Mountains subunit could legally occur (still legal motorized routes as of 2017 at the time of the survey). Furthermore, the BLM only surveyed at a popular mountain biking trail head in the Doña Ana subunit, and as one would expect, the survey indicated that mountain biking is the predominant activity in the Doña Ana subunit. There are many different access points to the Doña Ana subunit, and the most popular access points for motorized use are to the west of the Doña Ana subunit off of Del Rey Blvd and were not captured in the survey. Additionally, the BLM only surveyed the Potrillo subunit for a single day which does not provide for any meaningful sample size, but anecdotally, I have only ever personally observed motorized recreation and target shooting occuring in the area around Kilbourne and Hunt’s holes. The BLM only surveyed the Sierra De Las Uvas/Robledo subunit a total of 8 days, 4 of which were weekdays. This is a very small sample size as well, and under represents motorized recreation in one of the primary subunits where it takes place since most motorized recreation primarily occurs on weekends.This subunit is remote like the Potrillo subunit and requires a greater time investment from users, therefore, most people who work full time are unable to visit these subunits during the traditional work week. It is unclear whether the Picacho Recreation area, a hiking trail head primarily for Picacho Peak, and Corralitos Road were used for all survey dates, but obviously the Picacho Recreation site would not capture motorized users. The primary ingress and egress points for the Sierra De Las Uvas/Robledo subunit for motorized recreation are the airport east boundary road (shown on Google Maps as “Box Canyon Dr.”), through the Paleozoic Trackways National Monument (PTNM), Faulkner Canyon Road, an unmarked road ¾ of a mile northwest of Faulkner Canyon Road of NM185 prior to Foster Canyon, and lastly, Corralitos Road. Further marginalizing the prevalence of motorized recreation, the BLM divides “Driving and sightseeing” and “OHV riding,” which are both forms of motorized recreation, as separate activities. Not to mention, nearly all other activities quantified by the BLM rely on some degree of motorized use to participate within the OMDPNM.

Within the RMP/EIS, there were several statements made pertaining to the economic benefit of the OMDPNM to the Las Cruces area; however, motorized recreation is drastically undervalued. The BLM's "Use Value," based on the Oregon State University College of Forestry database, associated with OHV recreation is wildly inaccurate. The OMDPNM Analysis of the Management Situation assigns a Use Value of $52.74 for OHV use, yet assigns a Use Value of $73.98 for Hiking, and $197.88 for mountain biking. The methodology for arriving at these figures isn't entirely clear, but when accounting for vehicle purchase price, fuel, modifications, maintenance, tow vehicles/trailers, camp/lodging fees, repairs etc., it is hard to believe that any non-motorized form of recreation could have an economic value comparable to OHV recreation. There are entire economies built around motorized recreation, and communities such as Farmington NM, Moab UT, Hurricane UT, Silverton CO, and others have prospered catering to motorized users. A study conducted by Arizona State University from 2016-2017 estimated the economic impact of motorized off highway recreation to be 2.64 billion dollars for the state of Arizona. A 2021-2022 study by the Bureau of Economic Analysis, Outdoor Recreation Satellite Account and Regional Economic Account, estimated that the entire economic impact of all outdoor recreation to be 5.71 billion dollars for the state of Arizona. This data suggests that nearly half of all economic impact associated with outdoor recreation comes solely from motorized and OHV recreation for the state of Arizona which represents outdoor recreation opportunities directly comparable to those in New Mexico (for which studies determining economic impact of motorized/OHV recreation have not been performed). According to a report issued in 2020 by the New Mexico Outdoor Recreation Division, the economy of New Mexico benefits by an estimated 2.3 billion dollars from outdoor recreation. If outdoor recreation spending in New Mexico follows the trends seen in Arizona, potentially a billion dollars or more of the 2.3 billion determined in the 2020 study could be from motorized/OHV use. While the Chile Challenge event was held in the Las Cruces area, it brought in hundreds of vehicles from across the country, thousands of participants and spectators, as well as the presence and sponsorship of many large, nationally-recognized businesses such as B.F. Goodrich, Advance Adapters, and others. This week-long event brought national media coverage of the area, and participants patronized local hotels, campgrounds, restaurants, fuel stations, and part stores and mechanic shops. The BLM Las Cruces District Office also earned its highest Special Recreation Permit revenue during the period the Chile Challenge took place in Doña Ana county. The attention the Chile Challenge and early rock crawling events brought to the area made lands within the OMDPNM a major travel destination throughout the year among motorized recreation users. Continued closures for motorized users have greatly diminished this economic impact in recent years, and additional closures within the OMDPNM will further diminish economic revenue from this sector.

 

['84 Bronco II]

The RMP/EIS states that all roads in the remaining areas open to motorized use created after the presidential proclamation establishing the OMDPNM in May of 2014 will be subject to closure, and all roads created after the 1993 Mimbres RMP in the areas open to motorized use will be subject to review and potential closure. The RMP/EIS also alludes to a proliferation of roads since the 2014 proclamation, but how does the BLM plan to identify all of the existing routes within the decision area and ascertain the dates they were established? I have not witnessed a proliferation of routes since 2014. From 2014 on, there is high-resolution satellite imagery and substantial aerial photography available, but what methods will the BLM rely on, especially for routes created between 1993 and 2014? Is the BLM working with local individuals and clubs to map known existing routes and determine when they were established? Some motorized routes that have existed prior to 2014 and are missing from the BLM’s existing route maps such as “Faulkner Falls/Faulkner Canyon Detour” (32°27’33.9”N 106°58’15.9”W) and “White Rabbit” (32°27’51.3”N 106°58’12.9”W). It is difficult to see enough detail in the map of the Doña Ana subunit to determine whether the existing routes are accurately mapped.

In the RMP/EIS, the nearby Aden Hills and Red Sands OHV areas are used as a justification for further closures within the OMDPNM to motorized use. Both of the OHV areas represent very low value recreational experiences for motorized and OHV users as opposed to much of the terrain in the OMDPNM; which, while never officially designated as OHV areas, represent high value recreational opportunities for motorized and OHV users. The Aden Hills and Red Sands OHV areas are both flat and featureless patches of desert that do not have the same quality of scenery and unique geological features that provide for technical driving opportunities and rock crawling. Aden Hills receives very little use, a reflection of its low recreational value, and Red Sands only receives as much use as it does due to its close proximity to El Paso, which has very limited opportunities for motorized recreation.

The closure of the Box Canyon and Picacho Peak area to motorized use within the Sierra De Las Uvas/Robledos subunit shown in alternatives B and C would be a massive loss for motorized users. Aside from being one of, if not the most, popular areas within the OMDPNM for motorized recreation, closure would significantly reduce access to the adjoining PTNM. It would additionally result in route connectivity issues due to the arbitrary closures of routes at the PTNM/OMDPNM boundary, and effectively make these routes out-and-back trails on the PTNM side. This would double the impact of each user on those routes, as well as negatively impact the overall user experience. I see no reason to close this area to motorized use since the Picacho Peak Recreation Area, where most non-motorized users recreate, is well removed from Box Canyon, Spring Canyon, and Civilian Conservation Corps dams where most motorized users recreate. It seems to me that any perceived “conflict” between user groups arises solely from a vocal minority that is completely intolerant of motorized use. This relatively small user group has no less than 10 distinct wilderness areas comprising nearly half of the OMDPNM lands to recreate on. It seems to be a more than fair compromise for them to tolerate motorized use limited to existing roads on the other half of the monument lands; particularly if motorized users really are the minority the BLM makes them out to be in their recreational outcomes surveys

Additionally, the closures to motorized use in the Doña Ana subunit would create route connectivity issues, and exclude motorized users from some of the most scenic areas within the Doña Ana mountains. Road D063 provides access to stunning camping locations on the north side of Doña Ana Peak within the OMDPNM and would be closed under alternatives A and C. D063 also provides a primary means of access between the southwest and northeast sides, as well as along the east side of the Doña Ana range. Closing the portion that traverses the OMDPNM would create major connectivity issues and leave portions of the Doña Ana subunit much less accessible to visitors. The proposed closures to motorized use in the Doña Ana subunit would also cut off access to the cliffs along the southeast side of Doña Ana Peak, which are a very scenic attraction within the subunit, and very difficult to access otherwise. After the Box Canyon/Picacho Peak area, the Doña Ana subunit is the next most popular area within the OMDPNM with motorized users. I have never witnessed any sort of user conflict in this area, and all of the roads are well established at this point, so what benefit is achieved by closing this area to motorized users is dubious at best. Again, this seems like a proposal to cater to the minority of users intolerant of motorized users, despite the fact that they already have nearly half of the monument designated as wilderness area, the most restrictive use designation closing access to nearly all other user groups.

The Potrillo Mountains subunit sees so little visitation than the recreation outcomes survey team chose not to spend more than a day surveying it, and the subunit has the highest concentration of wilderness areas between all the subunits, yet the BLM wants to further restrict motorized access around Kilbourne hole, the primary attraction within the subunit, under alternatives B and C. Why does the BLM see the need to restrict motorized access around Kilbourne hole? I have never encountered users around Kilbourne Hole that were not either primarily motorized users or target shooters. By the BLM’s own estimation, the Potrillo Mountains are the least visited subunit of the OMDPNM, so why further restrict access and make it more difficult for visitors to experience? It is also odd that all of the wilderness area within the Potrillo subunit is classified as a Visual Resource Management (VRM) class 1, yet most of the non-wilderness land and roads bordering these VRM class 1 wilderness areas are the lowest VRM class 3 and 4 designations. This raises questions about the legitimacy of the VRM class 1 designations within the entirety of the wilderness areas in the Potrillo Mountains subunit.

Alternative D within the RMP/EIS technically provides the most access to motorized users, but the additional 3,293 acres is mostly meaningless for motorized users. The additional land is of little to no value to motorized users, and is red herring used solely for the purpose of meeting the absolute minimum criteria of an Alternative D plan under the BLM’s RMP framework. The additional land open to limited motorized use covers only the Aguirre Springs and Dripping Springs recreational areas and essentially represents administrative use roads that do not result in expanded opportunities for motorized users as the intent for Alternative D states.

The loss of motorized access not only impacts OHV enthusiasts, but limits recreational opportunities for all user groups, including hikers. Restricting areas as wilderness and closed to motorized use curtails all uses and effectively closes areas to the majority of the public. Few people, even relatively young and fit, are going to hike several miles in harsh and unforgiving terrain to visit remote locations within the OMDPNM from the nearest location accessible by motorized means. Should the elderly or otherwise disabled members of the community be any less able to access these special areas within the OMDPNM? For these people, motorized access is the only way they will be able to see many of these places; not to mention, motorized access allows for people to see and experience much more of the monument in a single visit. The BLM should not let vocal elitists control who is able to experience our public lands or what uses are “acceptable.” Motorized access is imperative for most Americans, and OHV access allows for people to experience these lands with minimal development, thereby preserving the character of the land and inherently reducing the likelihood of over-visitation. Furthermore, OHV users have been losing land access across the nation and have continually been marginalized; despite all time high participation and economic impact. The BLM should actively engage with organizations such as the Las Cruces Four Wheel Drive club to manage land use issues and organize trail clean ups. Many of the land use issues could be resolved by improved public education as well as signage and information available to users. At the end of the day, closure is not management, public lands should be available for use by the most diverse groups of users, and the Las Cruces area has already suffered too many closures to motorized users.