Public Comment: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah


Recreational Access and Conservation - Conservation and Public Service Activities	Short Cuts
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The following letter was perpared from information provided by BlueRibon Coalition. Please provide your name and address and e-mail this letter to the BLM Outdoor Recreation Planner.

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Outdoor Recreation Planner Bureau of Land Management Salt Lake Field Office 2370 S. 2300 W. Salt Lake City, UT 84119 RE: Standards for Public Land Health and Guidelines for Recreation Management for BLM Lands in Utah. Outdoor Recreation Planner: Please accept these comments to your Recreation Management Standards and Guidelines. I have been reviewing the process of your Recreation Management Standards and Guidelines and believe they are overshadowed by the BLM National Recreation Strategy. As such, this duplication creates an unnecessary burden on the recreational users of public lands to abide by the "correct" set of rules. If, in fact these BLM Standards and Guides are more important for the state of Utah and they establish absolute standards by which all recreation management must abide; then, they are implementation OF the National Strategy in Utah - before the Strategy has been finalized. Most of the Standards and Guides (5 pages) are fairly reasonable. However, I have identified significant problem areas: In the Introduction: 1. "The resources of these lands include not only timber, minerals, soils, riparian areas, water, air, and vegetation, but also beauty, opportunity for quiet and solitude, historical and archaeological sites, wildlife habitats, threatened and endangered species habitats and wilderness." This general statement of introduction inappropriately commingles physical features (timber, soils, water), values (quiet and solitude), and legal requirements (t&e species, wilderness). The implication is that these diverse aspects of public land are the same, and should be given equal weight in management. The introduction should discuss these separately and explain the agency's legally mandated mission for each. For example, values like "quiet and solitude" should not be equated with physical resources. They are the subjective perceptions of a segment of the community and no standard exists to define their meaning. 2. "The following guidelines for recreational use of the public lands are intended to assist in meeting not only the Rangeland [ecological] Health Standards but also to minimize harm to public land values as listed above." They seem to be saying here that all of the public land attributes listed above are VALUES, when clearly they are not. It seems to be elevating, once again, the values they've listed to something concrete and absolute when they are actually subjective and associated with Wilderness. The mixing of "values" with"features" creates and unreasonable burden on the recreational user to understand the guidelines. Physical attributes (wildlife habitat) equated with legal obligations (t&e habitat and historical sites) and subjective values. They are not the same, they have different mandates, yet this Standard implies that they are equal and that they will be managed equally. The Standards and Guides must address them differently and manage them separately. Subjective values such as beauty, solitude, and quiet have nothing at all to do with the condition of upland soils. This should be deleted. Sincerely,