Monday, December 7, 2009

Crazy Uncle Found in CCMA DEIS

On December 4, (commonly called a data dump when done on a Friday, since few in the media or users will have time to read and initially respond in a timely manner), the BLM published/posted the Draft Resource Management Plan and EIS for CCMA.

As riders know, the CCMA land closure saga is very complex. In a normal OHV-related NEPA process (TMR, new staging areas, trail construction, etc.), the land agency has a Purpose and Need and Goals and Objectives. Usually, those tenets are related to managing OHV recreation as it relates to wildlife, soil, flora, etc.

What makes CCMA different is the “asbestos” health issue. That “crazy uncle” in the basement is now sitting at the front of the dinner table telling his family what food (e.g. trails and access) they can eat.

In a normal OHV NEPA DEIS process, OHVers would submit a proposal to either support one of the action alternatives including the preferred alternative (if they are OHV friendly) - since supporting the no-action alternative as your only option is IHMO usually a waste of time, support a modified action alternative – that could include the preferred alternative or an action alternative the “mixes and matches” various items from the different alternatives, or to propose a new alternative that mixes and matches items from the menu – however, this may require a supplemental DEIS if it is too different from alternatives in the DEIS.

What is problematic with the CCMA DEIS is their working thesis continues to be that “all asbestos is bad asbestos.” BRC and others believe that assumption is false or at least uncertain - even BLM’s own staff had questions on the validity of the EPA study as day-lighted in BRC’s FOIA Request)

BRC FOIA Information also link to Turcke Letter

In The General’s personal opinion, that false assumption has created an arbitrary decision matrix that functionally excludes any alternative that includes historic levels of OHV use in CCMA in what appears to be a political decision or calculation on BLM’s part to keep OHV use out of CCMA.

Riders cannot forget the fact that at several of the public scoping meetings in 2008, BLM representatives told Steve Kortoff (Friends of CCMA leader) an others that they were closing CCMA to OHVs because they were afraid of “lawsuits” (most likely suits related to enforcement of the Clean Air Act or other air quality legislation/rules).

Just as BRC stated in June 2008, it is, and will continue to be, their goal to bring sound science into the decision-making process and to have CCMA reopened for responsible OHV recreation.

The General believes OHV groups collectively are in agreement that they are going to work together to get CCMA reopened for motorized recreation and permitted OHV events. The analysis of the DEIS will take some time (probably mid-January at the earliest) and I believe riders on blogs and the internet would serve themselves and sport well to let BRC and other groups review the document in a professional manner. Between now and the expected BLM public meetings in January, folks should enjoy the Christmas Season. There will be plenty of time to fight the battle in 2010.

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  1. I will dig up the maps I have of the routes they used to take the air samples. I think they did not use enough of the trails from a statistical analysis standpoint, and they picked trails that they knew had high concentrations of asbestos to slant the test results.

  2. Todd,

    You are right. The EPA admitted at the 1st public meeting they did not know that Jade Mill and other old mill sites (that are now campgrounds) contained commercial asbestos when they did the tests.

  3. And now Carnegie?
    What can the troops do?

  4. Butch,

    This is a long process. First, I would encourage riders to enjoy Christmas with their loved ones. Second, read the DEIS and be prepared to attend public meetings in Jan/Feb.
    Third, be prepared to submit comments once you and OHV groups, including BRC legal, have fully reviewed the document to see what alts etc. they feel OHVers can or should support and have those comments filed by the March 5 deadline.