BLM UBBABY 1988 LAN AMENDMENTS TO THE CALIFORNIA DESERT CONSERVATION AREA PLAN OF 1980 Decision Record December 1989 California Desert District Bureau of Land Management U.S. Department of the Interior */;#^ United States Department of the Interior BUREAU OF LAND MANAGEMENT CALIFORNIA DESERT DISTRICT OFFICE 1695 SPRUCE STREET RIVERSIDE, CALIFORNIA 92507-2497 IN REPn RKFER lO: 1600 (CA-060.25) BL^A LIBRARY SC-324A. BLDG. 50 _ DENVER FEDERAL CENTER P. 0. BOX 25047 DENVER, CO 80225-0047 Ul Memorandum To: State Director (CA-910) From: District Manager, California Desert Subject: 1988 Amendment Decision Enclosed is the Record of Decision for the 1988 amendment review of the California Desert Plan indicating my approval of the amendments. The enclosed document is provided for your review and concurrence. Cj^ jL^uulJL XJ Enclosure I cpncur with the California Desert District Manager's amendment decision. ^//:A^^ State Director, California Date TAKE PRIDE IN, AMERKA ^O0-6$S08 CO ,5^3V:430 RECORD OF DECISION The 1988 amendment review of the California Desert Conservation Area Plan was conducted in accordance with Bureau of Land Management Planning Regulations (43 CFR 1610.5-5), with the procedures set forth in Chapter 7 of the CDCA Plan (1980), and with the Council on Environmental Quality regulations for implementing the National Environmental Policy Act (40 CFR 1500). Proposals for amendments were accepted during a 47-day period from January 28 to March 18, 1988. The thirty-three amendments proposed by the public and by the BLM staff were screened by BLM management and by the California Desert District Advisory Council according to the following criteria: 1. Is the proposed amendment based upon new data not considered when the plan was developed? 2. Does the information represent a change in legal or regulatory mandate? 3. Is the supporting detail sufficient and the problem clearly stated so that the request can be considered? 4. Does the information represent a formal change in State or local government or agency plans? A public scoping meeting was held on April 9, 1988 in El Centro, and nineteen proposals were accepted for consideration in the environmental assessment (EA). Of the remaining fourteen proposals, seven were rejected from consideration or will be handled by methods more appropriate than the amendment procedure, as described in Appendix B of the EA. Considerat ion of seven proposals was deferred until a later date. The public comment period on the EA extended from June 8 to August 21, 1989. Thirty-two written comments were received. Oral comments were accepted at the June 16, 1989 meeting of the Advisory Council in San Bernardino. The preferred alternative for Amendment Two has been changed from that recommended m the EA. This amendment, which proposed an ACEC for the area adjacent to Red Rock Canyon, was rejected on the grounds that designation of an ACERC would not add to the area's current management and protection. This includes management agreements in which the BLM, the California Department of Parks and Recreation, the Audubon Society, and the Gear Grinders 4- WD Club take part. Amendment 20, a change in range classification of the Pilot Knob grazing allotment, was brought back from deferred status into the 1988 amendment cycle. This amendment was introduced in the 1983 Plan Amendment cycle but was deferred due to insufficient resource and management information. It was to be reconsidered after the allotment management plan and environmental assessment were completed. The preferred alternatives for all other amendments are the same as those described in the environmental assessment. Each amendment is described below. All letters received from the public and responses to specific comments are given in the Comments and Response section of this Record of Decision. Finding of No Signiflcant Impact The environmental assessment identified no significant effects on the human or the natural environment. Therefore, an environmental impact statement is not required. CALIFORNIA DESERT CONSERVATION AREA ■^ \ •"V- ) . 1988 PLAN AMENDMENT INDEX MAP s Amendment Number -=! ^^ ;-A yVi r— y \) f \ \ k L M i 1 \ r zJ l>r< AMENDMENT ONE NEW ACEC AT RODMAN MOUNTAINS CULTURAL AREA Proposed Amendment Designate an ACEC for cultural resources at the Rodman Mountain Cultural Area. Other Alternatives Considered No Action Decision Accept Proposed Amendment. Rationale Rock art sites within this area have been listed on the National Register of Historic Places. These sites are significant because: they show a diversity of artistic styles and are associated with habitation sites, trails, and resource exploitation sites; they are conveniently located for public interpretation; and they are significant to the religious and spiritual concerns of Native Americans. ACEC status will provide the mechanism to give this unique area the special management it needs. Since the ACEC area lies within a recommended wilderness study area, further protection will be provided if Congress designates this area as wilderness. Implementation Needs None District Manager Date ' /_ ] PROPOSED ACEC I I RODMAN MOUNTAIN ' CULTURAL AREA AMENDMENT 1 New ACEC RODMAN MOUNTAINS ,i' %:y''* ^ jooo |/-~/-aX' ;3 ■^^ '-"ku V ( - i^ rr-r^: T8N AMENDMENT TWO NEW ACEC ADJACENT TO RED ROCK CANYON STATE PARK Proposed Amendment Designate an ACEC for wildlife and botanical resources adjacent to Red Rock Canyon State Park in the land co-managed by the BLM and the California State Department of Parks and Recreation. Other Alternatives Considered No Action Decision Reject Proposed Amendment Rationale The area is already adequately protected by a number of management processes. Adding a new designation would not improve on the area's current management and protection. Further, though the area is adjacent to a State Park, its resources, in total, do not merit ACEC designation. Current management includes the following: 1. A Memorandum of Understanding (MOU) between the BLM and the California Department of Parks and Recreation. The area of the proposed ACEC is managed by State Parks as part of Red Rock Canyon State Park, except that BLM manages mining and grazing. The Scenic Cliffs/Nightmare Gulch portion of the area is closed to vehicles from February 1 to July 1 to protect sensitive resources. From July 1 to January 31, vehicle use is allowed between the 16th day and the end of each month. Vehicle access is restricted to three designated routes. State Parks monitors and reports results to BLM. 2. A Cooperative Management Agreement (CMA) between State Parks, BLM and the Audubon Society. The Audubon Society monitors the Scenic Cliffs/Nightmare Gulch area and provides an annual report to State Parks and BLM, discussing the trend and conditions of sensitive resources. 3. A CMA between State Parks, BLM, and the Gear Grinders 4-WD Club. The Gear Grinders maintain the designated vehicle routes and keep them open for 4-WD use. Better coordination of these three management efforts is needed. We will hold at least one annual meeting of the four parties to discuss the results of monitoring, new issues, and individual concerns. Current management should be evaluated and any needed changes should be implemented. Implementation Needs Annual meeting of BLM, State Parks, Audubon, and Gear Grinders. District Manager Date AMENDMENT 2 PROPOSED ACEC BOUNDARY New ACEC Red Rock Canyon \ AMENDMENT THREE NEW ACEC AT DEDECKERA CANYON Proposed Amendment Designate an ACEC at Dedeckera Canyon and the adjoining area for botanical and other significant resources. Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale This canyon is an area of unusual values. Its dolomite cliffs provide habitat for unique plant assemblages, including Dedeckera eurekensis and many species endemic to the Death Valley region. Its archaeological sites have yet to receive adequate study, but there is evidence that they should be protected from degradation. Raptors are present and, possibly, bighorn sheep. A 4WD route runs through the canyon between Eureka and Saline Valleys. Camping in the canyon could be hazardous to both the natural resources and to the campers, as flash floods sometimes sweep down the canyon with great force. ACEC management could protect the botanical and archaeological resources and control human use of the canyon. Implementation Needs None. District Manager Date AMENDMENT 3 New ACEC DEDECKERA CANYON \ PROPOSED ACEC BOUNDARY 10 AMENDMENT FOUR EXPAND BOUNDARIES OF COYOTE MOUNTAINS ACEC (#62). Proposed Amendment Expand boundaries of Coyote Mountains ACEC (#62) Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale The original boundaries of this ACEC included only a few paleontological areas in the Coyote Mountains. New research by the San Diego Natural History Museum, under cooperative agreement with the Bureau, has better defined the wider distribution of paleontological resources. Implementation Needs None Ot.^0^ ^,^- District Manager 'J 12.' Date ^ 11 AMENDMENT 4 ORIGINAL BOUNDARY NEW ACEC BOUNDARY ACEC 62 COYOTE MOUNTAINS FOSSIL SITE X 12 AMENDMENT FIVE DELETE CAMP IRWIN BOUNDARY ACEC (#28) Proposed Amendment Delete Camp Irwin Boundary ACEC (#28). Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale Approximately 80% of the ACEC and 100% of the cultural resources are located within the Fort Irwin National Training Center, which is administered by the Department of the Army. The cultural resources on public lands under BLM administration do not warrant the special management provided by an ACEC designation. Implementation Needs None District Manager Date 13 AMENDMENT 5 Delete ACEC 28 CAMP IRWIN MILITARY BOUNDARY ACEC 28 \ > V:'? S5T>»-~-i- ■v ■■- \\ ^-^r "7: 9 " FOSf IRWrN MILITARY RE^RVATiDN RESERVATION BOUNDAftY lAPPROXlililATE> ' , j /^ ^_::=^_-,^t__ TUN SBM A^-^- ^-, - ' "«>/ .-V 1 36 31-:...:- vp>-;- Hv""' .^,11 UJ LU CN cc QC 14 AMENDMENT SIX DELETE KRAMER HILLS ACEC (#38) [ Proposed Amendment Delete Kramer Hills ACEC (#38). Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale A 100% pedestrian survey of the ACEC in 1984 and again in 1986 failed to locate any cultural resources within the ACEC. The resources present in this area do not warrant the speciaL management implied by an ACEC designation. Implementation Needs None .1 q.^L^ . fc^ ,^\ir^ District Manager Date 15 ACEC 38 AMENDMENT 6 Delete ACEC 38 KRAMER HILLS AMENDMENT SEVEN DELETE DALE LAKE ACEC (#57) Proposed Amendment Delete Dale Lake ACEC (#57) Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale A 100% pedestrian survey of the ACEC in January 1987 failed to locate signifi- cant cultural resources within the ACEC; previously recorded sites could not be relocated. The resources present in this area do not warrant the special management implied by an ACEC designation. Implementation Needs None Loi District Manager Date ' 17 AMENDMENT 7 18 AMENDMENT EIGHT CHANGE CLASS "M" TO CLASS "L" IN YUHA DESERT MANAGEMENT AREA Proposed Amendment Change the Multuple-Use Class (MUC) from "M" to "L" in the portion of the Yuha Desert Management Area between Highways 80 and 98 (excluding the Dunaway Staging Area). Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale Wildlife and cultural resource values in the Yuha Desert have deteriorated steadily since the late 1970s, in spite of many attempts to achieve management control. These included the formulation and implementation of the Yuha Desert Management Framework Plan (1975), the Yuha Basin ACEC Activity Plan (1981), the Yuha Desert Wildlife Habitat Management Plan (1983), and the Yuha Desert Management Plan (1985). A change to Class "L" would provide more protective management and would improve the Bureau's potential for halting the decline of resources in this sensitive area. Implementation Needs None District Manager Date 19 AMENDMENT 8 20 AMENDMENT NINE CHANGE CLASS "M" TO CLASS "L" IN EAST MESA AREA Proposed Amendment Change the MUC from "M" to "L" in the East Mesa Desert between Highway 78 and the Mexican border, and between the East Highline Canal and the Old Coachella Canal. (Exclude Long Term Visitor Areas and the Gordons's Well Camp Site). Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale Since adoption of the Desert Plan in 1980, the population of the flat-tailed horned lizard (FTHL) has declined significantly in some parts of its range in southeast California, southern Arizona, and portions of Baja California. This decline led to the lizard's being designated as a "sensitive species" by the BLM and a candidate for listing by the U.S. Fish and Wildlife Service's Office of Endangered Species and the California Department of Fish And Game. The East Mesa is one of four crucial habitat areas in California, and the East Mesa ACEC was designated for protection of the species in 1980. Studies have shown that the crucial habitat extends west and north of the original boundaries. Cultural resources along the Lake Cahuilla shoreline extend further to the east than originally indicated. These resources would also benefit from the added protection provided by changing the MUC to Class "L". Implementation Needs None District Manager Date 21 AMENDMENT 9 AMENDMENT BOUNDARY CHANGE CLASS M to L CLASS M TO L EAST MESA 22 AMENDMENT TEN CHANGE CLASS "M" AREAS TO CLASS "L" IN EAST MOJAVE NATIONAL SCENIC AREA Proposed Amendment Change all Class "M" areas within the East Mojave National Scenic Area to Class "L". Other Alternatives Considered B. Modify proposal to exclude the Mescal Range. C. No Action Decision Accept Alternative A-(proposed amendment). Rationale This action would meet the resource protection objectives of the East Mojave National Scenic Area Management Plan and would assure effective reclamation of impacts from mining and recreation use. The change would affect three areas (approximately 120,000 acres) which make up about 10% of the Scenic Area. Implementation Needs None District Manager Date 23 AMENDMENT 10 EMNSA Boundary CHANGE FROM M TO L Alternative A EAST MOJAVE NATIONAL SCENIC AREA Change Class M to Class L \ 24 AMENDMENT ELEVEN \ CHANGE MUC FROM "M" TO T AND VEHICLE ACCESS FROM "LIMITED" TO "OPEN" IN AREA ADJACENT TO DUMONT DUNES OPEN AREA Proposed Amendment Change the MUC from "M" to "I" in the area adjacent to the Dumont Dunes Open Area (Area 1); change motorized vehicle access from "limited" to "open" Other Alternatives Considered A. Add Area 2. B. Add Areas 2 and 3 to existing open area. Change Class "M" to Class "I" in Areas 2 and 3. C. Add Areas 2, 3, and 4 to open area. Change Class "M" to Class "I" in Areas 2, 3, and 4. D. No Action Decision Accept Alternative B. Rationale It was originally intended that the Dumont Dunes OHV open area would include subareas 1, 2, and 3. Maps for the CDCA Plan were drawn incorrectly. This oversight was discovered during the planning effort for the Dumont area. The amendment will correct this oversight. Addition of Subarea 2 will incorporate the historically used camping and staging area for the main dunes, while Subarea 3 will add the area used by families and novice riders. Implementation Needs 1. Install appropriate boundary markers, including: Stage 1: Boundary signs, boundary collector routes, and barriers/fencing along Highway 127 and at the north boundary of Salt Creek ACEC. Stage 2: If Stage 1 items are insufficient add additional barriers/fences at other parts of the boundary. 2. Provide information/education materials for users, including a brochure, signs, and an information kiosk. 3. Initiate the designation process for routes of travel in areas adjacent to the open area. District Manager Date i 25 AMENDMENT 11 \ CO CO "O Q c ^ ■o CO CO c c CO CO CD CN CVJ a C\J 1 ° CO CO CO CO CO c o 0 1 0 1 CD 1 ••= CC CO CO ^ o "3 w 0._ < ■o CO Ti O ■D Q CO »- X •♦- JD *- ■n +- ■o ^ o ulA (^ District Manager lO Date 35 AMENDMENT 16 Change Motorized Vehicle Access from Limited to Closed ACEC CHUCKWALLA VALLEY DUNE THICKET ACEC \ AMENDMENT SEVENTEEN CHANGE VEHICLE ACCESS FROM "LIMITED " TO CLOSED" IN THE PALEN DRY LAKE AREA Proposed Amendment Change motorized vehicle access in the Palen Dry Lake ACEC from "limited" to "closed." Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale The management plan for this ACEC recommended closure of the area for protection of cultural resources from motorized vehicle use. Implementation Needs None District Manager Date 37 AMENDMENT 17 PALEN DRY LAKE ACEC CHANGE MV ACCESS FROM LIMITED TO CLOSED \ AMENDMENT EIGHTEEN PROHIBIT GRAZING SOUTH OF INTERSTATE- 10 IN THE FORD DRY LAKE ALLOTMENT Proposed Amendment Prohibit livestock grazing south of Interstate-10 in the Ford Dry Lake Allotment. Other Alternatives Considered No Action Decision Accept Proposed Amendment Rationale Recent loss of the entire population of 50 mountain sheep in the Warner Mountains to pneumonia as a result of Pasturella hemolvtica infection in combination with known recent contact with domestic sheep indicates a fatal infection was introduced by domestic sheep to the mountain sheep. Domestic sheep have also been documented as a source of infection. The California Department of Fish and Game plans to augment the bighorn sheep population in the Chuckwalla Mountains but would probably not do so if the Ford Dry Lake Allotment, which is ephemeral range and grazed intermittently, remains open to domestic sheep grazing. Implementation Needs None District Manager Date 39 AMENDMENT 18 lU uj -* o >- J o < o o GC Z O N o c o Q) T- E ■^- 0 o +- CO < .E 12 0 N 0 ^ CO *- CO l: c _i ^Z > ■H- O ^ 5^ Q ■C X ■D 2§ O Q. CO U. 40 AMENDMENT NINETEEN NEW GRAZING ALLOTMENT NEAR DAGGETT Proposed Amendment Establish a new ephemeral grazing allotment near Daggett. Other Alternatives Considered B. Modify proposal so that Camp Rock Road is the eastern boundary of the allotment. C. No Action Decision Reject Amendment Rationale The proposed allotment is within the range of the Newberry Mountain bighorn sheep herd. Insufficient information is available on this herd and on the possible effect of domestic sheep. In addition, the allotment would be within the habitat of the desert tortoise, which was given an emergency listing as an endangered species by the U.S. Fish and Wildlife Service on August 4, 1989. An additional grazing allotment in tortoise habitat would be inappropriate while this listing is in effect. Rejection of the amendment would be consistent with the "1-40 Compromise" of the CDCA Plan, which designated that all range south of 1-40 be managed to increase the habitat of the desert bighorn. Accepting the amendment would, in the best case, provide for maintenance of bighorn habitat, and, in the worst case, could adversely affect the bighorn, themselves. Nothing in this rejection shall effect on-going trailing authorizations to the extent that sheep skirt the edge of this range. District Manager Date 41 / AMENDMENT 19 •^ \ Land Currently Under Lease Private Land Public Land NEW GRAZING ALLOTMENT DAGGET ALLOTMENT BOUNDARY •••••• Alternative A — — — — Alternative B \ AMENDMENT 20 PILOT KNOB GRAZING ALLOTMENT CLASS CHANGE Proposed Amendment Change range classification of the Pilot Knob grazing allotment from ephemeral to ephemeral/perennial. Alternatives Considered A- Allow year-round grazing (refer to environmental assessment). B. Allow use from March to October. C. No action. Decision Accept Alternative A with modification. Change range classification to perennial. Rationale As requested in the Record of Decision for the 1983 CDCA Plan Amendments, the Ridgecrest Resource Area completed the Pilot Knob Allotment Management Plan (AMP) and an environmental assessment (EA) of its proposed actions. The AMP and EA have been reviewed by the public. The Bureau has consulted with the U.S. Fish and Wildlife Service (USFWS) about the effect of implementation of the AMP on the desert tortoise, which was designated an endangered species under an emergency listing on August 4, 1989. When implemented, the AMP will institute specific actions to reduce conflicts between cattle grazing and tortoises. Fences and other facilities will be constructed so that cattle can be moved to areas outside of tortoise habitat during the periods when tortoises are active and feeding. Cattle will be allowed inside tortoise habitat only when tortoises are inactive and underground. These actions will improve and stablize perennial plant vigor by controlling livestock distribution throughout the allotment. Implemenation Needs Construct fences, pipelines, and a well. Since part of the allotment is within Wilderness Study Area 173 (recommended as non- suitable), preference will not be granted until after Congress decides on wilderness status. Until that time, AUMs will be allocated on a temporary non-renewable basis. 43 Supplemental Information This amendment was introduced in the 1983 Plan Amendment cycle. However, due to insufficient resource and management information at that time, the decision to accept the amendment was deferred until completion of the allotment management plan and environmental assessment. District Manaeer Date / 44 AMENDMENT 20 45 COMMENTS & RESPONSES WRITTEN COMMENTS AND RESPONSES The BLM received a total of 32 letters addressing the proposed amendments during the public comment period. All letters were reviewed. Those letters that had substantive comments (i.e., questions or issues that had a direct bearing on a proposed amendment) were given a response. Table 1 lists each comment letter in order of receipt and designates a reference number. Within the letter the substantive remarks are noted and the response is keyed to the appropriate comment. All comment letters have been reprinted verbatim and substantive comments addressed. Letters that did not address substantive issues but presented an opinion are acknowledged by their inclusion. TABLE I COMMENT LETTERS Letter Number Source of Letter 1 Beverly Childs Mcintosh, Riverside County Planning Dept. 2 H.G. Wilshire, Mountain View, CA 3 Peter Burk, Citizens for Mojave National Park, Inc. 4 Dale A Musegades, U.S Border Patrol 5a Pete Bontadelli, CA. Department Fish and Game 5b Dennis J. O'Bryant, CA Division of Mines and Geology 6 Mary Ann Henry, Ridgecrest 7 Richard Spotts, Defenders of Wildlife 8 Edward Karapetian, Dept. of Water & Power, City of L.A. 9 Fred Simon, Kern County Planning & Development, Bakersfield 10 Robert D. Johnstone, U.S. Air Force, Edwards Air Force Base 49 TABLE I (CONT.) 11 Donald W. Moore, Audubon Society, Yuma Chapter 12 Edwin L. Rothfuss, Death Valley National Monument 13 Brooks Harper, U.S. Fish & Wildlife Service, Laguna Niguel 14 Elizabeth Forgey, Boron, CA 15 John R. Swanson, Minneapolis, MN 16 Vincent Yoder, CA Native Plant Society, Bristlecone Chapter 17 Jay B. Wilson, California Woolgrowers Association 18 Donald W. Moore, Audubon Society, Kerncrest Chapter 19 William E. Rinne, U.S.D.I., Bureau of Reclamation 20 Emery Henrich, Mojave, CA 21 Kenneth B. Jones, CA Dept. Parks & Recreation, San Diego 22 Jeffery J. Tunnell, Gear Grinders Four Wheel Drive Club 23 Cary W. Meister, Audubon Society, Yuma Chapter 24 Elden Hughes, Whittier, CA 25 Mary L. Grimsley, Ridgecrest, CA 26 Jerry D. Grimsley, Ridgecrest, CA 27 Elden Hughes, Whittier, CA 28 Judith Anderson, Sierra Club - So. Cal. Reg'l. Conserv. Comm.22 29. Patrice Davison, CA Assn. 4- WD Clubs 30. Hi Desert Multiple Use Coalition, Ridgecrest 31. Wayne Rettig, Ridgecrest 32. Suzanne Shettler, CA Native Plant Soc, Carmel Valley, CA 50 I ^eAooi\ ■- i \r :■* _ i-/ m JUL 12 mz 38 RiWP CA. BCM:if897 July 6, 19B9 ={iVE^^iDc COURlV PLAnninc DEPA^umEnu Gerald E. Hillier, District Nanager California Desert District Burea'-i of Land Management 1695 Spruce Street Riverside, CA 92507 Dear Mr . Hi 1 1 i er : i--'^iiii\:\Tr']ti: 1 i .--i lA 4- ..-vdniinj_ ACTION BY: nerURN TO. Thank you for transmitting to us the Environmental Assessment for the 1993 Proposed Plan Amendments to the California Desert Conservation Area Plan of 1980. Staff has reviewed the three amendments that address areas in Riverside County. These proposed amendments, numbers 16, 17 and 13 will provide increased protection to i>jildlife habitat and cultural resources. Staff concurs with the Bureau of Land Management ( BLM ) amendment proposals for ACEC No. 57, Chuc(-:awa 1 1 a Dune Thicket, ACEC No. 55, Pal en Dry Lake and the Ford Dry Lake Allotment. Please continue to inform this Department of BLM actions affecting Riverside County. Very truly yours, RIVERSIDE COUNTY PLANNING DEPARTMENT Roger S. Streeter, Planning Director BCM:pa 4080 LEMON STREET, 9^" FLOOR RIVERSIDE, CALIFORNIA 92501 (714)787-6181 51 46-209 OASIS STREET, ROOM 304 INDIO, CALIFORNIA 92201 (619)342-8277 -4. California Desert District F=Vi:V- '^-. Ci Bureau of Land Management ATTN: Plan Amendments 1695 Spruce St. Riverside, CA 92507 Dear Sirs, .333 JUL 13 ^H 2^ 52 July 9, 198Q I favor Alternative A for Amendments 1-4, 8-10, and 13-18; Alternative B for Amendments 7 and 12; Alternative D for Amendment 11, and Alternative C for Amendment 19. If, as indicated for Amendment 11, "manageable boundaries" is the principal criterion for expanding Dumont Dunes ORV Open Area, it would seem to me that 2-1 complete closure of the area would go even farther toward accomplishing that end. Sincerely, H.G. Wilshire 1348 Isabelle Ave. Mtn. View, CA 94040 52 Response to H. G. Wilshire Response to 2-1 In 1973, the Interim Critical Management Program for Recreation Vehicle Use on the California Desert established the Dumont Dunes Open Area, based on historical recreational use. In 1980, the Desert Plan continued that designation. Because of the popularity and longtime use of this area, closure of the dunes without adequate environmental grounds would be unfair to many recreationists and could result in difficulties in enforcing the closure. 53 ( gg Ep, oo3 \ CITIZENS FOR MOJAVE NATIONAL PARK, INC. P.O. BOX 106 BARSTOW. CALIFORNIA 92312 ESTABLISHED 1976 California Desert District O Bureau of Land tlanagement ^3 ATTN: Plan Amendments 1695 Spruce Street Riverside, CA 92507 Dear Mr. Hillier; 21 June 1989 Thank you for sending us a copy of the the proposed 1988 plan amendments to the Desert Plan. Below are our comments on the Proposed 1988 Amendments to the CDCA EA. We support Alternative A of Plan Amendment *10. All Class fl areas in EMNSA should be redesignated Class L. It is contradictory that National Scenic Area lands should be anything less than Class L. All the areas, including the Mescal & Ivanpah mountains merit Class L status due to their wildlife, scenic, botanic and cultural values. We are opposed to Plan Amendment * 12. We support Alternative B~reject the amendment. We see no need for an airport on Ivanpah Dry Lake. Our public lands do not exist for Whiskey Pete's Casino's profits. If Whiskey Pete's wants to build an airport, let them build it on private land in Nevada. The proposed airport would be a nuisance, add noise pollution, and be a visual disaster to the wonders of East Mojave National Scenic Area. The proposed airport lies in and near crucial desert tortoise habitat and the proposed airport would decimate tortoise populations in the area. We support Alternative A of Plan Amendment *\A. By deleting a segment of Utility Corridor E within the southeast corner of EMNSA , visual and scenic resources will be preserved. The utility corridor will still exist but will be moved outside EMNSA. slightly to the east. By eliminating this segment of the utility corridor, the Signal Hill WSA can be better protected and managed. We support Alternative A of Plan Amendment 'IS. By deleting Contingent Utility Corridor W. a great amount of EMNSA's scenic quality will not be threatened. New transmission corridors are not appropriate in a National Scenic Area. Outside the EMNSA area, we are opposed to plan amendment *19. We support Alternative C to reject the amendment to establish a new ephemeral grazing allotment near Daggett. We want to see bighorn sheep protected from the diseases of domestic sheep and cattle. Thank you for your consideration of our responses. We believe that "Take Pride in America' means managing our public lands to protect natural and cultural resources. Sincerel Peter Burk erel^ /? , President 54 \ c^ [ ^m2\ ?^2^^5 U. S. BORDER PATROL Iiuniigraiion &.Saturali:,anon Service 1111 North imperial Avenue Post Office Box 60 El Centro, California 92244 C"lir. -L--^^ DISTRICT Office of I he Chief Patrol A gem June 20, 1989 Mr. Gerald Hillier, District Manager California Desert District Bureau of Land Management 1695 Spruce Street Riverside, California 92507 Dear Mr. Hillier: ELC 40/92-C K S^£S_l j .\il\' y ^:-^ 4-1 We received a copy of the Proposed 1988 Plan Amendments for the California Desert Conservation Area and noted a couple of proposals which trouble us. Proposal numbers 8 and 9 involve changing the multiple class use from "M" to "L". We have no objections to the change as it affects the general public. However, our responsibility for patrolling the International Boundary should warrant a specific exemption. Illegal alien and drug traffickers cannot be given free reign because of restrictions which could potentially limit our ability to carry out our congressional mandate. We would like to go on record as opposing the change in class from "M" to "L" unless we can be given assurances that it would not limit our operations. Thank you for the opportunity to provide comments on this issue. 1/ Sincerely, Dale A. Musegades ^ Chief Patrol Agent 55 Response to U. S. Border Patrol Response to 4-1 The proposed change in multiple-use classification from "M" to "L" is based on new information and is intended to enable BLM to better manage the wildlife and cultural resources present in the Yuha Desert and the East Mesa areas. Congress has mandated the protection of severely declining species such as the flat-tailed horned lizard which occurs in these areas. The change will not affect vehicle use on existing roads. In order to protect sensitive resources, the Bureau allows cross-country travel only where it is absolutely necessary; e.g., law enforcement and life-threatening situations. We plan to continue our program of mutual cooperation with the U.S. Border Patrol. 56 •tate rrf Qlaltf0mta (^^HH. GEORGE DEUKMEJIAN GOVERNOR GOVERNOR'S OFFICE OFFICE OF PLANNING AND RESEARCH 1400 TENTH STREET SACRAMENTO 95814 (9] 6) 323-7 4H0 DATE: July 13, 1989 TO; U. S. Bureau of Land Management California Desert District ATTN: Irene Rice 1695 Spruce Street Riverside, CA 92507 FROM; Office of Planning and Research State Clearinghouse RE; Environmental Assessment, Proposed Plan Amendments to the California Desert Conservation Area, Plan of 1980 (SCH 89061602) As the designated California Single Point of Contact, pursuant to Executive Order 1237?, the Office of Planning and Research transmits attached corrments as the State Process Recommendation. This recommendation is a consensus; no opposing comments have been received. Initiation of the "accommodate or explain" response by your agency is, therefore, in effect. Sincerelv . Robert P. Martrnez Director Attachment cc: Applicant 57 ^^eAOo^ Resources Building 1416 Ninth Street 95814 (916) 445-5656 TDD (916) 324-0804 California Conservation Corps Department of Boating and Waterways Department of Conservation Department of Fisfi and Game Department of Forestry Department of Parks and Recreation Department of Water Resources GEORGE DEUKMEJIAN GOVERNOR OF CALIFORNIA THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA Air Resources Board California Coastal Commission California Tahoe Conservancy California Waste Management Board Colorado River Board Energy Resources Conservation And Development Commission San Francisco Bay Conservation and Development Commission State Coastal Conservancy State Lands Division State Reclamation Board State Water Resources Control Board Regional Water Quality Control Boards U. S, Bureau of Land Management California Desert District ATTN: Irene Rice 1695 Spruce Street Riverside, CA 92507 Dear Ms, Rice: July 13, 1989 The State has reviewed the Environmental Assessment, Proposed Plan Amendments to the California Desert Conservation Area, Plan of 1980, submitted through the Office of Planning and Research. We coordinated review of this document with the California Highway Patrol, State Lands Commission, Lahontan and Colorado River Regional Water Quality Control Boards, Colorado River Board, and the Departmens of Conservation, Fish and Game, Parks and Recreation, and Transportation. The Departments of Fish and Game, and Conservation have provided the attached comments for your consideration. Thank you for providing an opportunity to review this document. Sincerely, for Lordon F. Snow, Ph.D Assistant Secretary for Resources Attachments cc: Office of Planning and Research 1400 Tenth Street Sacramento, CA 95814 (SCH 89061602) State of California Memorandum SseAoos The Resources Agency ^° '■ The Honorable Gordon K. Van Vleck Secretary for Resources 1416 Ninth Street Sacramento, CA 95814 Attention Gordon F. Snow, Ph.D. Projects Coordinator From Department of Fish and Game Date July 7, 1989 5a Subject: Proposed 1988 Plan Amendments to the California Desert Conservation Area, Bureau of Land Management (BLM), SCH 89061602 The Department of Fish and Game has reviewed the Draft Environmental Assessment (EA) for the proposed 1988 amendments to the California Desert Plan. The EA describes the environmental effects of accepting or rejecting each of the 19 proposed amendments accepted by the ELM for review. We have the following comments on the proposed amendments: Amendment 3, Designate an Area of Critical Environmental Concern (ACEC) at Dedeckera Canyon and the Adjoining Area for Botanical and Other Significant Resources. We support adoption of the proposed amendment. Amendment 5, Delete ACEC No. 28, Camp Irwin Boundary. We support adoption of the proposed amendment. Amendment 6, Delete ACEC No. 38, Kramer Hills. We support adoption of the proposed amendment. Amendment 8, Change the Multiple Use Class from "M" (Moderate) to "L" (Low) in the Portion of the Yuha Desert Management Area between Highways 80 and 98 (Excluding the Dunaway Staging Area). We support adoption of the proposed amendment. Amendment 9, Change the Multiple Use Class from "M" to "L" in the East Mesa Desert between Highway 78 and the Mexican Border, tEe East Highline and the Old Coachella Canals (Excluding Long-Term Visitor Areas and the Gordons's Well Camp Site). We support adoption of the proposed amendment. Amendment 10, Change all Class "M" Areas within the East Mojave National Scenic Area to Class "L". We support adoption of the proposed amendment. 59 "29 cA ooS The Honorable Gordon K. Van Vleck -2- July 1, 1989 5a- 1 Amendment 11, Change the Multiple Use Class from "M" to "I" (Intensive) in the Area Adjacent to the Dumont Dunes "Open Area"; Change Motorized Vehicle Access from "Limited" to "Open". We support adoption of the preferred alternative (adoption of Alternative B; add areas 2 and 3) provided that boundary fences are established between areas 2 and 3 and the Salt Creek Hills and Salt Creek ACEC. Off highway vehicle activity is currently impacting the west side of the Salt Creek Hills. Amendment 12, Change the Multi pie Use Class of an Area I on the North End of Ivanpah Dry Lake , Adj acent to Inte rstate 15 and the Nevada Border , from ' 'L" to "M" for Construction of an Air port. We support adoption of the preferred alternative to reject the proposed amendment. The placement of an airport in this area could negatively impact the Ivanpah Desert Tortoise Crucial Habitat Area through cumulative impacts to the tortoise caused by increased traffic and development within the region of the ai rport . Amendment 15, Delete Contingent Utility Corridor W. We support adoption of Alternative A. Amendment 16, Change Motorized Vehicle Access in the Chuckawalla Dune Thicket ACEC from "Limited" to "Closed". We support adoption of Alternative A. Motorized vehicle access into this area is an inappropriate use. Amendment 17, Change Motorized Vehicle Access in the Palen Dry Lake ACEC from "Limited" to "Closed". We support adoption of Alternative A. Motorized vehicle use in this area is an inappropriate use. Amendment 18, Prohibit Livestock Grazing South of Interstate 10 in the Ford Dry Lake Allotment"! We support adoption of Alternative A. The Department has previously recommended the elimination of livestock grazing in the area due to the potential of spreading disease to bighorn sheep from contact with domestic sheep. Potential negative impacts to the desert tortoise caused by the grazing use within its habitat is another major consideration in our support of this alternative. Amendment 19, Establish a New Ephemeral Grazing Allotment near Dagget. We support the selection of adopting Alternative C to reject this amendment . 60 "^SEA oos The Honorable Gordon K. Van Vleck -3- July 1, 1989 Thank you for the opportunity to review and comment on the EA. you have any questions, please contact Fred Worthley, Regional Manager of Region 5, at 330 Golden Shore, Suite 50, Long Beach, CA 90802 or by telephone at (213) 590-5113. If Pete Bontadelli Director 61 Response to California Department of Fish and Game Response to 5a- 1 The Dumont Dunes Management Plan will indicate a tiered set of management actions to deal with encroachments into areas surrounding the OHV area. Signing routes closed and monitoring is the first step. If signing is not effective, the next step will be fencing. The Salt Creek Hills ACEC Management Plan has been amended to include a fence on the northern boundary of the ACEC near the Little Dunes. Construction is scheduled for 1990. 62 Stat? of California Memorandum SS fcA COS- THE RESOURCES AGENCY OF CALIFORNIA To From Dr. Gordon F. Snow Assistant Secretary for Resources Ms. Irene Rice U. S. Bureau of Land Management 1695 Spruce Street Riverside, California 92507 Department of Conservation — Office of the Director Dote Subject: 5b July 10, 1989 Environmental Assessment for the Proposed 1988 Plan Amendments to the California Desert Plan, SCH# 89061602 5b-1 The Department of Conservation's Division of Mines and Geology (DMG) has reviewed the Environmental Assessment (EA) for the Proposed 1988 Plan Amendments to the California Desert Plan, and we offer the following comments for consideration. Amendment 3 The proposed Dedeckera Canyon Area of Critical Environmental Concern (ACEC) includes areas where the potential for economic industrial minerals has been recognized by DMG's Mineral Land Classification Program. DMG's work in this area (Taylor and Joseph, 1988) has determined that portions of the proposed ACEC are underlain by carbonate and siliceous rocks that elsewhere have comprised economic resources of limestone and silica. We recommend that consideration be given to the mineral potential of this area before adopting this ACEC. If you have any questions concerning these comments, please contact Zoe McCrea, Division of Mines and Geology Environmental Review Officer, at (916) 322-2562. Dennis J. O' Bryant Environmental Program Coordinator DJO:TM:efh cc: Zoe McCrea, Division of Mines and Geology Timothy McCrink, Division of Mines and Geology Reference; Taylor, G. C. , and Joseph, S. E. , 1988, Mineral Land Classifi- cation of the Eureka-Saline Valley Area, Inyo and Mono Counties, California: California Division of Mines and Geology Open-File Report 88-2. 63 Response to California Division of Mines and Geology Response to 5b- 1 Cliff wall and talus slopes within the upper portions of the canyon are composed of Paleozoic age carbonate and siliceous rocks (Department of Conservation, Division of Mines and Geology, 1988, Mineral Land Classification of the Eureka-Saline Valley Area, Inyo and Mono Counties, California, Open File Report 88-2, geologic map). These rocks, due to lack of interest in the area, distance to markets, and environmental restrictions in the area existing at this time, are recognized as having a low potential for development. This potential was considered in the review of the purpose of the ACEC. While the ACEC does not segregate the area from entry under the United States mineral laws, it is recognized that measures placed in operating plans, or modification of operating plans to protect natural and cultural resources in accordance with the prescriptions in the ACEC plan may limit access to these minerals. These tradeoffs are part of our consideration in the development and implementation of the ACEC plan. 64 I 'SB EA oa(c \ 389 JUL 25 ?■« 35 U CaH-^fTalaCA Desert District Bureau of Land Management ATT: Plan Amendments 1695 Spruce St. Riverside. California 9250? 329 Perdew Ridgecrest, CA 93555 July 23, 1989 6-1 I have studied the I988 Plan Amendments to the Calif. Desert Conservation Area Plan of 1980 and wish to make the following comments: Amendments #1 to #7: I support ALL of the changes in ACEC designa- tions. Amendments 8, 9, 10: I support changing Class M areas to ClassL in the Yuha Desert Management Area , the East Mesa Area and East Mojave Scenic Area, I oppose Amendment #11 to Class change at Dumont Dunes, ORVs do not need any more areas to rip-up and exclude non-vehicle oriented recreationists, ORVs drift into the Amargosa riparian area, and we do not need any more of that. I oppose Amendment #12 to have an airport on Ivanpah Dry Lake and to change the Class from L to M. Create an airport for a casino because they do not want to drive cars. Too bad I I support #16 and 17 changing Class L to Closed the Chuckwalla Dune Thicket ACEC vehicle access and Palen Dry Lake ACEC vehicle access, I support #18 to prohibit grazing south of Interstate 10 on the Ford Dry Lake Allotment. I am oiH>e-&»d to #19, to establish a new ephemeral allotment near Daggett. No more cattle or sheep allotments on the desert. Mary ^nn Henry T 65 Response to Mary Ann Henry Response to 6-1 The riparian habitat of the Amargosa River is within the Amargosa ACEC (#13) and begins approximately 4 miles north of the OHV area. Any problems will be resolved by signing, fencing, and ranger patrol. See also response to 2-1. 66 --." ''f*- T OF WILDEff^l'B >^H 3: I L_^l_..^_n:i..,-..;.:/ . J o I* ! \JA J i """1 "! U]\- _; i 1 __] ; t i July 22. 1989 "''TTT'^^ [iiSZjlM. Gerald E. Hillier, District Manager California Desert District mm U.S. Bureau of Land Management / ATTN: Plan Amendments 1695 Spruce Street ! r .'.■:?-', vj; Riverside, CA 92507 !.-....-.^-— Re: Response to Environmental Assessment for the Proposed 1988 Amendments to the California Desert Conservation Area Plan. Dear Mr. Hillier: Defenders of Wildlife submits this letter as our comments and recommendations on the above-referenced document. Please consider our input, and include this letter in the appropriate public record At the outset, we generally support and applaud BLM' s Preferred Alternatives for those proposed amendments relating to important wildlife habitats (with the exception of Amendment #11) . Specifically, we endorse and urge BLM to adopt the Preferred Alternatives for Amendments #2, 3, 8, 9, 10, 12, 13, 14, 15, 16, 17, 18, and 19. We concur with the described justifications for BLM's Preferred Alternatives on these Amendments. Indeed, we wish to commend BLM for these positive Preferred Alternatives. For example, we are especially pleased with BLM's Preferred Alternative to adopt Amendment #18. This Amendment would prohibit livestock grazing south of Interstate 10 in the Ford Dry Lake Allotment. Defenders had submitted a requested desert plan amendment identical to this Amendment #18. We are grateful that BLM has now -considered this Amendment, and is apparently inclined to implement it. We hope this Amendment will be adopted and implemented as soon as possible. On the other hand, we are disappointed that BLM's Preferred Alternative on Amendment #11 is to expand the "open area" avail- able for off -highway vehicle recreation in the Dumont Dunes. We disagree with BLM, and we instead recommend Alternative D to reject this Amendment. From an endangered species conservation perspective, we believe that BLM has prudently accepted as its Preferred Alternative the CALIFORNIA OFFICE: 5604 ROSEDALE WAY, SACRAMENTO, CALIFORNIA 95822 • (916) 442-6386 NATIONAL OFFICE: 1244 NINETEENTH STREET, NW • WASHINGTON, DC 20036 • (202) 659-9510 67 SS^A ooT OF WILDLIFE 2. adoption of Amendments #8 and #9. Implementation of these Amend- ments would improve protection for the flat- tailed homed lizard, Defenders of Wildlife is greatly concerned at the continuing decline of this species and its habitats. Consequently, we are pleased that BLM is willing to take steps to increase its conser- vation. We hope these Amendments #8 and #9 will be adopted soon, Thank you very much for considering our views. Sincerely, ^ ' ■ . ■ / Richard Spotts California Representative Defenders of Wildlife RS/js cc: Interested parties 68 (s^e^f^oog Depgintoeinit of Water and ■:^y.' ^9r, •^^': " ' , -:•> ' TOM BRADLBY Maj'or e City of Los Angeles Commission RICK J CARUSO, President JACK W LEENEY, Vue President ANGEL M ECHEVARRIA CAROL WHEELER WALTER A ZELMAN JUDITH K DAVISON. Secretary Mr. Gerald E. Hillier District Manager California Desert District Bureau of Land Management 1695 Spruce Street Riverside, California 92507 Dear Mr. Hillier: NORMAN E. NICHOLS. General Manager and Chief Engirieirr. r ELDON A COTTON, Assistant General Manager- Power \..'.\:: DUANE L GEORGESON, Assistant General Manager ■ Wafer ' . ;,; ' DANIEL W WATERS. Assistant General Manager ■ External Affair's™ ' NORMAN J POWERS. CW/fmanr/a/O/I/Jfff ! :'' • July 25, 1 ^;8|^_^;;r^j ;^ 8 r-:S''=:::- t Los Angeles Department of Water and Power (DWP) Comments on Proposed 1988 Plan Amendments to the California Desert Conservation Area Plan of 1980 - Environmental Assessment 8-1 We have reviewed the proposed Environmental Assessment and have the following comments concerning Amendment 12 and Amendment 15: Amendment 12 would change the Multiple-Use Class designation of an area on Ivanpah Dry Lake from Class "L" to Class "M" to allow for the construction of an airport. DWP is opposed to this amendment. The proposed airport lies in an area currently designated for utility corridors in the California Desert Conservation Area Plan (Desert Plan) . Corridor D and Corridor BB come together in this area forming a corridor up to five miles wide which .is, ^crucial to the electric energy supply of the Los Angeles Basin. Currently, DWP has four transmission lines (TLs) in Corridor D and a right-of-way for a TL in Corridor BB. We also believe that additional TLs will be needed in the future to meet increasing electrical energy demand in Southern California. The proposed airport and its safety zone will make it more difficult to site future TLs and will restrict the potential use of the existing interstate utility corridors. Because of its proximity to existing and future TLs, the airport would endanger lives, aircraft, and TLs. The proximity of the airport to DWP TLs will be detrimental to the reliability of the DWP electrical "^system as part of the western states' electrical network. 69 1 1 1 North Hope Street, Los Angeles, California D Mailing address: Box II I, Los Angeles 90051-0100 Telephone: (2\'ii)A%\-A2\\ Cable address: dewapola f/4A'. (213) 481-8701 g?z£"/A ooS Mr. Gerald E. Hillier - 2 - July 25, 1989 I DWP agrees with the Bureau of Land Management's (BLM) recommended preferred alternative to reject the adoption of Amendment 12 and further concurs with the cited rationale in support of this recommendation. 8-1 8-2 If Amendment 12 were to be adopted, DWP believes that the airport should be relocated at least 3/4 of a mile northwest of the current proposed location and the runway reoriented to parallel existing corridors and transmission lines. The relocation would help to minimize potential conflicts between I low- level flying aircraft and the transmission lines. Amendment 15 would delete contingent Corridor W from the Desert Plan. Contingent Corridor W, along with other utility planning corridors, was identified in the planning process for the Desert Plan by the Joint Utility Advisory Committee in the late 1970s "to establish a network of joint-use planning corridors capable of meeting projected utility needs to the year 2000." Further, this utility corridor element will serve as a guide for future decision making, beyond the year 2000, The elimination of contingent Corridor W will further limit possible energy transmission routes through the California Desert for utility companies. Corridor BE and Corridor D will continue to be important transmission routes for DWP as well as other utility companies for future transmission projects, but the elimination of contingent Corridor W may contribute to the congestion of these two utility corridors. We feel that the time is approaching for BLM to reexamine the existing corridor network within the California Desert. We would be available to work with the BLM in this effort. If you have any questions regarding our comments or would like to meet with our staff, please contact Mr. George P. Nino at (213) 481-4047. Sincerely, EDWARD KARAPETIAN Manager of Environmental and Governmental Affairs c: Mr. Richard Fagan, Manager Needles Resource Area 101 West Spikes Road Needles, California 92363 Mr. George P. Nino 70 Response to Los Angeles Department of Water and Power Response to 8-1 We are essentially in agreement concerning Amendment 12 and thank you for the additional information and suggestion for possible relocation of the airstrip. Due to other factors, we could not consider that alternative location. Response to 8-2 Your comments on Proposed Amendment 15 are well taken. When Contingent Corridor W was identified, it was to officially recognize that location as a potential corridor. With that designation, it would still have been necessary to amend the CDCA Plan in order to activate the corridor. Removing the designation will encourage utility companies to seek transmission routes outside the East Mojave Scenic Area. However, if it should become necessary to use this route in the future, an amendment to the CDCA Plan could be proposed. 71 I'gg^/? oo^ RANDALL L. ABBOTT ^- — • 2700 M Street DIRECTOR Suite 100 ^ . , „ . „, Bakersfield.CA 93301 David Pnce 111 Assistant Director (805) 861-2615 DEPARTMENT OF PLANNING AND DEVELOPMENT SERVICES July 21, 1989 9 ^.^ California Desert District j ; ^ Bureau of Lard Management , ' '"'" Attention Plan Amendments *'\^ 1695 Spruce Street ;•;::: Riverside, CA 92507 " o ;:: :::?. • ._ '^ J — - — i Re: Environmental Assessment, Proposed 1988 Amendments to the California Desert Conservation Area Plan 3- Ladies and Gentlemen: Thank you for the opportunity to comment upon the above-noted project. One of the proposed Areas of Critical Environmental Concern (ACEC) is located in Kern County: the Red Rock Canyon ACEC. We concur in the analysis presented and have no further comments at this time. Very truly yours, RANDALIx L. ABBOTT, Director Plapmng\and Development Services ~i'i sib 72 DEPARTMENT OF THE AIR FORCE HEACHl^fteS^ iflfctORCE FLIGHT TEST CENTER (AFSC) Qf,Qfi9)WA'R05 AIR fOUCi l&tSi, CALIFORNIA 93523 S83 JUL 2B ?M Z 56 ml Gerald E. Hi I I ler California Desert District Bureau of Land Management ATTN: Plan Amendments 1695 Spruce Street Riverside, CA 92507 Dear Mr . H i II i er : » 4 JUL itef ^?'^77m^ 10 h iiV 10-1 Thank you for the opportunity to review the Envir for the Proposed 1988 Plan Amendments to the Calif Area Plan of 1980. Two amendments, specif icall Critical Environmental Concern (ACEC) Adjacent t three (ACEC at Dedeckera Canyon) are located unde Both areas may experience military aircraft overfl above ground level. The Air Force Flight Test Ce Air Force Base assumes since no impacts to airspa the EA, that no overflight restrictions are be i n ACECs. If restrictions may be considered now or i ble adverse impacts to military airspace use must onmental Assessment (EA) ornia Desert Conservation y numbers two (Area of 0 Red Rock Canyon) and r special use airspace, ights as low as 200 feet nter (AFFTC) at Edwards ce use were addressed in g considered for these n the future, the poss i - be included in this EA. If you have any questions regarding the above comment, please contact Wendy Waiwood, of my staff, at (805) 277-3837. S I ncer e I y ROBERT D. JOlHNSTONE Chief, Plans and Policies Division 73 Response to U. S. Department of the Air Force Response to 10-1 The Bureau recognizes that mihtary aircraft training and testing activities in the California Desert are an important part of the national defense system of the United States. Overflights of military aircraft at low levels over the proposed ACECs are expected. ACEC designation will not affect this activity. 74 Kemcrest Chapt^ - ' U r ; < National Audubon Societv ■ \ .'LJT'f.G _ I i'O: DA' P.O. Box 984 m Jul 2" TM 2- 5o \M...J U- Ridgecrest, CA 93556 - VRJCT 11 11-1 .„. .1 flA'SMi July 25, 1989 California Desert District i .' " Bureau of Land Management f ■•1 ' 1695 Spruce St. i ' ,.::::; .".^v" ' Riverside CA 92507 U^'n;;^.. ^0:_ Attn: Plan Amendments Re: 1988 Plan Amendments Dear Mr. Hillier, We are opposed to Amendment #6 Kramer Hill ACEC being deleted. We believe that area to be proposed Category 1 tortoise habitat, crucial habitat. It also does not make sense to remove semi -protected desert habitat in view of the crisis tortoises are in. The area becomes a "lost resource". The Federal Emergency Listing yesterday should make you pause and reconsider. Under "Environmental Consequences" you do not list wildlife, perhaps because under "Affected Environment" you note that a pedestrian survey found "no other resources of special management concern", meaning no tortoises. We would like to be sure of that - that no tortoises were found in an area where they almost certainly are found in. We understand that there may be a heap leach mine planned for the area and deletion of the ACEC will aid that. We support your other proposed actions of "support" or "reject" except for Amendment #11 which we oppose. We are pleased to see Amendment #2, which we proposed, being supported. Thank you for the opportunity to comment. Sincerely, Donald W. Moore, President cc: Desert Tortoise Preserve Committee Sierra Club .-.1 75 Response to Kerncrest Chapter, National Audubon Society Response to 11-1 The Kramer Hills ACEC is located in an area which has been proposed as Category I desert tortoise habitat. The tortoise was given an emergency listing as an endangered species on August 4, 1989. It will be protected as required by the Endangered Species Act. Deletion of the ACEC designation will not affect management of the tortoise in this or any other area. A mine operator will be subject to the requirements of the Endangered Species Act for operations on public lands. A plan of operations has been filed for heap leaching within the area, but so far there has been no activity on public lands. ACEC status would not affect the process, if mining should occur. See also responses to 14-4 and 28-7. 76 United S|;pEt€5^ D^epkrtment of the Interior^ IN REPLY REFER TO: L7619 ^ NATIONAL PARK SERVICE JM^J^ ^#^LK^ Sa^&NAL monument "' DEATH VALLEY, CALIFORNIA 92328 July 25, 1989 Gerald E. Hillier, District Manager California Desert District Bureau of Land Management ATTN: Plan Amendments 1695 Spruce Street Riverside, California 92507 12 • "A- ;i;:'i5/:.^-.|f" m 12-1 12-2 Dear Gerry: The staff of Death Valley National Monument has reviewed the Proposed 1988 Plan Amendments to the CDCA Plan of 1980. Overall, the amendments appear to be environmentally beneficial. However, we are concerned over the proposal to enlarge the vehicle play area at the Dumont Dunes due to the potential for affecting the resources of Death Valley National Monument. The environmental assessment for Amendment 11, the expansion of the Dumont Dunes Open area through changes in the Multiple Use Class, appears to- be deficient in that the potential impacts to Death Valley National Monument are not identified. Expansion of the area open for vehicle play will, in our opinion, result in significant increased visitation and vehicle play in the area. This, in turn, will further tax the ability of local emergency medical services to respond to accidents. The enlarged vehicle play area will make effective law enforcement and visitor assistance patrols mere difficult because the perimeter will be much greater. There is a likelihood that expansion of the vehicle play area and increased visitor use will result in increases in the generation of dust. This, in turn, may impact the scenic quality of the region during certain weather conditions. We suggest that additional evaluation be done on the potential for impacts due to increased dust generation, especially to the scenic quality within Death Valley National Monument and the adjacent Wilderness Study Areas . jProtection of the Amargosa River is of utmost importance. As you Yknow, this river flows through the Dumont area and into Death 77 ^^^/lO(2 12-3 J^Valley National Monument. Within the Monument the Amargosa River supports a significant population of Amargosa River Pupfish (Cyprinodon nevadensis amargosae ) . We believe there is a strong probability that OHV use will spill over into Area 4 and degrade the Amargosa River within the Dumont Dunes area, and those impacts may extend into the Monument and adversely impact the habitat of the pupfish through degraded water quality. We assume that the only effective method of keeping OHV use out of this sensitive area is fencing. Are there any data on the occurrence of unlimited OHV use outside the boundary of the existing open area? 12-4 12-5 12-6 It is difficult to comprehend that impacts to archaeological resources over such a large area can be adequately mitigated. To do so would require a complete survey of the entire area proposed to be open to unlimited OHV use. The proximity of Salt Creek, the Amargosa River and Saratoga Spring causes us to believe there would is a high probability that significant _archaeological resources exist throughout the area. The environmental assessment does not address potential impacts' to the two species of dune beetles known to inhabit the area^ Has additional study of their distribution been made since th^ work of Andrews and Hardy in 197 6? Expansion of OHV use in the area seems questionable if these two beetles are endemic and are already experiencing impacts due to the existing OHV use. Perhaps additional work on the significance of these two species of beetles is in order before the environmental assessment can be completed. We believe some OHV use in the Dumont area "spills" over into Death Valley National Monument, especially in the Saratoga Spring and Ibex areas. We would like to work with the BLM staff in the Barstow Resource Area Office in controlling any such illegal use through a public education program using signs and patrolling rangers . Thank you for the opportunity to comment on the environmental assessment for the 1988 CDCA Plan Amendments. If you have any questions please contact us. Sincerely, ^ Edwin L. Rothufu: Superintendent 78 Response to National Park Service, Death Valley National Monument Response to 12-1 It is not anticipated that enlargement of the OHV area will adversely affect Death Valley National Monument. The draft Dumont Dunes Management Plan includes education of the OHV public concerning street legal use of vehicles within the Monument. The plan also calls for additional BLM and volunteer personnel to provide visitor services. Response to 12-2 The only dust generated in the area is along the access road. Dust abatement measures proposed in the Management Plan should prevent any increase in dust. Response to 12-3 See responses to 5a-l, 6-1, and 13-1. Response to 12-4 Areas 2 and 3 are mostly devoid of cultural sites. However, there is a small area which may contain cultural resources. It will be surveyed along with the Tonopah and Tidewater Railroad grade and its associated town sites (Sperry, Dumont, and Valjean). The survey will determine the area's eligibility for inclusion in the National Register of Historic Places. A mitigation package will be prepared for eligible sites, followed by consultation with the State Historic Preservation Officer, as required by Section 106 of the National Historic Preservation Act. Mitigation will be accomplished through data recovery. See also response to 5a- 1. Response to 12-5 The Bureau's legal mandate is to conserve listed threatened or endangered species. No such species exists in the Dumont Dunes area. References to unclassified species of beetles (Hardy and Andrews, 1976) are preliminary and incomplete. The lone report did not address other nearby dune areas (only six of 40 in California were visited) nor was sampling intensity stated. If these beetles do constitute endangered species, the California Department of Fish and Game and the U.S. Fish and Wildlife Service are the appropriate agencies to initiate a formal listing process. The BLM will cooperate with such actions by allowing research to be conducted. In the interim, other nearby dune systems are protected through either closure to OHVs (Kelso and Ibex) or OHV use on limited or existing trails (Devil's Playground and Cadiz). 79 Response to Death Valley National Monument (cont.) Response to 12-6 Use of existing routes outside the OHV area is legal. If a specific problem is identified, signing and fencing of the Monument boundary and patrols by BLM and National Park Service (NPS) rangers will be considered. A cooperative agreement between BLM and the NPS could be prepared for handling any problems which may arise. 80 United States Department of the Interior FISH AND WILDLIFE SERVICE LAGUNA NIGUEL FIELD OFFICE 24000 Avila Road Laguna Niguel , California 92656 iji Reply Refer To: FWS/LNFO (1-6-89-TA-944) 13 ] iM July 26, 1989 MEMORANDUM To: From: Subject : District Manager, California Desert District, Bureau of Land Management, Riverside, California Acting Field Supervisor Proposed 1988 Plan Amendments to the California Desert Conservation Area, California The Fish and Wildlife Service (Service) has reviewed the environmental assessment for the proposed 1988 Plan Amendments to the California Desert Conservation Area. The proposed amendments include the creation of three new Areas of Critical Environmental Concern (ACEC), deletion of three existing ACECs, one boundary adjustment to an ACEC, five multiple use class changes, deletion of portions of three utility corridors, three changes in motorized vehicle access, and two changes in the Livestock Grazing Element. Under the Bureau of Land Management's (Bureau) preferred alternative, 17 amendments would be accepted and two would be rejected. The Service offers the following comments on those amendments which we believe have potential the affect fish and wildlife resources : Amendment 2. New ACEC Adjacent to Red Rock Canyon. The Service concurs with the Bureau's assessment that this proposed amendment will provide additional protection to nesting and foraging raptors and to numerous Federal candidate species, such as the desert tortoise ( Xerobates agassizii ) , Mohave ground squirrel ( Spermophilus mohavensis ) , and Red Rock tarweed ( Hemizonia arida ) . Therefore, the Service supports the adoption of this amendment . Amendment 3. New ACEC at Dedeckera Canyon. ACEC designation in this area would lead to increased protection for desert bighorn sheep (Ovis canadensis nelsoni ) and the Federal candidate species, July gold ( Dedeckera eurekensis ) , as well as other plant 13-1 gg£5^0(3 District Manager 2 species endemic to the Death Valley region. The Service supports adoption of this amendment. Amendment 8. Change Class "M" to Class "L" m the Yuha Desert Management Area. This amendment has been proposed in response to deteriorating habitat values for the flat-tailed horned lizard ( Phrynosoma meal 1 ii ) , which is a category 1 candidate for listing under the Federal Endangered Species Act (Federal Register 54:559; January 6, 1989). The change to Class L would permit the Bureau to place greater environmental constraints on mining, off- road vehicle use, and other activities which could occur in this region and allow for management actions which would benefit the conservation of the flat-tailed horned lizard. For these reasons, the Service supports the adoption of Amendment 8. Amendment 9. Change Class "M" to Class "L" in the East Mesa Area. The Service supports adoption of this measure for the same reasons advanced for Amendment 8. Amendment 10. Change Class "M" Areas to Class "L" in East Mojave National Scenic Area. This proposed amendment would increase the Bureau's ability to manage wildlife on approximately 120,000 acres within the East Mojave National Scenic Area. Included among the resources found in this area are numerous species of raptors, desert tortoises, bighorn sheep, mule deer (Odocoileus hemionus ) , and four candidate species of plants. Alternative B would exclude the Mescal Range area from the land use classification change and result in fragmentation of wildlife habitat management actions. Therefore, the Service recommends that Alternative A, which would involve the land use change on the entire 120,000 acre area, be adopted by the Bureau. Amendment 11. Change Class "M" to Class "I" and Vehicle Access from "Limited" to "Open" in Areas Adjacent to Dumont Dune Open Area. Alternatives A, B, and C would add varying amounts of land to the Dumont Dunes Open Area in an effort to "acknowledge historic use patterns and . . . provide manageable boundaries for the open a^rea," as stated on page 4-12 of the environmental assessment. Alternative A would set a Wilderness Study Area as a boundary for off-road vehicle use, while Alternatives B and C would allow use of areas near and at the Salt Creek ACEC and the Amargosa River, respectively. The environmental assessment identifies several wildlife species of concern in the area of the proposed expansions. Two Bureau sensitive fish species, the Amargosa pupfish ( Cyprinodon nevadensis amargosae ) and the Amargosa speckled dace (Rhinichthys osculus nevadensis ) , are known to occur upstream from the Open Area, while the Dumont Dunes support two new, unclassified, and potentially endemic species of beetles, Eucilinus sp. and ^ Tr igonoscuta sp. Despite the fact that these wildlife 82 13-2 13-3 S'^ ie/^oi3 District Manager 3 resources occur within or near the proposed expansion areas, there is no discussion of the potential impacts of Alternatives A and B in the Environmental Consequences section of the assessment . Furthermore, the environmental assessment does not contain any information on means by which impacts to Wilderness Study Area 222 would be prevented. Although the Service is not mandated to evaluate the impacts of projects to wilderness areas per se, the management of these areas in a manner that excludes many activities that are detrimental to wildlife can provide numerous benefits to many species. Therefore, we are concerned about the resulting impacts should off-road activity be permitted to the borders of a Wilderness Study Area. The Service believes that potential adverse impacts to wildlife habitat within Wilderness Study Areas 219, 220, and 221 can also result from adoption of this amendment. Although these areas have been recommended as nonsuitable for wilderness, they are currently being managed under the Interim Management Policy and Guidelines for Lands under Wilderness Review to retain their wilderness values . The rationale given for expanding this particular Open Area may create or perpetuate a management strategy that results in a spiral ing downward trend of loss of habitat. Legalization of the unauthorized activity that has had an impact on wildlife resources will not solve this problem. Although this amendment may not increase the overall use of the Open Area, it will legitimize currently occurring dispersed recreation. A potential outcome of this type of management would be continued spread of the illegal activities to areas outside of the proposed boundaries . 13-4 Finally, thorough endemic could be the beet extirpat indicate and does strategy manageme the environmental assessment should provide a more analysis of the impacts that could occur to the two beetles and the native fish species and of means that used to avoid these impacts. With particular regard to les, permitting any actions which could result in the ion of species prior to their scientific descriptions s a iack of sensitivity to these natural resource values little towards contributing towards a true multiple use that maintains a balanced approach to resource nt . Amendment 12. Change a Portion of Ivanpah Dry Lake from Class "L" to Class "M" . As the environmental assessment indicates, Ivanpah Dry Lake is surrounded by Category 1 desert tortoise habitat and development of an airport and its ancillary features would very likely lead to degradation of this habitat. Therefore, the Service concurs with the Bureau's recommendation that this amendment be rejected. 83 SEE A 0(3 13-5 District Manager Amendment 13. Delete portion of Utility Corridor M . The Environmental Consequences section of the environmental assessment indicates that adoption of this amendment may have a minor impact on the Yuma clapper rail (Ral lus longirostris yumanensis ) , a federally listed endangered species. We are unable to determine from the document how the rail might be affected, as the proposed amendment is to remove the utility corridor from potential rail habitat. However, Section 7 of the Federal Endangered Species Act requires that all Federal agencies consult with the Service, either formally or informally, should any action undertaken by that agency have the potential to affect a listed species. Therefore, we recommend that the Bureau contact the Service with regard to this amendment to ensure compliance with the Endangered Species Act. Amendment 14. Delete One-mile Wide and Nine-mile Long Segment of Utility Corridor E. The Service recommends the adoption of this amendment, which would remove the potential of utility construction within 5,760 acres of Category 1 tortoise habitat in the East Mojave National Scenic Area. Amendment 15. Eliminate "Contingent" Corridor W. The Service also recommends adoption of this amendment because of benefits to the desert tortoise within the East Mojave National Scenic Area. Amendment 16. Change Motorized Vehicle Access from "Limited" to "Closed" in Chuckwalla Dune Thicket ACEC. The Chuckwalla Dune Thicket is dominated by large palo verdes ( Cercidium f loridium) and ironwoods (Olneya tesota ) and provides important habitat for numerous species of wildlife, including many migratory birds. Eliminating vehicle access through this area will benefit these species. Therefore, the Service concurs with the Bureau's recommendation that this amendment should be adopted. Amendment 18. Prohibit Grazing South of Interstate 10 in the Ford Dry Lake Allotment. The Service recommends adoption of this amendment which will enhance opportunities to manage bighorn sheep in the'Pord Dry Lake area. Amendment 19. New Ephemeral Grazing Allotment near Daggett. Adoption of this amendment would adversely affect bighorn sheep through potential disease transmission and competition for forage, while the desert tortoise would be affected by competition for the annual plant species upon which it feeds. The Service recommends against adoption of this amendment for these reasons. In conclusion, the Service commends the Bureau for presenting a set of amendments which, on the whole, will enhance wildlife values in the California desert. We support the Bureau's recommendations on those amendments which could affect wildlife with the exception of Amendment 11, the Dumont Dunes proposal. 84 %'€^A 0/3 District Manager 5 Additionally, we urge the Bureau to fully consider its responsibilities under Section 7 of the Endangered Species Act which requires all Federal agencies to consult with the Service if a federally funded, permitted, licensed, or constructed project could affect a listed species. Given the current situation with the desert tortoise, we recommend that the Bureau fully consider the tortoise in its planning activities in the event this species is listed in the near future. If you have any questions concerning these comments, please contact Ray Bransfield of my staff at FTS 796-4270 or (714) 643- 4270. Sincerely , Brooks Harper Acting Field Supervisor 85 Response to U. S. Fish and Response to U. S. Fish and Wildlife Service Response to 13-1 The Amargosa River is an intermittent water way through the Dumont Dunes OHV area. This stretch of the "river" does not lend itself to effective management of fish species, including the Amargosa pupfish and the Amargosa speckled dace. Both of these species are being managed in the Amargosa Canyon Natural Area/ACEC. See also responses to 6-1 and 12-5. Response to 13-2 The final Dumont Dunes Management Plan will provide procedures for signing the boundary of the adjacent WSA (four signs per mile), trail crossings, and designated routes. The WSA will continue to be monitored according to the Interim Wilderness Management Policy. One BLM ranger currently provides law enforcement in the area, and the Dumont Dunes Management Plan calls for an additional Visitor Services Ranger to work at Dumont and Rasor. Volunteers will be organized into a dune patrol, distributing information on rules, regulations, and the proper use of public lands. A brochure will be distributed providing information on the use and boundary of the area, and the sensitivities of the WSA. If signing of the boundary and education is not effective in preventing unauthorized activity in the WSA, the next management action will be fencing. Response to 13-3 The rationale for expanding the OHV area is based on use which has occurred historically, as well as the recognition of the unmanageability of an ambiguous boundary. Due to the shifting sands, the boundary was unestablishable; thus, unintentional unauthorized activity has occurred historically. Establishing a definite boundary will leave no room for misinterpretation and will provide the tool for proper management. The outcome of this management decision is not the spread of illegal activities, but the recognition of historical use and the establishment of a manageable boundary. See also response to 5a- 1. Response to 13-4 See responses to 12-5 and 13-1. Response to 13-5 The Bureau regrets that there was a typographical error in this section. We believe that adoption of the amendment will, in fact, have a minor positive effect on the Yuma Clapper Rail (RaUus longirostris yumanensis) through removing the possibility of impacts along that portion of Corridor M which is proposed for deletion. 86 P.O. Box 307 (- ^ Qj,c<^ ^pt^ Boron, CA 93596 • /-'^ July 27, 1989 California Desert District, BUA ^m ATTN: Plan Amendments I*! 1695 Spmce Street Riverside, CA 92507 COMENTS ON THE PROPOSED 1988 AHiENDT-lENTS FOR THE COCA ?LAI^f Amendment Two 14-1 But m proposing a new AC EC for Red Rock Canyon do you continue to allow restricted OHV use in Nightmare Gulch? The tortoises don't know when the raptors are nesting! The OHV route should be eliminated To make this an ACEC and leave the routes open is an obvious submission jto the pressure of the Gear Grinders. Amendment Three 14-2 14-3 14-4 Again, the Gear Grinders will keep their trail through DeDeckera Canyon. This trail is very similar to the Nightmare Gulch trail and only serves the purpose of getting ^WDs from point A to point B. Apy and all ACECs should be closed to vehicle use! Amendment Five I suspect that v/ith the proposed Fort Irwin Expansion you have little choice but to delete the Camp Irwin Boundary expansion.... "Snendment Six 14-5 [^ 14-6 But what are your plans for class designation once you delete the Kramer Hills ACEC? Please advise if this will be made a Class L larea to protect Category 2 tortoise populations. endment Seven ^pw will you class the Dale Lake area once you have deleted the ACEC? Amendment Nine How can you justify wmdpowered gPi^rating facilities on Class L lands The acres and acres of land surface disturbed in the installation and service of wmdmachines is contradictory to Class L designation. Furthermore steel trees are a big "0" in visual quality: "Amendment Ten 9 14-7 But you propose to authorize 1900 cattle yearlong in the "Mojave National ^?M^^^^^®^"' ^^ cattle understand the constraints of limited use? Must BLM make bighorn sheep compete with domestic animals for forage?. . .and tortoises? To allow cattle grazing in the MNSA is a mockery of good management. ^ Amendment Twelve If Category 1 desert tortoise habitat was a primary reason for the original Class L designation, then with the state and (emergency) federal listing, shouldn't this be a separate issue?. . .separated from livestock grazing and recreational activities? Amendment Sixteen I support the Chuckwalla Dune Thicket ACEC Amendment Eighteen There should be no grazing (not even day use) south of I-IO. If domestic animals are infecting mountain sheep, then .v/hy do you. believe there would be no transmittal of pathogen^ on a day-^use ^asis?j U^ppQ^I^I^^^ 3 Amendment Nineteen Here again bighorn sheep will be impacted. I support Alternative C Sincerel'' Hrff. Warren VI. Forgey Response to Elizabeth Forgey Response to 14-1 Vehicle use is already restricted in the proposed ACEC under a memorandum of understanding (MOU) between the BLM and the California Department of Parks and Recreation. The area is managed by State Parks as part of Red Rock Canyon State Park, except that BLM manages mining and grazing. The Scenic Cliffs/Nightmare Gulch portion of the area is closed to vehicles from February 1 to July 1 to protect sensitive resources. From July 1 to January 31, vehicle use is allowed between the 16th day and the end of each month. Response to 14-2 The Desert District has recommended that the 4-WD route between Eureka Valley and Saline Valley should remain open. This decision was in response to a large number of requests from the public during review of the CDCA Plan and during later route designation. The ultimate decision will be made by Congress when it takes action on wilderness designation. ACECs are not closed to vehicle access, although routes may be closed when necessary. Response to 14-3 The reason for deletion of the Fort Irwin ACEC was that the portions of the ACEC within the jurisdiction of the BLM contain no known cultural resources. There is no relationship to the proposed expansion of Fort Irwin. Response to 14-4 The Kramer Hills ACEC area will remain in the same multiple-use class as the surrounding area, Class M, or moderate use. The entire area is within the Consolidation Zone of the Land Tenure Adjustment Project (LTA). When the LTA Record of Decision is signed, Class M land within the Consolidation Zone will become Class L. Response to 14-5 The Dale Lake ACEC area will continue to be designated Class M, the same as the surrounding lands. Response to 14-6 The Multiple-Use Class Guidelines of the CDCA Plan specify that wind-generation power plants may be allowed in Class L areas. The Class L designation also highlights the presence of sensitive resources and insures that these areas will receive greater management attention. Proposed actions are subject to environmental review according to the requirements of the National Environmental Policy Act. Response to Elizabeth Forgey (cont.) Response to 14-7 Livestock grazing is compatible with limited use (Class L) in the East Mojave National Scenic Area. Cattle numbers and their use of forage are monitored regularly. The majority of the scenic area has been identified as being in "good" condition; the remaining areas are being managed to improve their condition. The CDCA Plan allocated forage to bighorn sheep before allocating any to cattle, in order to reduce the chances of competition between the two. Competition for forage between bighorn and cattle is usually not an issue in desert ranges, where water is often the limiting factor for sheep. We are currently trying to ascertain whether or not there is competition of any kind between cattle and tortoises. We will act to minimize these conflicts wherever possible. There are many resources in the EMNSA; finding equitable solutions for balancing them is a goal of the Bureau's multiple use mandate from Congress. 89 JOHN R. SWANSON . . P. O. Box 6554 r" ~ ^ \ Minneapolis, Minn. 55406 I C ^^ ^ O l^ \ *! f% '^^.^^ f->^<^k, \'\*t'i '^V»*\ f\T>v\*^ k^-r^vtiv\4 . sr CO rK* '^ § """■' CO '■'•1 ^'"' flC' r> en •**• ««T. ,-0 "-^ 5S'> 90 [Bs eA oiS[ < BRISTLECOIME • CHAPTER DEDICATED TO THE PRESERVATION OF THE CALIFORNIA NATIVE FLORA P.O. Box 330 Lone Pine CA, 935A5 July 26, 1989 In re: 1600 (C-060.23) California Desert District, BLM ATTN: Plan Amendments 1695 Spruce Street Riverside CA, 92507 |0 • Sf.. CD -a- CO Gentlemen : The folowing is in regard to your Environmental I— Assessment of the Proposed 1988 Amendments to the Calif- ^j;;,iiia Desert Conservation Area Plan. cirr :.:3 We are most pleased to be able to say that we agreee ,v{:^th each of your preferred alternatives for the 19 pro- ...I ^.osed amendments. Thank you for providing us with the opportunity to comment upon the proposed amendments. Yours very truly , Vincent Y^der, Conser vat y ion Chair Bristlecone Chapter California Native Plant Society 91 17-1 CALIFORNIA WiOOLi^OWERS ASSOCIATION I 1 iAi DATE *^<3a Jul 3 1 :m O 28 July 27, 1989 -■>':-:.:,. /^ Gerald E. Hillier, District Manager California Desert District Bureau of Land Management |y ATTN: Plan Amendments 1696 Spruce Street Riverside, CA 92507 Dear Mr. Hillier: The California Wool Growers Association appreciates the opportunity to submit comments on the 1988 proposed amendments to the California Desert Conservation Area Plan. The plan, and the continuing amendment process, has been an ongoing and efficient mechanism to manage the numerous resources of the desert for the groups who utilize those vast renewable resources for recreation and their livelihood. CWGA continues to support the Multiple use management of public lands. CWGA would like to comment on proposed amendments number 18 and 19. The BLM decisions to accept amendment 18 and reject amendment 19 are based in part on the interaction of domestic livestock and bighorn sheep. It is therefore appropriate to address that issue first. The bighorn fatality in the Warner Mountains is cited as one of the principal reasons for acceptance of alternative A (amendment 18) and acceptance of alternative C (Amendment 19). Dr. William J. Foreyt is cited as the principle reference to that event. There have been other works published on that event including a BLM Technical Review Team's report which followed their meetings the following summer. There are several important facts that were brought out in those TRT meetings which are not brought forth in the literature cited in the plan amendment. First: It was unclear, at best, as to whether or not there had ever l/been contact between domestic livestock and the bighorn sheep. Don Torell Joe Esnoz Jay B Wilson Pres.aeni Vice PresiOeni E.ecuiive Vice P'esideni Ukian Caiitornia losi h.iis Canlomia Sacramenio Caulo'nia Unifying the Voice of the California Sheep industry Since i860 1221 H Street, Suite 101 • Sacramento, California 95814-1910 (916) 444-8122 Q O <^<^i^A oiT Page 2 , Plan Ammendments July 27, 1989 17-1 iSecond: The weather conditions that winter were severe. The snow was abnormally deep combined with extremely cold temperatures over an extended period of time. The snow depth limited the mobility of the bighorn and covered much of the available forage. These factors alone placed a great deal of stress on the animals. 17-2 Third: After the Fish and Game Department realized that a serious problem existed in the Warner Mountain bighorn sheep population, they decided to capture the surviving animals by helicopter and place them on feed. The roundup and change from their familiar surroundings placed additional stress to the surviving bighorn. AMENDMENT 18 CWGA would like to oppose the acceptance of alternative A (Adopt amendment) and support adoption of Alternative B (Reject Amendment). AMENDMENT 19 CWGA supports adoption of alternative A. The potential permitee has demonstrated a willingness to resolve any potential conflicts in the development of an allotment management plan. The plan identifies a potential impact of grazing on the Sand Lananthus and the Monkey Flower. It is commonly accepted, and so stated in the plan amendment, that these plants are not very palatable to domestic sheep. Sheep, by nature, are very selective in their grazing behavior, having the ability to selectively remove only the part of any plant that they find desirable. If 200 lbs. of forage are required per acre on this ephemeral allotment, and the customary grazing restrictions are followed in the forthcoming allotment management plan, there would be an abundance of palatable feed available and subsequently, no reason for sheep to disturb the aforementioned plants which they find undesirable. It can not be expected that sheep would utilize this vegetation if more palatable vegetation is available. It is premature and erroneous to base this decision on the possible conflict between bighorn sheep and domestic sheep or the presence of a plant which domestic sheep find unpalatable. Once again, we appreciate this opportunity to comment. Sincerely, , Jay B. Wilson Executive Vice President 93 Response to California Wool Growers Association Response to 17-1 The California Department of Fish and Game maintains that both the Warner Mountains and Lava Beds National Monument bighorn sheep die-offs were preceded by contact with domestic sheep. The causative organism in both cases was found to be Pasturella sp. bacteria. Regardless of the Warner Mountains case, potential impact to wild sheep from domestic sheep is also documented by Sandoval (1988), in addition to the three references given in the environmental assessment. In brief, the California Wool Growers Association provides no new information to support rejection of Alternative A (adopt amendment). Response to 17-2 The conflict between bighorn sheep and domestic sheep is documented and must be considered as an impact. Potential impact to sensitive plant species from grazing or, secondarily, from trampling cannot be ignored. 1/ CA Dept. Fish and Game, 1988. Summary regarding bighorn sheep, infectious diseases, and livestock. State of California, the Resources Agency, Dept of Fish and Game (3pp.) 2/ Sandoval,A.V., 1988. Bighorn sheep die-off following association with domestic sheep: case history. Desert Bighorn Council Transactions 32: 36-38. 94 '^SEA O (« Kemcrest Chapter National Audubon Society P.O. Box 984 Ridgecrest, CA 93556 RECE^VEa '383 JUL 3 \ ?H 3: 50 CHIP, il: S- - ■■"' • • - 11 — -. ■ 'l>< INIT. \ nm 18 IsOUTlNG 5 TO: DATE California Desert District Bureau of Land Management 1695 Spruce St. Riverside CA 92507 Attn: 1988 Plan Amendments Dear Mr. Hillier, PIPE sis July 27, 1989 t" Lutein 3p: jVUN_j L— At^i^^ ^ LACTIC rm 18-1 This is an addition to our July 25 comments. Concerning Amendment ^t6 Kramer Hills ACEC deletion - would it be possible to adjust the ACEC boundaries to exclude a possible gold mine rather that deleting the entire ACEC? We would like to work with you on a mutually agreeable compromise if you delay action on this Amendment. Thank you for your consideration. Sincerely, Donald W. Moore, President 95 Response to Kerncrest Chapter, National Audubon Society Response to 18-1 Deletion of the Kramer Hills ACEC is not related to the mining operation in the area. The subject gold mine is proposed for privately-owned land that is not under BLM jurisdiction. The ACEC deletion is based on the finding that the area does not contain the significant cultural resources for which it was originally designated. 96 f Rf . I^itedl^ates Department of the Interior IN REPLY REFER TO: ^^^^ JUL 3 I '^ K)WER j'lir T-: iSlGT UREAU OF RECLAMATION COLORADO REGIONAL OFFICE P.O. BOX 427 BOULDER CITY, NEVADA 89005 LC-159 ENV-6.000 Memorandum To: ^^t. 2 7 1989 19 Mr. Gerald E. Hillier, District Manager, California Desert District, Bureau of Land Management, 1695 Spruce Street, Riverside CA 92507 Attention: Plan Amendments From: Regional Environmental Officer Subject: Review of Environmental Assessment for the Proposed 1988 Plan Amendments to the California Desert Conservation Area Plan of 1980 (Environmental Assessment) We have reviewed the subject plan as requested. The Bureau of Reclamation presently has a ground water recharge test project in the East Mesa area along a section of the abandoned Coachella Canal. Water is released into the abandoned canal and allowed to infiltrate into the underlying ground water aquifer. We have been contemplating the use of spreading basins outside the canal prism as part of our recharge project. Amendment Nine m the plan recommends adopting the concept of changing Class "M" lands to Class "L" lands. We would like to know what effect this change in classification could have on our project. We would appreciate a response to our memorandum at your earliest convenience. (jJjM,^^ £. /fx; 97 Response to U.S. Bureau of Reclamation, Lower Colorado Regional Office Response to 19-1 BLM sent a memo to the Regional Environmental Officer indicating that the MUC change would not affect the proposed recharge basins and that an environmental assessment would be required. The memo described in detail the reasons for the change and noted the presence of several ACECs and a Habitat Management Area. Also described were several of the sensitive wildlife species found at the East Mesa. The memo concluded that "future environmental assessments for recharge projects should consider all reasonable alternatives, including pumping rather than creating spreading basins." 98 "."•7f* FlE •> — 'JC 99 \ktQA 6^1 STATE OF CALIFORNIA— THE RESOURCES AGENCY GEORGE DEUKMEJIAN, Governor DEPARTMENT OF PARKS AND RECREATION Southern Region Headquarters 1333 Camino Del Rio South, Suite 200 San Diego, California 92108 (619) 237-7961 August 11, 1989 21 21-1 Ms. Irene Rice California Desert District Bureau of Land Management 1695 Spruce Street Riverside, California 92507 Dear Ms. Rice: Thank you for the opportunity to review the Environmental Assessment prepared for your proposed 1988 Plan Amendments to the California Desert Conservation Area Plan of 1980. The California Department of Parks and Recreation supports the designation of lands adjacent to Red Rock Canyon State Park as an Area of Critical Environmental Concern (ACEC) . As noted in your proposal, this amendment would provide additional, and much needed, protection for wildlife, vegetation, rare and endangered species of plants and animals, archeological resources and paleontological sites on lands currently co-managed by our two agencies. Our Department continues to be interested in acquiring this land as an addition to Red Rock Canyon State Park, and your proposal for increased protection of these resources is consistent with our management goals for the are* Sinc^r^iy, Kenneth Southern ones. Regional Director eg ion cc: R. Rayburn G. McDaniel J. Geary ]00 Response to CA Department of Parks and Recreation, San Diego Response to 21-1 Your comment is noted. 101 ;SfrUO IS P r ' I" •■^ •,. i;tsi '6(2 ^A ozi. Gear Grinden Four Wked Drive Club P.O. BOX 32 RIDOECRC8T. CAUF. SSBSB Gerald E. Hillier, District Manager California Desert District Bureau of Land Management 1695 Spruce Street Riverside, California 92507 RE: 1988 PROPOSED PLAN AMENDMENTS 22 Dear Mr. Hillier, 22r^ We, the members submitt the foil Desert Conservat Amendments #2 - Gear Grinders ha Corridor and wit reation. High De agreements provi of the Gear Grinders 4WD Club of Ridgecrest, would like to owing comments to the 1988 Proposed Amendments to the California ion Area Plan of 1980. We will specifically be addressing Nightmare Gulch/Blackrock Canyon and #3 - Dedeckera Canyon. The ve "Adopt-A-Trail" aggreements with the BLM for the Eureka/Saline h both the BLM and the California Department of Parks and Rec- sert Area (CDPR) for Nightmare Gulch/Blackrock Canyon. These de for the maintenance of existing AWD trails. First, however; if not for the announcement in the paper concerning these proposed amendments, the Gear Grinders would not have known of these proposed changes which could potentially affect our recreation in the two areas, as well as the existing "Adopt-A-Trail" agreements. We feel it should be mandatory that all parties to an Adopt-A-Trail agreement be notified of any potential manage- ment changes to an an area covered by a cooperative management agreement. CHAPTER 3, AFFECTED ENVIRONMENT NIGHTMARE GULCH/BLACKROCK CANYON We feel this proposal adds yet another layer of unecessary protection to this area. Protection is already afforded the area by the 5 month closure to ALL entry, during the raptors nesting season, as well as the 2 month vehicle closure during the months of July thru January. Also, since the area is already managed by both the CDPR and the BLM, an ACEC designation is unecessary and redundant. The desert tortoise is protected in this area by the five month raptor closure, as the tortoise is most active from March through June - when it returns to it's burrows to hibernate through February (according to the BLM's Toroise literature). The Statement is made that ". . . the Mojave ground squirrel may occur in por- tions of the affected area." The actual presence of the Mojave ground squirrel in the "affected area" has not been substaniated and so we assert that this is not a valid reason for establishing an ACEC. 102 g^fe/l ozz 1988 Proposed Amendments, Page 3 Gear Grinders 4WD Club Therefore, we strongly urge the BLM to REJECT Amentment 2, An ACEC for land ajacent to Red Rock Canyon. 22-3 AMENDMENT THREE NEW ACEC AT DEDECKERA CANYON First, most people will ask, "Where is Dedeckera Canyon?" We, too, had to look at the map to decide where it was located, and our immediate response was "Oh, the Eureka/Saline Corridor." We hope this is just the name of the "canyon" and not an attempt to change the historic name of the Eureka/Saline Corridor. 22-4 22-5 CHAPTER 2, ALTERNATIVES We recommend that the current management be maintained, and the added title of ACEC is not necessary. On Page 2-2, under "Proponent's Reason for Submission", reasons stated for the establishment of the new ACEC include: "There is evidence that they should be protected from degradation", yet nowhere in the text is there any evidence given substantiating the "degradation" to archaeological sites. Also, "Camping in the canyon could be hazardous to both the natural resources and to the campers, as flash floods may sweep down the canyon with great force." First, camping in the canyon would be infrequent, at best, because of the camping available at the Eureka Dunes and the hot springs in Saline Valley. The Gear Grinders have camped twice at the north of the "narrows" while doing trail maintenance, however, this is not the norm. The hazard of flash floods to campers in the canyon is an emotional statement that is completely invalid. Any canyon in the desert is a hazard in those conditions, and common sense should protect most visitors. However, the statement does show that flash floods are the source of more damage to natural resources than would be any campers. Indeed, any evidence of campers would be removed. CHAPTER 3, AFFECTED ENVIRONMENT We agree that "the dolomite cliffs of the Last Chance Range provide nesting and roosting habitat for raptors as well as habitat for bighorn sheep." This is not justification, however, for an ACEC. (Page 3-3) We agree "the cliffs of the Last Chance Range also provide habitat for many plant species endemic to the Death Valley Region." However, neither is this a justi- fication for an ACEC designation. A cultural resource inventory "may" need to be done, but an ACEC designation solely for the purpose of obtaining more funds is not appropriate. At the Desert Advisory Council Meeting in Riverside this past June, a statement was made to the effect that an ACEC designation could be used to obtain funding for a cultural resource inventory. We do not feel that an ACEC designation is the appropriate vehicle for obtaining funds to do a cultural resource inventory, and that is is not a valid land management tatic. 103 £<6BAo^-z. 1988 Proposed Amendments, Page 2 Gear Grinders 4WD Club 22-2 As has already been noted, off road vehicle use in the area is restricted by an MOU between the BLM and the State Park to certain portions of the year, which minimizes the impact, if any, to wildlife and vegetation. The Nightmare Gulch vehicle trail itself, being situated at the bottom of a steep-walled canyon, does not permit vehicles to stray off the route and access to cultural artifacts, such as the geoglyph on the rim of Nightmare Gulch. Access to the geoglyph is greatly restricted by the same steep walls of the gulch, which makes hiking to the geoglyph hazardous. Mining is not a factor within the proposed ACEC. After checking the records of the nine mining claims within the proposed ACEC, it was found that none are active, as they have not filed plans of operation or notices of intent. Under Recreation, the statement "There are four OHV routes of travel in this area." is not accurate. The only two designated routes are the Nightmare Gulch and Blackrock Canyon trails, which are NOT shown in their entirety (see attached map #1), which together form a loop trip through the area (see attached map #2 for entire trail). Both are maintained as one trail by the Gear Grinders under the Cooperative Management Agreement with the BLM and California Department of Parks and Recreation, High Desert Area. To address the Cultural portion, the geoglyph is up on the rim of Nightmare Gulch, as stated previously, and is both both inaccessable by vehicle and extremely difficult to find. Human intrusion will not be a factor on this artifact, unless its location is posted. CHAPTER 4, ENVIRONMENTAL CONSEQUENCES In this section Pages 4-2 and 4-3, contains some statements that are either disturbing or give no real indication as to the future status of the existing OHV routes. Under Wildlife, "An ACEC could allow greater restrictions on activities, such as grazing and mineral exploration and development." Glenn Harris, the Ridgecrest Resource Area Range Specialist, indicated to us, that although this area is part of the Cantil Common Allotment, it is not suitable for grazing and is not used for that purpose. Again, under Recreation, there are only two designated routes. Other than the seasonal closures, there are no valid reasons to close either Nightmare Gulch or Blackrock Canyon to vehicle travel. Under Cultural Resources and Paleontological Resources, the statement is made that "Designation of this area as an ACEC would have little affect on cultural or paleontological resources." Another statement is made that "Under the MOU between BLM and Red Rock Canyon State Park, the area is currently managed as if it were within the State Park." and also ". . . the area is already receiving special management attention. . ." . Therefore, as vehicle usage within the area is already well managed, and as neither grazing nor mining are currently factors within the proposed ACEC, we do not feel that the establishment of an ACEC is required or desirable. 104 ^e ~ I.-5 tr - «4K.8 PjijQ. ELDEN HUGHES 14045 Honeysuckle Lane Whittier, California 90604 (213) 941-5306 mm August 16, 1989 24 24-1 24-2 24-3 California Desert District Bureau of Land Management Attn: Plan Amendments 1695 Spruce Street Riverside, CA 92507 RE: Amendment 11, Change class M to class I and vehicle access from Limited to open in area adjacent to dumont dunes OHV Area. None of the alternatives which enlarge the OHV area are adequate. Essentially they reward the past "breaking of the rules/ lack of enforcement" by saying if the area has been trashed, let's include it in the OHV area. The buffer is neededo protect the WSA's, the ACEC, and the Amargosa. To say "the present boundary is unmanageable because the area of the dunes, themselves, changes constantly due to the shifting of the sands" is to display ignorance of both the dunes and management. To make the statements (4-13) that there is a high probability of cultural sites, but we will avoid the significant ones, while at the same time saying this is the area of historic use, makes the BLM look less than competent. I recommend alternative D. Likely the camping areas need to be provided for, but neither A B or C provide adequate protection for surrounding resources. Sincerely, 114 Response to Eldon Hughes Response to 24-1 See response to 5a- 1 and 13-3. Response to 24-2 The writer's concern about needing a buffer to protect the WSAs, the ACEC, and the Amargosa River was relieved by an on-site visit with BLM personnel to observe the area and review management actions which are planned for protection of the areas of concern. Response to 24-3 The term "historic use" refers to historic recreational use. See also response to 12-4. 115 j'ffft^A czS^ Mary L. Grimsley R F. 1 — Pi(^r i 'i 'v August 10, 1989 M AUG i 8 FH 3: G2 Gerald E. Hillier, District Manager California Desert District Bureau of Land Management 1695 Spruce Street Riverside, Ca. 92507 RE: 1988 Proposed Plan Amendments ro; DATE INIT. 5^_ ADM PA Ad.m'n _BJHS_„ Mk'xl AiVls ACTION DY: PETURN TO: 1012 N. Sierra View Ridgecrest, CA 93555 619-446-3458 --i 25 Dear Jerry, I would like to thank you for extending the public comment period to August 21. Enclosed are my personal comments on a couple of the amendments with which I am familiar with. As you may know, I am a member of the Gear Grinders 4WD Club in Ridgecrest, and the Gear Grinders has both of the "adopt-a-trail" agreements for the Nightmare Gulch/ Blackrock Canyon area (amendment 2) and the Eureka/Saline Corridor (amendment 3 - Dedeckera Canyon). We have had both of the agreements for several years, and have done the required maintenace of each trail each year, so I have on the ground knowledge of both areas. AMENDMENT 2 - NIGHTMARE GULCH/BLACKROCK CANYON I have been involved with helping to retain the "use of vehicles on existing trails" in this area since the time the State applied to have the area added to Red Rock State Park. At that^time, the State demonstrated that existing uses were incompat- able with State guiolines, and said, in-as-much, that Nightmare Gulch would be closed to vehicle travel. Therefore, the BLM retained the area but has allowed the State to manage it with the provision that vehicle travel would be permitted in the area. Next came the attempt, by environmentalists, to get the area closed to vehicle travel, which ended in the ^-month time sharing that exists today. Then came the raptor closure from Feb. 1 - July 1 by the Audubon Society. Now the Audobon Society has proposed an ACEC designation for the area. How nice. Next year they will have an amendment that vehicle travel is incompatible with an ACEC designation, that is of course if a vehicle closure is not installed during the ACEC planning process. Jerry, this was all decided already, with a trip by the BLM Desert Advisory Council and BLM personel through Nightmare Gulch, seeing that the slow vehicle travel through the Gulch was not having a negative impact on either vegetation or wildlife. Mother nature has changed the Gulch so significantly over the last ten years, it is sometiriies hard to believe it is the same canyon bottom. I have seen it scrubbed out down to the bedrock, and the next year it is covered. I have seen the sides cave in, creating a lake behind the cave-in and raising the canyon bottom ten feet. The next year water had carved it's way through the cave-in, and the bottom was lowered. 116 Mary L Grimsley Comments re; Proposed Amendments, Page 2 25-1 I feel this is another layer of unecessary protection being added to this area. The protection that is already in place for the area with the 5-month closure to all entry during raptor breeding/nesting, along with the State Department of Parks and Recreation (SDPR) management, with the BLM overseeing, an ACEC desig- nation is unecessary. Reading information phamphlets provided by the BLM, I found that the most active time for the desert Tortoise is March through June, when they pretty much return to their burrows, to hibernate till February. This is during the raptor breeding/ nesting time, when the canyon is already closed, so this is not a valid reason for the proposed ACEC. 25-2 In reference to: "The Mojave ground squirrel may occur in portions of the affected area.", is an inappropriate and invalid statement. Dinosaurs "may occur", but no one has seen them. Page 3-2. By the BLM's own admission, "A memorandum of Understanding (MOU) with Red Rock State Park currently affords protection for wildlife by controlling OHV use." Page 3-2. With 5 months of the year closed to OHV (and all other uses), and the other seven months are affected by the 1st half of the month closed to OHV use, the OHV use is very minimal. On page 3-3, under vegetation, "The MOU with Red Rock State Park affords the plants some protection by controlling OHV use", and the statements, ". . . judged by California Native Plant Society to be vulnerable under present circumstances." and ". . . the CNPS considers vulnerable under present circumstances" are all irrelevant and misleading. Considering the forces of Mother Nature, which have changed the bottom of Nightmare Gulch from scrubbing it out down to the bedrock, and then, filling it back up with sand and rock, and still the plants come back and grow and survive. Unless, of course, the CNPS isn't talking about Nightmare Gulch, but the surrounding areas, of which there are no OHV trails or tracks. As with mining affecting the wildlife and plants, after checking the records, there are 9 mining claims within the proposed ACEC, none of which are active, for they have not filed plans of operation or notices of intent. Under recreation, page 3-3, the statement "There are four OHV routes of travel in this area." is completely untrue and misleading. The only two designated routes are the Nightmare Gulch trail and the Blackrock Canyon trail - which together form a loop trip through the area. The other two trails (marked on Appendices Map-attached) have not been designated trails for quite some time. On the map in the Proposed 1988 Plan amendments, in the Appendices, the complete trail system of Nightmare Gulch and Blackrock Canyons are not shown, so I have attached a second map (map #2) which was printed out of the file which can be found at the Ridgecrest BLM Office. I also take to task the statement ". . . frequent day use of the area for hiking by people enjoying the area's scenic qualities and interesting native flora and fauna." Hikers do not have a monopoly on enjoying scenic qualities and fora and fauna. That is the same reason we, 4-wheelers, enjoying driving the gulch, to show new people and visitors the unique geologic formations, as well as "seeing" various raptors, bobcat, and fox. The wildlife are not as afraid of vehicles as the public is being led to believe. Man poses more of a threat on foot than in a vehicle. The geoglyph is up on the rim of Nightmare Gulch, and is extremely hard to find, even when you know what to look for. Being basically unkown, has protected it so far. Do not sign it to bring it more attention, or it will disappear. Weather is it's greatest enemy. 117 Mary L. Grimsley Comments re; Proposed *88 Amendments, Page 3 25-3 In Chapter 4, Environmental Consequences, on Page 4-2 & 4-3, there are some state- ments that are confusing and give no real indication asn:he future of these existing OHV routes. Under Wildlife, "An ACEC could allow greater restrictions on activities, such as grazing and mineral exploration and development". I went to the Ridgecrest BLM Office to investigate grazing and mining in the area. According to Glenn Harris, Ridgecrest Resource Area Range Specialist, this area is part of the Cantil Common Allot'^ent, however it is not used for grazing. It was part of the old "stock driveway". According to Mr. Harris, "this area doesn't lend itself to grazing". I checked the Red Rock/Nightmare Gulch file in the Ridgecrest office, and also talked to the ranger in charge of mining claims, and there are nine (9) claims, of which none are active as nq/Gne has filed a Plan of Operation or an Intent to Mine. 25-4 Again, under Recreation, there are only TWO designated routes. Other than the seasonal closures, there are no valid reasons to close either Nightmare Gulch or Blackrock Canyon. Under Cultural Resources and Paleontological Resources, the state*^is made that "Designation of this area as an ACEC would have little affect on cultural or paleontological resources." 'Ilien why make the area an ACEC? Another statement, "Under the MOU between BLM and the Red Rock Canyon State Park, the area is currently managed as if it were within the State Park.", and (in summary) ". . . the area is already receiving special managQHipnt attention . . .". Then why make the area an ACEC? Additional restrictions on grazing no longer applies, and with the strict mining regulations, the fact that mining is generally around the peremitter of the proposed ACEC, and that no raining is currently being proposed by the current mine/claim holders, I do not f«el that an ACEC is necessary, but redundant. Therefore, I strongly urge. the Bureau of Land Management to reject Amendment 2, an ACEC for Land Adacent to Red Rock Canyon. AMENDMENT 3 - NEW ACEC AT DEDECKERA CANYON On Page 2-2, under Proponent's Reason for Submission, reason's stated for the establishment of the new ACEC include, ". . there is evidence that they [archaeo- logical sites] should be protected from degradation", yet, nowhere in the text is there any evidence given substantiating the "degradation" to any sites. Also, "Camping in the canyon could be hazardous to both the natural resources and to the campers, as flash floods may sweep down the canyon with great force." First, camping in the canyon is infrequent at best, considering the camping available at Eureka Dunes and at the hot springs in Saline Valley. The Gear Grinders have camped twice north of, near, the "narrows", while doing trail maintenance, however, this is not the norm. The hazard of "flash floods to campers in the canyon" is an emotional statement that is completely invalid. Any canyon in the desert is a hazard in those conditions. Both Ridgecrest and Olancha should be moved from their present locations to high ground. However, the statement does prove one point: flash floods cause more damage to the natural resources as it "sweeps down the canyon with great force", than would any campers. In fact, any evidence of campers would be removed. 118 25-5 25-6 Mary L. Grimsley Comments re: Proposed '88 Amendments, Page 4 I am sure that "the dolomite cliffs of the Last Chance Range [probably] provide nesting and roosting habitat for raptors as well as habitat for bighorn sheep." However, this does not mean an ACEC is necessary. I agree "the cliffs of the Last Chance Range also provide habitat for many plant species endemic to the Death Valley Region"(Page 3-3). 1 recently learned that Ms. Mary Dedecker visited Cerro Gordo, and pointed out a Category 2 canidate for listing plant - July gold (Dedeckera eurekensis) around the mining camp, which I would assume is growing all through the Inyo Mountains, and not just in Dedeckera Canyon. I feel the above statement could be applied throughout the region, and is a weak argument for an ACEC designation. A cultural resource inventory "may" need to be done, but an ACEC designation solely for the purpose of obtaining more funds to do so, [according to a source which attended the recent Desert Advisory Council meeting in Riverside], is not appropri- ate. Stated under Recreation, "Very little, if any trail proliferation has occurred." The terrain on each side of the corridor does not lend itself to cross-country travel, hence, there is no trail proliferation. Also stated, "Some visitors to the area hike up side canyons to examine the proposed ACEC's unique flora and fauna". This statement eludes to the fact where the unique flora and fauna is located, ana not where vehicles are likely to disturb them. Page 3-4. In Chapter 4, Environmental Consequences, the statement under Wildlife and Vegetation "An ACEC could give added protection to the sensitive plant species July gold by controlling the activities of users of the Eureka-Saline Corridor". What kind of "controlls" are you talking about, when under Recreation, the statement is made, "Since the only route within the proposed ACEC would remain open, there should be no effect on any recreation activities . . ." ?? One statement contradicts the other. Under Alternative B, "Any proliferation of the Eureka-Saline Corridor or irresponsible activities by users of the route could have detrimental effects . . . " is an unsubstantiated and invalid statement. Therefore, I strongly urge the Bureau of Land Management to reject Amendment 3, a New ACEC at Dedecera Canyon. AMENDMENT 11, DUMMONT DUNES I do support the BLM position on adopting Alternative B for the Dummont Dunes, as it would - as stated on Page 2-5 "include the majority of the historic OHV use area, provide for family and individual OHV activity, and would improve the boundary manageability." I also agree that adding Area 4 is not necessary. Thank you for considering my thoughts and comments on these proposed amendments. I hope they will help you make that difficult decision. 119 Sincerely, Mary L. Grimsley Response to Mary Grimsley Response to 25-1 See response to 22-1 Response to 25-2 See response to 22-2 Response to 25-3 See response to 22-2 Response to 25-4 See response to 22-1. Response to 25-5 See response to 22-5. Response to 25-6 See response to 22-4. 120 SSea o 2^ ^'/Of ; 19 August 1989 ;oi.j AUG 2\ ^H !• 23 California Desert District Office _ Bureau of Land Management. ^ - _'•;>••'•"» ATTN: Plan Amendments '"^ 1695 Spruce Street 26 Riverside California Dear Mr. Hillier, 26-1 The purpose of my letter is to provide clarification of the back country vehicle use opportunities in the proposed Red Rock Canyon ACEC(Amendment #2). The plan indicates that there four designated routes of travel in the ACEC area. The map provided does not correctly show the trails available for use. Enclosure (1) presents a corrected map showing both open and existing closed trails. EP 123,EP 120 and EP 125 form part of a loop trail which is maintained under an Adopt-A-Trail agreement between the GearGrinders 4WD Club and the BLM. Vehicle use of EP 123 and EP 120 is prohibited from the 1st through the 15th of each month. Further, EP 123 and EP 120 are closed to all public entry from February through June to protect raptor nesting. Trails 1 through 5, shown on the attached map, are closed to vehicle use. Has the State Park been illegally denying vehicle access? Clarification of which trails are suppose to be open to back country vehicle use is needed. Nightmare Gulch(EP 123) and Blackrock Canyon(EP 125) are unique areas and deserve special protection. In my view, this area is currently receiving that protection. Unfortunately, I view the proposed ACEC status as simply another strategy for the ultra-environmentalists to "get the vehicles out". A goal that they have been working toward for 10 years. I just finished reviewing the Afton Canyon ACEC Management Plan, and was very disillusioned to see vehicle routes in non-sensitive areas arbitrarily closed. With these fears in mind, I must oppose ACEC status for Red Rock Canyon and recommend rejection of Amendment #2. ' -lerry D. Grimsley -^ lOlii N. oierra View Ridgecrest Ca. 93555 121 ^: ■tfi 'hi. !?■•: J»- - :, m 122 £)^£.6o^<^jLcr ({) Response to Jerry D. Grimsley Response to 26-1 See response to 22-2. 123 ^■^ 'S33 m 2 ; ?H { 7SE/=\ oxi ,. ELDEN HUGHES 14045 Honeysuckle Lane n J Whittier, California 90604 i^ijiRlCr (213) 941-5306 August 16, 1989 27-1 27 California Desert District Bureau of Land Management Attn: Plan Amendments 1695 Spruce Street Riverside, CA 92507 RE: Amendments Deferred: 88-p-15 Remove all grazing in the East Mojave National Scenic Area west of Kelbaker Road. I submitted the above amendment in behalf of the Sierra Club. The amendment discussed scenic values in the Kelso dunes which were note addressed in reason for deferment. The stated reason for deferment is an evaluation in an upcoming study. The bighorn are at risk. The scholarly papers submitted with the amendment, document the risk. If the BLM is funding the upcoming evaluation, then it should state who is doing the study, when it will be completed, what criteria will be used to determine the "at risk" status of the bighorn sheep, and who will submit the appropriate amendment. The deferral statement is totally inadequate. Sincerely, Response to Eldon Hughes Response to 27-1 Conflicts between cattle and scenic values in a small area can be resolved without eliminating grazing on 375,000 acres. The Kelso Dunes are largely untouched by cattle or humans. Efforts are currently underway to reduce the number of cattle in the parts of the dunes that receive the most visitor use. There are presently two separate studies on possible conflicts between bighorn sheep and cattle. Although cattle have been blamed for spreading diseases to bighorn, there is no clear evidence that they carry the diseases in question. In the first study, the Department of Fish and Game will study pathogens in the blood serum of bighorn and cattle in the Granite Mountains. In the second study, Dr. John Weyhausen has compared bighorn sheep in the Marble Mountains (no grazing) with sheep in the Old Woman Mountains (grazed). He is now comparing bighorn in the Old Dad Mountains (no grazing) with bighorn in the Granite Mountains (grazed). If the results of the above studies show that cattle grazing is depressing the local bighorn populations, BLM will attempt to correct the situation. A Plan Amendment will be introduced, if necessary. Proposals from other private or governmental agencies will also be considered at that time. If the results of the studies fail to establish a link between cattle and sheep populations, BLM will continue to support and facilitate studies that might identify factors that limit the bighorn sheep population. 125 ^^^ ?g€^/^ciz8 V - - — 5)f;5= *:- --.q:^ Mir '7 ' .„-„,„ SIERRA CLUB " "iSotiAE^m California Regional Conservation Committee August 16, 1989 28 28-1 28-2 California Desert District Bureau of Land Management Attn: Plan Amendments 1695 Spruce Street Riverside, CA 92507 Dear Mr. HilXier^ The Sierra Club offers the following comments on the 1988 Proposed Plan Amendments. First, once again, we repeat that one of the plan amendments ought to be to eliminate the cycle of annual plan amendments. The annual self examination hardly gives any Resource Area Manager the discretion to make a decision based on the existing plan before one of the proposed decisions gets tossed up as a Plan Amendment. The annual process is extremely labor intensive costly and time consuming. It defeats the purpose of planning ' which is to GIVE DIRECTION AND GUIDANCE FOR INDIVIDUAL DECISIONS BY RESOURCE AREA MANAGERS. The inefficiency of the annual process is illustrated by the fact that it is halfway into 1989 and we are :ust now looking at proposed 1988 amendments. Before these were available to the public the deadline had passed for submitting the 1989 proposed amendments. Comments on specific Plan Amendments 1. Sierra Club supports the designation of the new ACEC at Rodman Mountains . 2. Sierra Club supports the new ACEC adjacent to Red Rock Canyon in so far as it improves possible management of the area until the lands are deeded to Red Rock Canyon State Park as is proposed m S.ll, H.R. 780. We find the justification very curious. BLM resisted transferring these lands to Red Rock Canyon State Park It agreed to do when the park was established. Much toot dragging by BLM occurred because BLM has maintained that it felt It necessary to retain title to the lands so that: mining could continue; grazing could contiue: and ORV could continue. However , A. ORV traffic has had to be curtailed because it was disturbing eagle nests and traversed the very canyons where the 126 28-2 28-3 A endangered plants were trying to survive. p B. if it is designated as an ACEC, BLM "could allow greater restrictions on activities such as ... mineral explorationn and development. " C. if it is designated an ACEC, BLM could place "greater restrictions on activities such as grazing...." What justification then remains for continued BLM title? Are the few blades of grass in this portion of one desert allotment more important than the endangered plant species? We also noticed that grazing restrictions will help the wildlife but not the plants. Except for preparing the necessary ACEC plan, (probably with funds from the State Fish and Game Commission) BLM will have little on the ground responsibility in this area, since it is being patrolled already by State Park rangers. As it states in the EA portion, the area is already being managed as part of the State Park. Why then the resistance to giving the State Park title? Since, the "No Action" alternative admits that the current Desert Plan is not capable of maintaining the habitat for the Mojave Ground Squirrel, Desert Tortoise, as there is little choice but to opt for the ACEC at present. There is an omission in the environmental assessment in that it does not spell out what the relationship will be between this ACEC and the ACEC just to the east that encompasses Last Chance Canyon where there are at least 60 sites of historic and prehistoric interest. 28-4 3. We support the designation of the ACEC for Dedeckera Canyon. We are however, confused about the intent and probable management actions contemplated for this ACEC - they seem inconsistent and at cross purposes. The mere designation will not protect anything unless the land managers have something to implement. There is an assertion that there will be additional protection by "controlling the actions of users on the Saline- Eureka Corridor." However, it also states that there will be no effect on recreation activities which are in conformance with the IMP. (Does that mean that BLM is aware of activities not in conformance and cannot control those activities without the designation of the ACEC? What does that say about non- conformance in areas in which there is no ACEC?) It also states that the open route could be a potential threat to adjacent resources (presumably the Dedeckera for which the canyon is named), and that the route will remain open. Does the designation of this ACEC indicate that protection of the recently discovered and sensitive Dedeckera is considered more important? How important is it? Obviously not as important as keeping the route open. How will the actions of users of the route be controlled without having an effect on the recreation activities of users of the canyon? 4. We support the expansion of the Coyote Mountains ACEC. 2 127 28-5 28-6 28-7 What does "increased management priority mean" in terms of management direction? The document should be able to say plainly that collection of fossils will not be allowed in the ACEC if that is the intent. That does seem to be the management direction when one reads the section on effects of the designation on Recreation. Is there a management plan for the existing ACEC? Would this additional area operate under the same general management plan? Was this information discovered during the preparation of that ACEC? 5. BLM is not entitled to simply abandon the ACEC site if it is important. What will Fort Irwin be doing to protect the cultural resource? Appendix D, Page 74 of the Desert Plan states that the Secretary of Defense has relingquished responsibility for cultural preservation to the Secretary of Interior, thus it appears that acceptance of the Plan Amendment would not be in cgnformit with existing policy. TTand 7. Are we to presume that the Kramer Hills and Dale Lake sites have been decimated? If there is nothing there, it makes sense to remove the designation. If there was a mapping error, then the correct sites should be located. Current archaeologisti^ on staff at BLM are surely no more or less susceptible to mappinq errors than the members of the Desert Plan staff who located the site originally. Where is the assessment of the effect of removing this ACEC designation to the Desert Tortoise? FLrar.er Hills lies within important tortoise habitat. 28-8 3. Sierra Club would support a change from Class M to Class C if that is what Is required to protect the Flat Tailed Horned T.izard, geoglyphs and other cultural resorces. It appears that changing to Class L would only prevent NEW sources of impact, ,3uch as land disposal. Existing plans have NOT, according to 5LH'*s own statements, succeeded in halting the degradation. The principal culprit is ORV use, but the class change would not do anything more to restrict vehicle activity. If in the absence of wiineral entry problems and land disposal BLH is unable to save the resource, what good will the class change do? It appears to be too little, and too late. 9. Sierra Club supports the class change for East Mesa. The map and the text are not consistent. The text states 28-9 fciiat the area of high ORV use around Gordon's Well will be excluded, but the map appears to include the area. Which is it oaing to be? There is another inconsistency with respect to the Desert ilan. Under the Motorized Vehicle Element, the current ACEC is indicated as only being available for approved routes of travel, 23- "lo^^^^-^ ^^ ther*rf is ORV play and associated camping as is described, it is not supposed to be perraitted. Such use should be described. There is an inadequate description of the existing ORV use. 128 28-10 2&-11 A There is an inadequate description of the existing ORV use. Low to moderate use, when it comes to ORV areas, means that there may still be 6 or 8 foot creosote bushes standing. Something more quantitative is needed. The Sierra Club has personally viewed several groups of 10 or more ORV support vehicles (camper, truck, motorhome, etc.) at many points along the west side of the Coachella Canal on the same day. There is practically a "highway" which runs alongside the canal. As in the case with Amendment 8, the principal culprit in endangering the resources appears to be ORV use. If such use is not going to be constrained then restrictions on possible dangers from landfills, mines or agriculture will not be enough to save the resource. 2&-12 10. The Sierra Club has cosistently supported more protective class designations inside the national scenic area. Progress is being made — it moved from unclassifed to M, now we're moving from M to L. 11. and 12. Sierra Club opposes both class changes. The first, for the expansion of the Dumont Dunes Open area, is uncalled for, and would be extremely destructive of the Wilderness Study Area resource values. Never have we seen an ORV area in which users stayed where they were supposed to unless there is an enormous natural barrier. Making the ORV boundary contiguous with the WSA boundary (fortunately not proposed for overlap as in the case of the Imperial Dunes) is inviting conflict along the boundary. Also, the natural resources of Amargosa Canyon would be endangered. We would prefer the area have no change than one which rewards unauthorized and illegal use outside the open area by expanding the open area boundaries. 16. Sierra Club supports the change in Chuckwalla Dune Thicket Motor Vehicle Access. Please correct the document. One place refers to a September 1981 ACEC plan implementation, another to a 1982 ACEC plan. 17., 18., 19. We support the changes proposed in Amendments 17 and 18, and oppose the grazing increase of Ameendment 19 Sincerely, Jira.ith X. Anderson for the Desert Committee JA:ts 4 129 Response to Sierra Club, Judith Anderson Response to 28-1 Your comment is noted. Response to 28-2 Your comment is noted. Response to 28-3 The Last Chance ACEC is approximately 4 miles north of the proposed ACEC. It is designated for protection of cultural resources and has no particular relationship to the proposed ACEC. Response to 28-4 See responses to 14-2, 22-4, and 22-5. Response to 28-5 The term "increased management priority" means that fossil resources within the Coyote Mountain area would receive greater attention. Prohibition of fossil collection became necessary when Bureau personnel noted an alarming reduction in fossil numbers in prime areas. Fossil collection in the expansion area was placed under a temporary prohibition ordering April, 1988; this restriction will become permanent with the approval of this amendment. The expansion area will be managed under the prescription of the ACEC activity plan completed in 1987. Response to 28-6 The National Historic Preservation Act (Sections 106 and 110) requires the Army to manage cultural resources within the boundaries of lands under the Department of the Army's jurisdiction. In addition, the Army has a memorandum of Agreement with the State Historic Preservation Officer and the Advisory Council on Historic Preservation to assist Fort Irwin personnel in their identification and inventory program on cultural resources. See also response to 11-1. Response to 28-7 The Dale Lake and Kramer Hills ACECs were established by the CDCA Plan in 1980. The field data used by the CDCA staff was based on resource information and recommendations submitted by individuals from the private sector. Neither of the proposed areas was evaluated 130 Response to Sierra Club, Judith Anderson (cont.) in the field by BLM archaeologists prior to their designation as cultural ACECs. Attempts by BLM archaeologists (since 1980) to locate significant archaeological sites within the boundaries of both the Dale Lake and Kramer Hills ACECs have been unsuccessful. Five sparse lithic scatters comprise the total number of recorded sites within the Dale Lake ACEC. One site was surface collected by San Bernardino County Museum and has lost its integrity. Scientific values of remaining sites are marginal. No cultural resources are recorded within the boundaries of the Kramer Hills ACEC. Response to 28-8 The condition of resources within the Yuha Desert Management Plan area has stabilized through a series of actions initiated by the 1985 Yuha Desert Management Plan. We acknowledged in that plan that existing measures enacted since 1980 had been insufficient to prevent a deterioration of resources. Some of the actions instituted to reverse the downward trend include increased patrol, better signing, closing of some routes, limiting competitive racing, and prohibiting camping in certain areas, In addition, race courses have been rehabilitated and access guides have been published. Some impacts still occur because of the visitor load, but the overall trend is stabilizing. Response to 28-9 The map for Amendment 9 in the EA includes the Gordon's Well area in the proposed change from "M" to "L". The map is in error and should have excluded the Gordon's Well area (Sec 31, T.16S., R.20E., SBM). This correction has been made in the final map. Response to 28-10 The Gordon's Well area is within the East Mesa ACEC and is a Class "M" area. A Class "I" open area exists east of Gordon's Well and is not a part of the proposed amendment, but the area is often referred to as Gordon's Well or East Mesa. The recreation description for Amendment 9 incorrectly referred to OHV play in the adjacent open area as occurring in East Mesa. The camping and use on private lands adjacent to the ACEC may have also been referred to as "OHV play" in East Mesa. The CDCA Plan permits camping within 300 feet of approved routes of travel. The Southern East Mesa ACEC and the EAst Mesa wildlife Habitat Management Plan do not limit the area of camping in Section 31. Inventories found very little evidence of the Rat-tailed Horned Lizard in this parcel. The camping referred to occurs on or adjacent to an approved route of travel and is also within the Bureau of Reclamation's withdrawn 2000 foot-wide right-of-way for the Coachella Canal. 131 Response to Sierra Club, Judith Anderson Response to 28-11 A variety of factors could affect the flat-tailed horned lizard (FTHL). Monitoring studies are continuing with the hope of determining the specific causes of both positive and negative effects. There is little evidence of the presence of the FTHL in the Gordon's Well area, and a trend of decline within the FTHL habitat for the East Mesa. Therefore, charges that off-road vehicles are the principal cause of endangering the FTHL in an area where declines have not been proven is merely speculation. The CDCA Plan, as amended, is not the only way to protect the habitat of the FTHL. The BLM is pursuing a variety of approaches in the East Mesa ACEC. On July 27, 1989, important FTHL habitat on the east side of the ACEC was closed to all camping. The closure removes the main attraction for recreational use of the East Mesa ACEC and is designed to prevent overflow camping from extending into important habitat. Response to 28-12 See responses to 5a- 1, 6-1, 13-2 132 29-1 29 29-2 29-3 PATRICE DAVISON FIELD REPRESENTATIVE P.O. Box 2151, Riverside, CA 92516 August 21, 1989 Mr, Gerald Hillier Manager, BLM Desert District 1695 Spruce Street Riverside, Ca. Re: Comments on proposed 1988 Desert Plan Amendments Dear Mr. Hillier: These comments reflect the concerns of the California Association of Four Wheel Drive Clubs. In general, the Association has great difficulty accepting proposals for increasing the number of ACECs, when there is no new outstanding information warranting such designation. Comments are referenced by Amendment number: Amendment 1 - None of the reasons provided are justification for this additional ACEC. The description accompanying the proposal clearly points to a lack of adequate consideration of alternatives. The Bureau's compulsion to automatically designate an ACEC where potential for controversy or problem exists is an easy way out that neglects the public and ignores the resource. If public visitation is a problem, it would seem more appropriate to stop the current practice (of Barstow BLM personnel) of intentionally directing people to the area. If one were to speculate, it would seem as if this was merely an initial step in the process to close the area to public enjoyment and appreciation. The case has not been made for this designation, and the proposal must be rejected. Amendment 2 - Please refer to the High Desert Multiple Use Coalition's extensive comments on this matter. Once again, it would appear that the automatic reaction is to close (via ACEC) where possible, even when the circumstances do not warrant such. Amendment 3 - Again refer to HDMUC comments. If this area warrants ACEC designation, than perhaps the majority of the California Desert should also be proposed for ACEC status. The case for ACEC designation must be solid and appropriate. Amendment 4 - Better definition of paleontolgical values does not warrant enlargement of this ACEC. Reject this proposal. Amendments 5,6,7 - Support the deletions. 133 Amendment 8 - Strongly oppose. The existing BLM management efforts are satisfactory, no proven need to change. Why eliminate what is working ? 29-4 29-5 29-6 [Ami Amendment 9 - Strongly oppose because this change will result in Increased limitations on vehicle access. 29-7 2^8 Amendment 10 - Oppose in part. If Alternative B was proposed, excluding Mescal and Cinder mine areas, would be acceptable. The degree of mining in the area suggests that some modification to the amendment is necessary. Amendment 11 - In our best judgement. Alternative C is the best recommendation. The popular area should be enlarged as much as possible to counteract the restrictive actions occurring elsewhere. The BLM must provide for the displaced user. Amendment 12 - Support Amendment 16 - Strongly oppose the closure to motorized use. The validity of this area as an ACEC has been questionable from the start. This proposal is an example of how ACEC designation is used as a step in the process to close an area to public use. Although sometimes measured and incremental, the end result is the same. This area, if closed, would restrict the legitimate access for other areas as well. Amendment 17 - Same comment as 16 with the addition that the question of managability must be examined. ACEC designation should not mean closure of motorized access. Routes must be available for public use. Management by closure is a sad commentary on the Bureau's abilities, and decreases the public confidence. It is the desire of this Association that the foregoing comments serve as a means to facilitate some future communication regarding the proposals. Richard MacPherson is the key contact and can be reached through my office, or you may call him (714) 682-6924 at home to set up an appointment. Thank you very Plan Amendments. much for this opportunity to comment on the 1988 Sincerely, f^^C^^ Patrice Davison Field Representative California Association of Four Wheel Drive Clubs PO Box 2151, Riverside, Ca. 92516 (714) 369-8960 134 Response to Patrice Davison, CA Assn. 4-WD Clubs Response to 29-1 Cultural resources within the proposed ACEC are listed on the National Register of Historic Places. Executive Order 11593 requires federal agencies to administer and maintain properties so that archaeologically significant sites are preserved, restored and maintained (16 U.S.C. 433.2.b.4 1982). The National Historic Preservation Act, Section 10, requires federal agancies to locate, inventory, and nominate to the Secretary of Interior all properties und er its control that appear to qualify for inclusion on the National Register and exercise caution so that historic properties are not allowed to deteriorate significantly. Cultural resources within the proposed ACEC have been vandalized and subjected to other impacts. Designation of this area as an ACEC will provide the BLM with the mechanism to give this area special management to prevent continued impacts. It will also facilitate development of a program to educate the public in the appreciation and enjoyment of the cultural resources in this area of the California Desert. Response to 29-2: See response to 22-1. Response to 29-3: See response to 22-5. Response to 29-4 A change in MUC from Class "M" to Class "L" will not increase limitations on vehicle access on the East Mesa. The vehicle access designation in this area is "limited." Existing routes have already been designated "open" or "closed" in the route designation process. In addition, the area of moderate-to-heavy use around Gordon's Well and east of the Old Coachella Canal has been specifically excluded from the MUC change. Response to 29-5 The difference between the MUC guidelines for mining in Classes "M" and "L" is that a plan of operations is required in Class "L" for operation on areas of 5 acres or less. The effect of this change in the Mescal Range would be negligible, since almost all mining operations are larger than 5 acres and already require a plan of operations. Response to 29-6 Alternative C was rejected as it could have negative effects on the Amargosa River and, potentially, on Death Valley National Monument. Response to 29-7 and 29-8 Both ACEC plans had previously closed these areas to vehicles. The proposed amendments merely provide additional documentation of the decision. In addition, neither ACEC contains a designated route of travel. Consequently, no reduction of authorized 4-WD use will occur. 135 HIGH DESERT MULTIPLE-USE COALITION P.O. BOX 1167. RIDGECREST. CA 93555 Mr. Gerald E. Hillier District Manager California Desert District Bureau of Land Management 1695 Spruce Street Riverside. California 92507 August 18, 1939 30 Re: Proposed 1988 Amendments to the 1980 CDCA Plan Dear Mr. Hillier: Please consider our comments on the following proposed amendments ; 1) Rodman Mountains proposed ACEC 30-1 We supp designs tion . be impl ement signing , cam mcrea.'i e use expend the e Rather than forth, the b who is allow return for f ort Altern We are c ed under t Pg round de of the ar ffort nece increasing e.st pro tec ed by the unctioning ative A, that this area deserves ACEC oncerned that the intensive management to his Alternative could, however, involve velopment, etc., which could actually ea by persons who do not, at this time, ssary to find areas of such cultural value. patrols, displaying regulations and so tion for such resources might be a resident BLM to live on site on a rent free basis in as site caretaker and interpreter. Red Rock Canvon . proposed ACEC This am impact on bo High Desert area. We no habit, Sit. We as in Nightm in the subje presence and. observation Speci-Etl atte the uses of The area is overgrazing , problem" in Harris, BLM endment is bei tany and wildl Multiple-Use C ted that the a .stopped to ob are Gulch, at ct area. He w never left hi and the subseq ntion was paid man and the pr a part of the or anything e the area and m Range Conserva ng proposed for its desired positive ife (p. S-3). Several members of the oalition (HDMUC) recently visited this rea is indeed outstanding raptor serve a great-horned owl perched above this time the only usable vehicle route as relatively unconcerned with our s perch throughout 10 minutes of uent passage of our three vehicles. to the effects upon the environment of ocesses of nature during our visit. Cantil commom alottment but Ise livestock-related, is a "non- ay be confirmed as such by Mr. Glenn tionist, Ridgecrest Resource Area. 136 30-3 There are nine mining claims in the area, none of which are active, and, no plans or notices of intent to open new mines have been filed as of the date of these comments. We could not find any recent evidence of abuse of resources by prospectors or any other human visitors and, with the restraints placed upon vehicle travel by natural barriers and regulatory agency policies, we found that there is no proliferation, whatsoever, of vehicle routes . We also visited the si a short distance from Night cannot be found except by o foot trail, where it exists is steep and slippery in pi 20 feet across its widest d represent anything recogniz because of its rarity in th compared to other Southwest particular danger and is no at this time other than tha intentional omission of any managing agencies. te of the geoglyph or intaglio. It is mare Gulch but the hiking route to it ne who already knows the way. The , is only barely visible and the way aces. The intaglio is small, perhaps imension, and does not obviously able. While somewhat significant e locale, it is not impressive when desert sites. We believe it is in no t deserving of any special protection t which would be afforded by an publicity efforts on the part of the 30-2 It is unclear to us why this area needs ACEC designation. The Nightmare Gulch route is already closed to all human visitation from February 1 to July 1 each year for the protection of raptors during their nesting season. The timing of this closure also benefits desert tortoises, who are most active outside their burrows from March 1 through June 30, according to Desert Tortoise Natural Area literature. The Nightmare Gulch- Black Rock Canyon Loop is the only passable route through the area at present. As a note, the map of this area in the back of the Proposed Amendments book doesn't show this complete route but it does show routes that are impassable and effectively no longer exist. The Loop route is additionally closed to vehicles for one-half of each of the other --even months of the year (open only for non-motorized travel duri^i Lne other half of each of those jraonths ) . While it is stated on page 3-2 that the nojave ground squirrel may occur in portions of this area, this has not been positively documented. As for endangered plants, the only serious danger here is from the "scouring" effects of heavy, localized rainfall. Such runoff frequently makes dramatic changes to features in the canyon bottoms but the native plants evolved under these conditions. By the way, when repairs to the abovementioned Loop are necessary to maintain passability from one year to the next, this maintenance is performed by the Geargrinders 4WD Club of Ridgecrest via a Cooperative Management Agreement (CMA) between themselves, the ELM and State Parks, signed 3/22/85. The cost to the public for this, being only for the required supplies and materials, is minimal. We understand that the ELM is able to gain additional funds for the management of an area if the area can be declared an ACEC. We don't believe 137 that this is ethical, however, unless the environmental concerns of an area can stand on their own merits, i.e. , simply saying that an area needs more protection does not make it so. In summary, we find nothing deserving "critical concern" in this area, we believe this amendment is unnecessary and, we urge you to reject it (Alternative B) . 30-4 30-5 30-6 3) Dedeckera Canvon (Eureka-Saline Corridor), proposed ACEC This amendment looks like a prelude to some kind of closure of the public road through this area which is most widely known as the Eureka-Saline Corridor. This is the only road in the area and the only vehicular route between the Eureka and Saline Valleys. From page 4-3 of the Proposed Amendments, we quote, "the open route could be a potential threat to adjacent resources." And, "any proliferation of the Eureka-Saline Corridor or irresponsible activities by users of the route could have detrimental effects on sensitive plant species in the amendment area." However, on page 3-4, it is stated, "Very little, if any, trail proliferation has occured." Apparently, protection for the sensitive plant species July gold is the only reason this amendment is being proposed. These questions come to mind: In an area as undeveloped and far-removed from population centers as this, does the sensitive plant species July gold not have adequate habitat in many other _canyons in the Last Chance Range to assure its healthy survival? How would "the activities of users of the Eureka-Saline Corridor" be controlled if the road is to remain open (p 4-4)? Since it is openly acknowledged that no proliferation of roads or trails has occured up until now, and there are no obvious indications that proliferation is about to occur, why make this area an ACEC? Similar logic would ban all off-highway driving anywhere in the desert for fear that someone might someday abuse resources. We believe that a Sierra Club group drove through the Corridor within the past year, camping out, hiking to the top of various desert peaks and generally looking for evidence of human abuse. They pronounced the area to be essentially free of same. Cultural resources in the area remain uninventoried and it would seem to be reverse logic to declare an area an ACEC so that an inventory could be facilitated so that something might be found that would justify the area's ACEC designation. It is stated that ACEC designation would not impact wildlife. The necessity of an ACEC designation for this area has not been adequately demonstrated. We urge the rejection of this amendment (Alternative B) now and until such time as an increase in use (and abuse) of this area is self-evident. 138 11) Dumont Dunes Usage Designation Changes We support Alternative B, the BLM-pref erred alternative. Addit iona 1 comments The Gear Grinders 4WD Club of Ridgecrest, an affiliate of the High Desert Multiple-Use Coalition, maintains the passability of three off -highway routes of travel in the California desert. Their efforts are acknowledged by the ELM to be valid volunteer public lands work. Two of those routes are in the areas that would be affected by Amendments 2 and 3. We hope that the CDCA amendment process does not become a vehicle for the carrying out of personal vendettas against either the Gear Grinders Club or individual members of that club. Thank you for allowing us to participate in the amendment process and for your consideration of our comments on the Proposed 1988 CDCA Plan Amendments. Sincerely, for the membership_of the High Desert Multiple-Use Coalition, Co-Chairman Copies to: -California State ELM Director Ed Hastey -California Desert Coalition 139 Response to High Desert Multiple-Use Coalition Response to 30-1 Management of the ACEC will involve signing, surveying, monitoring, patrol, enforcement, and if necessary, data recovery. The preservation and protection of cultural resources will be given the highest priority. No campground is planned, and specific identification of cultural sites will be avoided. Response to 30-2 See response to 22-1. Response to 30-3 See response to 26-1. Response to 30-4 See responses to 14-2, 22-3, 22-4. Response to 30-5 Although other small populations of Dedeckera eurekensis have been found in this region, the range is so small that each population needs protection. Response to 30-6 See response to 22-5. 140 SSi=Ao3 Buereau of Land Managemen t" - f A - ^fr California Desert District Attn: Mr Gerald Hillier, Di;S;tirlQt?*lai!iMg2^r27 1695 Spruce Street Riversidet CA 92507 C . . . -.-Jr.; = JJIi^iCT August 21, 1989 31 Dear Mr. Hi 1 i lert I appreciate this opportunity to submit comments regarding "Proposed 1988 Plan Amendments to the California De' Conservation Area Plan of 1980"» Please add my name to distribution list concerning future proposed amendments, records of decision or any similar material open for public input. Amendment 1* New ACEC at Rodman Mountains Cultural Area 31-1 On page 2 Subm 1 ss 1 o special m designati designat i without substant i I support signing s patrol s c plan can the use o pamph lets appropria -2f under n" f it IS anagement on. How on general p er man en t ally unnot alter nat i hou 1 d be d an be unde be imp 1 e f pamph let could te Resourc the column entitled, "Proponent's Reason for stated that the ACEC designition would provide over and above that provided by a wilderness will this be accomplished since a wilderness ly refers to those areas untrammeled by man, improvements or the imprint of man's work is iceab 1 e'' ve A, accepting this amendment. However, no one until sufficient monitoring and enforcement rtaken. Until the complete ACEC management mented, education could be accomplished through s containing interpretive information. These be made available upon request from the e Area Off ices. 31-2 Amendment 2S New ACEC Adjacent to Red Rock Canyon This proposed ACEC is already regulated by numerous overlapping management tools. Last year's plan amendments changed the proposed ACEC area to Class L. Approximately 90% of the proposed ACEC IS already covered by the raptor seasonal (Closure from February 1 to July 1 annually. The Memorandum of Understanding (MOU) with Red Rock Canyon State Park (RRCSP) and the BLM allows vehicle access in the proposed ACEC only from the 16th of each month to the end of each month. These multiple layers of control result in eliminating all public entry to 90% of the proposed ACEC for 150 days per year, while vehicle access to this same area is not allowed on 255 days out of the year. Wildlife concerns mentioned that were not specifically addres by the closure and MOU, are the desert tortoise and the Moj ground squirrel. ssed ave Page 1 141 According to the BLM brochure entitled "Desert Tortoise Natural Area"t the statement is made^ "From mid-June through February^ most tortoises are usually deep in their burrows and are seldom seen." Additionally, the draft management plan for the Crucial Desert Tortoise Habitat in Fremont Valley and Surrounding Areas, April 89, suggests under management r ecomendat ions, Sec. 111(D)(3)(a) designating a seasonal competitive and permitted ORV event closure during tortoise emergence (March 1 to June 30). Therefore, under the current area management, protection is already afforded the desert tortoise by the raptor seasonal closure dates and the additional vehicle restrictions under the MOU. 31-3 The statement that the Mojave ground squirrel may occur in portions of the affected area, indicates that there is insufficient data to raise it as an issue. However, the same protection that the desert tortoise enjoys from humans and vehicles applies to the Mojave ground squirrel. Unfortunately for the Mojave ground squirrel, there isn't any protection from the nesting raptors looking to feed their young. Addressing the sensitive and listed plant concerns. Grazing animals and mineral exploration would definitely pose a threat to these plants and needs to be addressed. The Red Rock tarweed that grows in the moist canyon bottoms, is protected from human and vehicle impacts for part of winter, through spring and into summer. Seasonal run-off rearranges these canyon bottoms extensively in this area, sometimes taking it down to the underlying rock. This must have an even greater negative impact on these relicit plants than do man and vehicles. ated that there are four posed ACEC, I assume ccompanying map with the ess Guide #7, printed Se awbone/Dove Springs Dese two routes. The Red Roc two routes. I went d ound there are only sed ACEC, one through Bl ugh part of Nightmare ut of the gulch as EP-12 ce has incorrectly bl he Nightmare Gulch route notify them of this e opened. Upon acquirin ement Agreements (CMA) e was a CMA between the (GG). This CMA states or keeping the the appro Nightmare Gulch' loop ro also states that the s current primitive cond Is are to be used. Thi e proposal. Incidentall ciety CMA (for entering Page 2 des ignate these are proposal . pt. 1988 rt Access k Canyon own and ma two des ig ackrock Ca Gu Ich, 0. If for ocked off isn't sho fact so g copies o concerni ng BLM, RRCSP that th ximateiy 6 ad passabl route wou 1 1 1 on Wit s CMA was y, the map the area d d OHV the The shows Gu i de State de an nat ed nyon, route some the wn on the f the the , and e GG mile e for Id be h no nev er that ur 1 ng 142 ylthe seasonal closure to monitor nesting birds and sensitive plants) IS excellent. I wish their CMA map had accompanied the proposal since they are the proponents of this amendment. The archeological site record, CA-KER-244, 12/87, for the geoglyph/i ntagl lo in question states that the Park rangers were mainly concerned that the intaglio might be altered by Geology field class pedestrian traffic. This intaglio is not visible from the vehicle route, and requires a slippery, sandstone climb to reach. Its actual location not being well known to the general public protects it from the casual visitor. Summarizing, I support alternative A, accepting this amendment, to protect the area from grazing pressures and mineral exploration. However, I would suggest adjusting the ACEC boundary to coincide with the annual seasonal closure boundary since it is easily identified and will provide an open route to the area north of the proposed ACEC area. No additional vehicle/human use closures or route restrictions should be added since the existing management restrictions are completely sufficient. 31-4 Amendment 3* New ACEC at Dedeckera Canyon First of all, I wasn't able to find Dedeckera Canyon on any of my USGS maps, BLM maps, AAA maps, DeLorme Atlas Gazetteer, etc. Next time, please put some common name, le. Eureka Valley Dunes in paranthesis somewhere in the name. This naming convention would allow the relative location of the amendment area to be easily identified within the CDCA 31-5 On pag Submi s ACEC p Dedeck 1 1 sta the pi page 3 that the he tra i 1 plant concer straig propos wi thou e 2-2, und sion " , it rov 1 de hab era eureke tes that t ant's hab 1 -4 the rou IS bordere ad 1 ng of r prolifera species Ju n for Ju ht- line di ed ACEC t vehicle er th is st 1 tats nsi s. he Eu tat. te IS d by ecr ea t ion ly go ly go stanc of J acces e CO ated for On r eka I a des stee t ion has Id i Id 1 e f r ust s to 1 umn tha un i pag -Sal ssum crib P t s s om ca it oc mi r e t ove the ent 1 t the que p e 4-3 1 ne C e thi ed as ny on IS s cur re n imal su 1 1 1 he Eu r two cor r tied dol lant , un or r 1 s ac gen wail tate dt fro ng f r eka mil 1 dor , "Pro omi te c assemb der wi 1 dor pas tuai ly e ra 1 1 y s. Aga d that ther ef o m vehic r om h ik Dunes es will ponent liffs lages, dlif e ses d 1 means follow in on very 1 re th les. ers, t picnic be a 's R of th 1 nc 1 and V recti be low i ng a page ittle e imp If ho hen a are probl eason e prop ud i ng ege tat y thr , sine dry 3-4, u f if act to we ver , pprox 1 a to em wit for osed the ion, ough e on wash nd er any the the mate the h or On page 4-3 it is stated that the open route could be a potential threat to adjacent resources. In what regard does a single, route threaten the adjacent resources since little or no trail proliferation has occurred. On the other hand, the route provides access to the wildlife guzzler for periodic maintenance. I support alternative B, reject the amendment. This amendment is unnecessary since the proposed ACEC is already closed to vehicular access (except for the one route F-1794, covered under a CMA to be Page 3 143 ma 1 n ta i ned managed as as a Class primitive L under 4WD the route)t and is currently being managea as uiass l unaer T^ne Interim Management. Policy and Guidlines (IMP)* Vehicular or human use in the canyon hasn't been shown to be a significant problem* 31-6 If it should be decided to accept alternative Af I strongly urge that the corridor remain open* Its primitive nature^ the long summer heat and the remoteness of the location all effectively control the human use of the corridor for nearly half of the year* 31-7 Amendment 48 Enlarge Coyote Mountains ACEC (No. b,2) This amendment seems unnecessary since the ACEC is currently managed Class L, is closed to OHV use> and lies within a WSA recommended nonsuitable for wilderness designation* However^ if it IS felt that the ACEC is necessary for protection of the fossil resourcet then I support alternative At accept the amendment^ with one suggestion for the amendment plan* Please set aside a reasonable size area, designated for hobby fossil collecting. Amendments 5^ bf 7! Deletion of ACECs (No* 28, 38 and 51) I support alternatives A, accept all of these amendments. Amendments 8 9* 31-8 changing specified area "M" to "L" Class designation from I suport alternatives A, accept amendment in both cases for the specific purpose of preventing the lands from being used for disposal sights, as well as protecting the mentioned cultural resources* However, I suggest that as stated in both amendment environmental consequence sections, that the changes in multiple use class should have little negative effect on current recreation uses* Amendment lOS Change Class "M" areas to Class Mojave Scenic Area "L" in the East I support alternative A, accept amendment* The Mojave Road and the East Mojave Heritage Trail should be protected from stated few road closures mentioned in the Environmental Consequences section* Also, care must be taken when making the Class L boundaries so as not to include probable rare earth deposits* Page 4 144 Amtndmant lit Change to Class "I" and Vehicle Access to "Open" for Area Adjacent to Dumont Dunes OHV Area I support alternative A, accept amendment. Amendinent 12* Change Portion of Ivanpah Lake from Class "L" to Class "M" I support alternative B^ reject amendment. Amendment 13f 14» 152 Eliminate Utility Corridors and Portions of Cor r 1 dors. I support alternatives Af accept all these amendmentst with the following st ipu lat ions J Regarding amendment 14^ maintain the Mojave Road where it currently exists. Regarding amendment 15» include the segments of the corridor road as proposed to the East Mojave Heritage Trail. However^ formal maintenance the road would no longer be necessary, and could be handled under a CMA. 31-9 Amendment 16 17S Change Vehicle Access from "Limited" to "Closed" in ACEC areas (No. 57 55) I support alternatives At accept amendments. However, I don't understand the necessity of this vehicle access change, since the applicable ACEC plans previously closed the same areas to motorized vehicles. Amendment 18* Prohibit grazing South of I nterstate- 10 in the Ford Dry Lake Allotment I support alternative A, accept amendment. Amendment 19X New Ephemeral Grazing Allotment Near Daggett I support alternative C, reject amendment. Again, thank you for this opportunity to comment concerning these ammendme n ts. Page 5 145 Sincerely Wayn e Re 1 1 ig /^LJLofjLfoiJit , C A 93SJSS Response to Wayne Rettig Response to 31-1 A cultural ACEC is specifically managed for its cultural values as compatible with wilderness values and could have more stringent management than a wilderness area. Response to 31-2 See response to 22-1. Response to 31-3 See response to 22-2. Response to 31-4 The Plan Index Map (p. 1-2 in the E.A.) gives the general location of each amendment proposal. The map for Amendment Three in the Appendix shows that Dedeckera Canyon is close to the Eureka Dunes and at the north end of the Eureka/Saline Corridor (Route F-1794). The Canyon has been labeled on the final map in this document. Response to 31-5 See response to 22-5. Response to 31-6 See response to 14-2 and 22-3. Response to 31-7 Fossil Canyon or Alverson Canyon, located at the southern end of the Coyote Mountains, is still available for fossil collection. Response to 31-8 The class change will not have an appreciable effect on recreation use within either area. Response to 31-9 See response to 29-7 and 29-8. 146 ^€t^A 03Z THE CAIIFORNIA NATIVE PIANT SOCIETY DEDICATED TO THE PRESERVATION OF CALIFORNIA NATIVE FLORA 24001 Martin Road Carmel Valley, CA 93924 August 19, 1989 California Desert Office, BLM 1695 Spruce Street Riverside, CA 92507 ATTN Plan Amendments 32 Gentlemen , The California Native Plant Society supports all 19 of the proposed amendments to the Desert Plan. We especially give strong support to Amendment No. 4 which would make Dedeckera Canyon an Area of Critical Environmental Concern (ACEC). Dede plan whic extr dolo ther Even Stan is a Dede The part here cker ts, h ha emel mite e wo wit d up Irea cker pres ial a Cany mostly ve not y rare cliff uld be hout c to in dy sta a Cany ent de protec on IS ende yet Dede a t mics been cker reasu Th inve a eur re t ere stig eken rove o are al ated . sis ( " s , wo noth a m p f i nocen te-li on ma signa tion uld ing res t re sted y he tion for be a but r the f creat as r Ip pr of W the u temp are ragi iona are , even ilde niqu ting p shrubs le veg 1 impa and i t a ne rness e na tu f rare so arc The t July G lace t to bu etatio ct . D ncreas ed for Study ral he and rel haeologi ype loca old"), s o camp . rn for c n cannot edeckera ed prote federal Area pro ritage r ati ve cal s lity urrou Howe ampf i for eure ly rare ites of the nded by ver , res . long kensis ction list vides epres m ing . only ented Dedeckera Canyon is worthy of ACEC status if any place ever was Thank you for your consideration. .. r CO " t: Osl ,""•. f €V> ■: 1. ■ 3!: O'S '"l- CO ■ -t. OJ ■. rO J 1 ' f.» ■■■JS » •-j ♦4.,"; ' -s — Sp.ncerely , / i ; // Ml Suaaniie Schejttler Presijoent 147 APPENDICES APPENDIX A -RESPONSE TO U. S.D.I,, BUREAU OF RECLAMATION IJnited States Depaitment of the Interior BUREAU OF LAND MANAGEMENT CALIFORNiA DESERT DISTRICT 1695 Spruce Street Riverside, California 92507 TAXE PIdDEIN, AMERICA IN RFPLY REFER TO: 1600 CA-067.21 ) Memorandum To : Regional Environmental Officer, Bureau of Reclamation, Lower Colorado Regional Office, P. O. Box 427, Boulder City, Nv 89005 From Subject District Manager, California Desert Proposed 1988 Plan Amendments/Class Change in the East Mesa, Imperial County The change from Class M to Class L, in and of itself, will not affect your proposed recharge project in the East Mesa. An environmental assessment of the proposed project would be required in either Class. However, the Class L designation highlights the potential resource conflicts and insures higher management priority and attention. The proposed Class L designation will more accurately portray potential resource conflicts in East Mesa. Since implementation of the Desert Plan a large amount of new inventories have been conducted to determine the extent of wildlife and cultural resources in the area. The results indicate that these resources occur over a larger area, and in greater density than originally thought. There are four wildlife species of special management concern known to occur in the East Mesa: the Flat-tailed horned lizard, the Colorado Desert fringe-toed lizard, the Yuma clapper rail, and the California black rail. The Yuma clapper rail is a State threatened and Federally-listed endangered species. The Flat-tailed horned lizard is a BLM sensitive species and was recently upgraded from a Category 2 to a Category I candidate for listing by U. S. Fish and Wildlife Service as threatened or endangered. We have enclosed a copy of our recent status report for this species. The California black rail and the Colorado Desert fringe-toed lizard are Category 2 candidates for U. S. Fish and Wildlife Service listing. — lake. fixLaa in uoui (^aLLjoxnia -L^£i.£xt (^oniEiuation cTTXEa . . cyy cyVatLonaL _'T£aiaT£. 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