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Richfield BLM Field Office:
In reviewing the alternatives in your Draft Resource Management Plan /Draft
Environmental Impact Statement (DRMP/DEIS); I feel that Alternative B is
acceptable, provided that some minor changes are made related to access
possibilities for personal, non-commercial rock and fossil collecting in the
Final RMP. Alternative A is preferable in allowing more open areas for such
collecting. I urge caution in selectively adopting portions of Alternatives C &
D in the Final RMP/EIS, and I have pinpointed several specific sections of those
alternatives that would adversely impact our hobby.
RECREATIONAL ROCKHOUNDING:
I noted in the DRMP/DEIS the following paragraph:
"3.4.6.3.5 OTHER MINERALS: Other mineral materials considered in
Mineral Potential Report include oyster shell, petrified wood, jasper,
agate, and chalcedony. Oyster shell from the Dakota Formation has been used
for road surfacing in Wayne County. There is also interest in oyster shell
for agricultural use. It is considered unlikely that the other mineral
materials considered will have development beyond hobby or casual use within
the next 15 years." (my emphasis)
Thus, hobby collecting of minerals by "Rockhounds" is recognized as a
legitimate pursuit. My wife and I are in our 70's, and she in particular is
unable to walk more than a very short distance from our truck to collect agate,
petrified wood, onyx, minerals, etc to make into jewelry in our "Rockhounding"
hobby. Surely, as suggested for camping and parking in your alternatives,
occasional travel off of designated routes to specific sites or deposits of
collectable materials can be accommodated, perhaps one-quarter mile for a
half day of collecting by individuals or organized Gem and Mineral
Societies?
AMATEUR PALEONTOLOGY:
In addition, I completely agree with the statement in Para. 4.3.6 “In this
manner, erosion is continually bringing new fossils to the surface even as it
destroys what is presently exposed.” However, as Dr. Jim Kirkland (Utah
State Paleontologist) will certainly agree, it is knowledgeable amateur
paleontologists like myself that bring to his attention many of the new fossil
finds in Utah. So the same recommendation regarding off road travel to
mineral collecting sites equally applies to paleontological sites.
Unfortunately, at the end of that same paragraph, you stated “By
definition, all vertebrate fossils are considered rare by BLM and impacts to
these types of fossils are of greatest concern.” (my emphasis) The marvelous
fish fossils (certainly vertebrate) of the Green River Formation in Wyoming near
Kemmerer are quarried in hundreds of tons each year on private and Wyoming State
leased lands. Hardly rare! I also noted that Table 3-13 (Vol I, p. 3-26)
“Geological Formations Present in the Planning Area” includes that same Green
River Formation in the western portion of the RFO. I urge in the Final RMP
you will keep that region available for myself and members of “Utah Friends of
Paleontology” to explore.
OFF-HIGHWAY TRAVEL:
My first concern is with regard to mineral collecting in the Clay Point
region south of the Henry Mountains. Alt. B Off-Highway designations on Map 2-14
and route designations shown on the CD Maps for “Notom Road” and “Hite” are
acceptable. (But Alt A (Map 2-13) is preferable in the Final RMP in
allowing more open areas for hobby mineral and invertebrate fossil collecting.)
Typical GPS coordinates for collecting sites in the Clay Point region
accessed from the Starr Springs camping area and the Notom Road/Burr Trail are:
- 37deg 41.75minN / 110deg44.78minW
- 37deg 44.11min N / 110deg52.81minW
- 37deg 46.50minN / 110deg44.27minW
There are numerous other GPS locations in the area, but these are typical for
finding agate, petrified wood, coprolite, and invertebrate fossils.
However, Alt C and D Off-Highway “Closed” designations for the Clay point
region on Map 2-15 and 2-16 and closed route designations shown on the CD Maps
for “Notom Road” and “Hite” are unacceptably restrictive. See:
- (T34S: R10E, R11E, R12E)
- (T35S: R9E, R10E, R11E, R12E)
- (T36S: R9E, R10E, R11E, R12E)
The Alt. D proposal even closes the road from Utah State Hwy 276 to Starr
Springs Campground, and the road from Starr Springs to the Notom/Burr Trail in
these same sections. BLM can rest assured of an RS2477 fight and probable
lawsuit if that alternative was adopted.
A second area of concern is in the “Last Chance” and “Mussentuchit”
localities in regard to hobby mineral collecting. Alt A (Map 2-13) Off-Highway
area is preferable in allowing more open areas for collecting. Alt. B
Off-Highway designations on Map 2-14 and the route designations shown on the CD
Map for “Fremont Junction” are also acceptable in the RFO portion, but we need
to be assured of continuation into the Price Field Office routes for the
Mussentuchit region, see:
- Richfield FO: T24S - R5E and T25S - R5E
- Price FO: T24S - R6E and T25S - R6E
Collecting sites at typical GPS coordinates in the Last Chance and
Mussentuchit region for multicolored Agate are:
- 38deg 45.909minN / 111deg19.092minW
- 38deg 39.18minN / 111deg16.84minW
There are numerous other GPS locations in the area, but these are typical for
finding agate and petrified wood.
However, Alt D Off-Highway “Closed” designations for the “Last Chance” region
on Map 2-16 and closed route designations shown on the CD Map for “Fremont
Junction” are unacceptably restrictive. Again see:
- Richfield FO: T24S - R5E and T25S - R5E
- Price FO: T24S - R6E and T25S - R6E
A third (there are many others) locality of concern in regard to
mineral collecting is near Salina. Alt A Off-Highway designation (Map 2-13) is
preferable in allowing more open areas for collecting. Alt. B Off-Highway
designations on Map 2-14 and the route designations shown on the CD Maps for
“Sevier River North” are also acceptable. My concerns are for collecting
sites at typical GPS coordinates in the Salina and Aurora region for “Salina
Blue Agate”:
- 38deg 59.23minN / 111deg57.78minW
- 38deg 59.41minN / 111deg57.85minW
There are numerous other GPS locations in the area, but these are typical for
finding agate and petrified wood.
However, Alt C and D Off-Highway “Closed” designations for the Salina /
Aurora region on Map 2-15 and 2-16 and closed route designations shown on the CD
Map for “Sevier River North” are unacceptably restrictive. See:
AREAS OF CRITICAL ENVIRONMENTAL CONCERN:
Alternative B (Map 2-43) provides all the reasonable ACECs needed in the
Final RMP. Alternatives C & D propose far too many marginal locations:
- Potential “Kingston Canyon” ACEC has a major highway running through its
length, historically occupied with ranching and farming lands, and the Utah
DWR is already doing a good job of managing the East Fork of the Sevier
River. Riparian protection can be managed within existing processes.
- Potential “Sevier Canyon” ACEC has a major highway and a paved bicycle
path running through its length, historically occupied with resort, ranching
and farming lands, and the Utah DWR is already doing a good job of managing
the Sevier River. Riparian protection can be managed within existing
processes.
- Potential “Rainbow Hills” ACEC has a major highway running along its
south edge, historically important for extraction of gypsum, and likely to
be explored for oil and gas.
- Potential “Special Status Species” ACEC seems to be a catchall for
anything the environmentalists missed in the rest of the potential ACECs,
and is obviously too expansive.
WILD AND SCENIC RIVERS:
Alternative B provides all the reasonable WSRs needed in the Final RMP.
Alternatives C& D propose far too many marginal locations and BLM’s
rational for not including them in Alt B is correct:
- Potential “Fremont River Below Capitol Reef NP to Caineville Ditch” WSR
has a major highway running through its length, and is historically occupied
with ranching and farming lands. It also is controlled by dams at Mill
Meadow and Johnson Reservoir; otherwise the river would be free-flowing only
when hit by a flash flood (an ephemeral stream). Riparian protection can be
managed within existing processes.
SPECIAL RECREATION MANAGEMENT AREAS:
Alternative B (Map 2-9 and Table 2-16) provides all the reasonable SRMAs needed
in the Final RMP. Alternatives C & D propose far too many marginal
locations, and BLM’s rational for not including them in Alt B is correct,
ERMA status is suitable.
- Potential “East Fork of the Sevier River” SRMA is an open sagebrush flat
surrounding the Otter Creek Reservoir. Current dispersed camping and OHV
travel is eminently practical and does not need a lot of “Management”.
- Potential “Sevier Canyon” SRMA has a major highway and a paved bicycle
path running through its length, and is historically occupied with resorts,
ranching and farming lands. The DWR is already doing a good job of managing
the Sevier River. Riparian protection can be managed within existing
processes. Non-motorized recreation opportunities are virtually
non-existent, except for seasonal river-running when there is enough water
released from Piute Reservoir.
- Organized group special recreation permits criteria on page 2-62
(Table 2-16 ) is appropriate, but the time limit for group occupation should
be extended to 6 hours to allow for half-day hobby collecting of minerals
in any one location.
NON-WSA LANDS WITH WILDERNESS CHARACTERISTICS:
BLM’s rational for not including Non-WSA lands in Alternative B is correct,
Alternative D proposes far too many marginal locations. As stated in para.
3.3.12, The Secretary of the Interior is certainly entitled to direct his
employees to inventory administered lands for any reasonable use; including
potential wilderness. However, even though Congress makes the final decision on
establishing Wilderness areas, the fact is that for all practical purposes
Wilderness Study areas (WSA) are being withdrawn from multiple use and managed
as if they were already established Wilderness Areas.
Alt. D proposes adding to this withdrawal from multiple use by mandating Non-WSA
lands with major restrictions, and effectively excludes my family and friends
from pursuing hobby collection of minerals and non-vertebrate fossils.
Specifically, I object to any inclusion in the Final RMP of “Bullfrog Creek” and
“Long Canyon” Non-WSA Lands (Map 3-9 and Table 3-20).
Furthermore, I find objectionable inclusion in the Final RMP of “Kingston
Ridge”, “Phonolite Hill”, “Rocky Ford”, and “Pole Canyon” Non-WSA Lands (Map 3-9
and Table 3-20). They do not possess the requisite wilderness
characteristics due to established historical development and use. These lands
are also flawed as discussed under ACECs and WSRs above.
OVERALL COMMENT:
The Richfield Field Office is to be congratulated on an exceptional job in
preparation of the DRMP/DEIS; especially Alternative B. From personal experience
in drafting similar documents for Aerospace contractors and Weber State
University, I know the amount of “Agony Units” required. I look forward to
seeing the Final RMP/EIS.
Sincerely,
(signed)
Evan E. Day
509 N. Highland Blvd.
Brigham City, UT 84302
Email:eday sisna.com
Member: Golden Spike Gem and Mineral Society (Ogden Utah), Timpanogos Gem and
Mineral Society (Provo, UT), Beehive Gem Society (Ogden UT), Utah Federation of
Mineralogical Societies, Rocky Mountain Federation of Mineralogical Societies,
Northwest Federation of Mineralogical Societies, American Federation of
Mineralogical Societies, Utah Friends of Paleontology.
EED File: EEDmisc/RCH RMP Comments Jan 14.doc
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