Protest/Appeal of Colorado River Valley BLM FRMP and FEIS

 April 3, 2014

This is another plan that tragically undervalues recreational usage and anytime other uses are balanced with recreational usage, recreational usage loses. Examples would be endangered species and cultural sites.  They apply the most restrictive standards possible for ESA and anything they think could be a cultural site now or in the future is subject to a mandatory closure.

Bureau Of Land Management Director (21 0)
ATT: Protest Coordinator
20M Street SE, RM 2134LM
Washington DC 20003

Protest/Appeal of Colorado River Valley BLM FRMP & FEIS

Dear Sirs:
Please accept this correspondence as the appeal of the entirety of the Colorado River Valley Field Office (“CRVO”) RMP and FIES (collectively referred to as “The Plan”) by the above Organizations. The Organizations are forced to appeal the plan in its entirety as many of the appeal points are foundational in nature and directly impact the balancing of resources in the Plan. These foundational analysis issues include failure to meaningfully analyze recreational economics, failure to apply accurate management documents for various species, failure to incorporate state planning documents addressing the importance of recreational usage of the planning area and the failure to inventory 89% of the planning area for cultural resources despite significant new regulations for all sites currently identified and those that maybe identified in the future being adopted. The Organizations vigorously assert these failures have directly resulted in the CRVO proposal that closes over 50% of multiple use recreational routes on the planning area. The Organizations vigorously assert these decisions are arbitrary and capricious as a matter of law and fact and are made in violation of numerous federal planning requirements.

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