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calamaridog
04-28-2005, 05:14 PM
Date: April 21, 2005

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EDITORIAL by Brian Hawthorne, BRC Public Lands Director (April 21) -- Largely in response to the organized OHV community's outrage upon unfair application of the Special Recreation Permit (SRP) policy, the Bureau of Land Management (BLM) recently issued an Instruction Memo (IM) modifying their previous policy.

Beginning early in 2004, the BlueRibbon Coalition, the American Motorcyclists Association, the United Four Wheel Drive Associations and others, contacted the BLM to express serious concern regarding application of the BLM's new SRP policy. The BLM's new Instruction Memo takes significant steps toward implementing solutions BRC and other OHV groups had suggested.

Several of the more outrageous abuses were featured in the July 2004 issue of BRC's Magazine (New Regulations Put Pressure on OHV Clubs, July 2004, pg 10-13). For those of you who missed it, the article is available on BRC's website www.share trails.org under our archive link for the BlueRibbon Magazine.

Typically, and tragically, situations where permits were required for motorized groups, but nt required for non-motorized groups, were common throughout the agency. BLM's Washington Office agreed that such unfair and arbitrary application of agency regulations could not be tolerated. Thanks in large part to our efforts, the BLM's Instruction Memo takes steps to modify the policy, and bring balance to the recreation permit system.

During a recent trip to Washington D.C., I had an opportunity to speak with Bob Ratcliffe, Deputy Manager of the National Recreation Program in BLM's Washington Office. Ratcliffe said problems with the SRP policy had been brought to the attention of staff at BLM's National Recreation Program, as well as BLM National Director Kathleen Clarke. Director Clarke was concerned that abuses of the new permit regulations could have an unfair and negative effect on small, non-profit clubs and organizations. Ratcliffe said the agency realizes the importance of organized recreational clubs in assisting with recreation management. Director Clarke was quite concerned that the BLM's relationship with the "mom and pop" clubs might be at risk.

BLM's Instruction Memo cautions individual Field Offices that the SRP process is not for prohibiting, or severely restricting, activities that would normally be allowed (such as OHV recreation). The Memo states that recreation permits must serve the public interest, and support the goals and objectives of land use plans. The new guidance encourages individual Field Offices to incorporate SRP policy with land use plans and states that it is imperative that areas which will have restrictions on users, (i.e., numbers, season of use, location, group size or other conditions that limit the user) be identified and quantified during the Resource Management Plan (RMP) process. Those kinds of recreation management decisions are to be made via the planning process, which is made with full public involvement, and not through application of the recreation permit policy.

Another important change deals with how BLM recovers costs for environmental analysis and other services charged to permit holders. These changes should reduce or eliminate environmental analysis fees for non profit club trail rides. The Washington Office is also encouraging Letters of Agreement instead of permits where organized groups may be accommodated with a minimum of inconvenience. Finally, BLM has attempted to clarify the regulations that refer to "paid public advertising" that put a simple notice in a club newsletter under the same category as, say, radio advertisements.

The nature of BLM management will only let us be cautiously optimistic about the changes. Clearly, the new IMs represent a significant improvement, and a sign of growing effectiveness on the part of the OHV community. However, because each individual Field Office operates much like a "fiefdom", they have a wide discretion on how they will implement the SRP policy. Thus BRC will be taking a 'wait and see' approach.

The agencies realize that volunteer efforts by OHV clubs are essential. Any recreation permit process must not be so cumbersome as to unfairly limit club's activities.

I want to acknowledge the work of BRC's member clubs and organizations that expressed concern to the BLM regarding recreation permits. The changes to SRP policy may not solve all our permitting problems, but without the involvement and action of our members, the situation would have likely festered and worsened. Once again this is a great example of how the T.E.A.M. (Together, Everyone Achieves More) concept works to benefit all.

-Brian Hawthorne