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RangeNet Project
Project SEORMP


Southeastern Oregon Resource Management Plan
A Review and Summary
by: Wilderness Care

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Observations, Comments, Suggestions, and Recommendations

Here are some observations, comments, suggestions, opinions and recommendations on the Bureau of Land Management's recently released Southeastern Oregon Resource Management Plan (SEORMP). The comments are not all inclusive as this is a very large document. It is important to review and make comments as this planning effort will guide management direction for at least the next 20 years on our public land (over 6 million acres, which are composed of some of the most magnificent places in eastern Oregon). It is important that BLM hear from us and our views. Remember to comment on both what you like and dislike. If there is an action in an Alternative you like, but it is not in the preferred Alternative, then tell BLM you want it included in the preferred Alternative.

BLM cannot ignore mass public opinion, unless inconsistent with the law, so please make comments. The more comments about specific topics from a bunch of people the better chances of convincing BLM to make changes, thus the reason for this summary.

The following material is not intended to guide your thoughts nor is it all inclusive, but rather are shown here as a general overview with some suggestions and changes. The result and idea are for you to take action and voice your opinion and perhaps share with others! Write your own letter in your own words.

You will observe that we have emphasized the protection of the values associated with special management areas throughout this review. That's because special management areas are the best and the last areas where outstanding natural values are found that are highly critical for careful and sensitive management applications. We cannot afford as a people and society to allow any more places with unique values to lose one bit more of their natural qualities.

Outside the general local communities found in southeastern Oregon, BLM has not apparently been receptive to addressing comments and suggestions except to a degree on Areas of Critical Environmental Concern (ACECs). However, your comments at this stage still count and can make a difference. To make your words heard stronger we suggest you send your comment letter to the chief of the BLM. Tell him you want to be heard this time regarding the SEORMP and after he reads your letter then for his office to forward it to the BLM in Burns or Vale in Oregon. Of course, you can always just send your letter directly to BLM in Burns or Vale or perhaps the Oregon State Office c/o the State Director in Portland Oregon.

Tom Fry, Acting Director
Bureau of Land Management
U.S. Department of the Interior
1849 C. St., Room 5660
Washington, D.C. 20240
Attn: State Director
Bureau of Land Management
P.O. Box 2965
Portland, OR 97208
Attn: Glen Patterson
Bureau of Land Management
HC 74 12533 Hwy 20 West
Hines, OR 97738
(541) 573-4400
Attn: Gary Cooper
Bureau of Land Management
100 Oregon Street
Vale, OR 97918
(541) 473-3144

The SEORMP is available at <>. The document is also available by print or electronically (a CD as we understand), contact Glenn Patterson or Gary Cooper as shown above.

You have until March 1, 1999 to make comments on this draft plan.

Table of Contents


General Comments

Goals and objectives found in this RMP are mixed together and are not appropriately or professionally addressed properly. This is important as goals and objectives define and guide actions. (Goals are generalized statements while Objectives are specific on how an action will be achieved). Please correct and adjust.

-Alternative E goes to far. Grazing and to some minor extent mining, are the big controversial issues in eastern Oregon. BLM, you went extremely overboard here Alternative E is inconsistent and is difficult to follow in any organized logic (it is not reasonable on any standard from any approach). Try again.

In many cases, it seems that the actions found in each Alternative are very similar to each other. The Alternatives are not distinct or diversified enough and do not show much of a difference from alternative to alternative except on "E". The proposed actions, or maybe lack of, do not adequately reflect the themes described for each Alternative. For instance, Alternative A is strongly commodity driven, but Alternative D does not go far enough in a reasonable manner to protect natural values.

Stating that the WSA IMP will be followed is not good enough. The IMP is a good document, but often lacks specifics on how to care for and properly protect wilderness values. There is a need to develop some specific definitive guidelines not now covered in the IMP to better safeguard against BLM actions.

BLM may well be the worst culprit in degrading wilderness values in Wilderness Study Areas (WSAs) than any other entity. Changes in WSA management is necessary and BLM needs help. As the U.S. Fish and Wildlife Service has jurisdiction over endangered species, as the State Historic Preservation Office (SHPO) has oversight on cultural and historic operations (both USFWS and SHPO are regulative agencies), and as the Council on Environmental Quality provides direction on how to carry out the National Environmental Policy Act (NEPA), something in the same lines to serve as a regulatory board or agency is needed for WSA and Wilderness Management oversight (maybe like the National Wilderness Preservation System [NWPS] Group, Board, or commission. We cannot trust BLM to do the right thing when it comes to proper WSA and Wilderness Management because the agency has other missions that far to often degrade or devalue wilderness values. The Burns District is a classic example of poor WSA management where livestock and recreation management/developments seem to be the first consideration in every situation and apparently overrides preserving wilderness values in WSAs. WSAs and wildernesses are national treasures and the last of their kind and need/deserve to be managed for their exceptional natural characteristics first and forehand. Proper WSA and Wilderness Management are more than an issue in the Burns and Vale Districts and probably the BLM as a whole is in need of revamping its wilderness/WSA programs.

Here's a non-specific RMP Comment - Under the Freedom of Information Act request that BLM submit to you the amount and type of projects and developments that have been placed in WSAs (both specific WSAs and as a whole) since they were originally inventoried. If BLM is honest I think you will be surprised just how many projects have been placed in WSAs. Be sure to also ask why the projects were constructed, were the projects placed to enhance wilderness values or were they placed to enlighten other programs such as to better accommodate for livestock grazing (placement of fences)! Have BLM also list types and amounts of developments that were originally inventoried so to provide a good comparison. Should be in better shape to challenge cumulative impact issues and to make a point on how badly BLM is managing our potential wildernesses that are under WSA status!

--Adaptive Management: An interesting concept and perhaps a good tool that allows flexibility, but BLM is asking us to trust an agency that in the past, and still remains today, has heavily favored the livestock industry (general commodities included). Perhaps someday BLM will have evolved to the point where we can trust their actions and adaptive management techniques applied without suspicions, but for now we need to see definitive management prescriptions.

Don't believe the document overall covers for future expectations well enough. Needs to be more pro-active, more futuristic based on current trends and projections. Too much status quo projected as being the same that would be occurring 20 years in the future. Status quo for being the same in 20 years is not realistic - change is never static.

--What we really need is somehow to protect the land from BLM actions. More damage is caused from the BLM than from the public. The BLM over extends its administrative privileges to the point of it being abusive. BLM, follow your own rules and regulations and adhere to the laws that were established to protect and preserve our public lands like us citizens are required to follow! This means in part to stop driving your extensive ATV fleet and large 4X4's in places that are closed or restricted to motorized vehicle use. Stop leaving behind junk like leftover fence material, culverts, and livestock watering troughs. BLM, just be responsible for your actions and lead by example!

Specific Comments Per Discipline

Energy & Mineral Resources:

--There should be no energy and mineral extraction within or immediately adjacent to any Special Management Area, where plants and animals are sensitive, threatened, or endangered, or at popular recreation places. Even if energy and mineral potential is presently low, you never know what may happen in the future. Restrictions should be applied that would completely protect values. The places mentioned above are far too important to allow any opportunity to threaten their values.

--Mineral and energy restrictions should continue in WSAs even if they are released, at least until another plan is developed. Rationale is; these places still have unique values and should continue to be protected until another clear course of action is taken on these lands. Mining and energy actions can destroy the values that made these places special in the first place.

--Stipulations to preserve Special Management Areas, unique plants and animals, and popular recreation locations do not go far enough to protect these places over the long run from potential mining and energy activities. Ensure that the places mentioned above are completely protected now and in the future from all possible actions that may cause degradation.


--Concerns with fighting fire in Special Management Areas. A bad situation occurred a couple of years ago in the Burns District in the Alvord Peak WSA. Bulldozers and tractors were used to plow control lines and plant seeds in the middle of nowhere. Property or life did not appear to be a factor! While sometimes emergency actions using mechanical equipment are necessary to protect human life and habitation, it should not generally occur. Bulldozers cause scars that often outlive wildfire affects. Guidelines should be established that help prevent destructive fire-fighting methods from occurring in Special Management Areas. BLM needs to be held responsible for protecting certain values even during emergency situations. The provision in safeguarding Special Management Areas in the plan does not go far enough and needs to be better defined and described or prescribed.

--Concerns with prescribed burns in Special Management Areas. Prescribed burning in Special Management Areas needs to be done for the right reasons. Develop criteria or guidelines to ensure the values in Special Management Areas are being perpetuated or improved. Natural burning usually occurred in the summer, not the fall when most agency burning is conducted. We are concerned that natural fire effects may be altered or changed by burning in the Fall as opposed in the Summer. Our concerns become more alarming where burning occurs in Special Management Areas. Would rather see wildfires in special places be allowed to burn naturally except of course where life or private property are immediately being threatened.

--Concerns with fire reclamation activities. Fire reclamation actions in Special Management Areas can and have degraded natural values. Stop using drills in these places and please ensure only native species naturally found in the area are planted. Develop criteria or guidelines for fire reclamation actions. If cheat grass or other weeds are a problem then stop or curtail the reasons why these undesirable species appeared in the first place (probably mostly due to extensive livestock grazing). Rest places that have been burned a minimum of ten years from livestock grazing. Arid lands simply take a longer time to recover and be healthy enough to handle livestock use.

Forest and Woodlands

--Prefer to see no timber production. The small amount of forested land found in the planning area is so light and in the more sensitive desert/forest transition zone that timber production is not environmentally appropriate and is just insignificant for cutting.

--Practicing forest health is good, but ensure that comprehensive ecological objectives are established then proceed in a manner that will achieve those objectives.

Water Resource & Riparian/Wetland Areas & Fish & Aquatic Habitat:

--Seems to be on the right track, but terribly complicated. In achieving the objectives be sure not to degrade Special Management Areas by placing projects in these unique areas, especially WSAs.

--Where Special Management Areas are present all waters should be at Proper Functioning Condition (PFC) where a natural ecological component or system is the bottom-line goal.

--BLM needs to work with ODFW to stop fish stocking in Wildhorse lake on Steens Mountain. This lake most likely never had fish and introducing alien species into a system historically void of fish will unfavorably alter the fragile ecological integrity of this fabulous natural high elevation lake.

Wildlife & Wildlife Habitat:

--Concerns that there is not enough forage for wildlife when factoring in grazing. To us, wildlife have a higher priority than livestock and forage should be allocated to wildlife first, then see if livestock can be tolerated. There is probably a balance that can occur, but it seems that the pendulum usually swings more favorably towards livestock. Wildlife in Special Management Areas are critically important, but please reserve placing developments in these places, especially WSAs.

--On Steens Mountain deer, and somewhat with elk, hunting seasons are terribly congested with people. We get concern for safety plus our recreation experience is lessened. Hunters have the same rights as us to be on Steens Mountain, but is there a way for BLM to work with ODFW to limit the tags and to restrict use on the many roads found on the mountain? Perhaps limit the tags issued and make it a quality hunt area where general recreation use and hunting can be made more compatible! Consider other places in the planning area that receive a lot of hunting to follow the above concept.

--Cross Country ATV use is increasing and is likely causing added stress to wildlife. See "Off Highway Vehicle" section for more information.

Wild Horses:

--Stop placing fencing in Herd Management Areas. Fencing interferes with the free roaming opportunities afforded to wild horses and is inconsistent with the Wild Horse and Burro Act because it impedes free movement. Find other methods to deal with livestock grazing problems other than with fencing in these horse herd areas.

--We agree that wild horses need managed, which means periodically being gathered, but we don't agree with the rationale that they are being removed to maintain a thriving ecological balance. If ecological balance is that big of a deal then why are there so many livestock on the range? We are not saying that ecological integrity is a bad management goal, on the contrary, it is a wonderful thought. However, don't attempt to use the term "ecological enhancement" until livestock are adequately and fairly addressed. Presently, livestock are a missing link in establishing a healthy ecological balance. It is not truly the horses causing something less than a thriving ecological balance, but rather in the case found in the planning area it's livestock.

Rangeland/Grazing Use

--Stop fencing Oregon and stop fencing me out especially in our back country areas. BLM, you are no longer just a grazing outfit.

Grazing is at the center of controversy and BLM has an opportunity to make some positive changes in this plan. While the proposed action is a small improvement, it does not properly address any potential solution and has short-comings for the life of this plan. The main reason grazing is occurring is to preserve a way of life and to a degree economic gains to local communities. Plus, livestock grazing is a large cultural custom in BLM (one of the problems). This being said, a theme could read "Sharing the Range" then change the objectives to read something like this:

Objective #1: Livestock grazing will be permitted on certain public land to maintain a ranching way of life and provide economic support to local communities in a manner that allows a sustainable ecological integrity of the land; must be consistent with the law, policy, standards, etc.; or by those areas stated in Objective #2 below; or should grazing privileges be relinquished by the private entity.

Objective #2: Where Special Management Areas, sensitive/threatened/endangered plants and animals, and popular recreation places, are found, livestock grazing/management may continue (as provided for by law). However, natural ecological conditions will be a priority and management conducted to achieve good conditions would be by a means that does not degrade, in any way, the values of these special places (as mentioned above). In other words, no to very few grazing projects (those projects allowed would be small and not noticeable, considered a rare event, and preferably temporary and then only to correct an immediate problem). This would mean that other livestock grazing management options would be sought such as reductions, longer and more rest periods, exclusions or permanently resting a grazing allotment, and change of seasons for use, etc.. The values of special places and creatures/plants should not be compromised because of the desire to graze livestock.

Based on the above new objectives, reconstruct the grazing section. The new objectives provide for an approach that allows for continued grazing, but better takes into account multiple land uses on our public land. If BLM insists on keeping their antiquated objectives then insist that grazing projects be kept out of Special Management Areas, especially in WSAs. We all want healthy ecological conditions on our public land and it has been shown that livestock grazing use can occur successfully, but it takes intensive management especially on arid land. When intense management means grazing projects need to be installed, this becomes unacceptable in potential wildernesses (WSAs). Many developments or projects (also referred to as range improvements) alter natural characteristics of the wilderness landscape and can have an adverse influence on primitive recreation opportunities (if it is a fence then it impedes or hinders free travel for people and wildlife).

Most ranchers are fine people with good intentions. There is a place for grazing, for Ranchers to continue their way of life, and local communities to gain their economic spin-off from the livestock industry. However, there are also areas where other values exist that may not be in harmony or even compatible with livestock grazing. All we are proposing is to share the public range in a manner that does not include all uses occurring in all places all the time. Determine what the dominate use is then primarily manage for that use. If it is a Special Management Area or place of unique or interesting value then the dominate use would be to preserve those values that made the place special. Perhaps grazing is compatible in Special Management Areas, but only if the values that made a place unique are not at all one bit compromised. We're not asking for the moon, just equality and fairness of how the land is managed.

--On Steens Mountain exclude livestock on more places. One such place should be Wildhorse Canyon in its entirety. It would be justified because of the high incompatibility between grazing and recreation use, scenic quality, pristine nature, and high riparian values. It can be done because it's public land. Thanks for excluding cows from Little Blitzen and the Indian gorges.

--In the RMP add the term "permanently rest a grazing allotment" as an option under adaptive and/or conventional livestock management. The above concept allows further flexibility and more options of how th manage grazing.


--Overall, all the recreation alternatives look about the same, would have been good to see more distinct differences between alternatives.

--Recreation growth projections are concerning; from around the present 400,000 visitors to over 1 million in 20 years. Like livestock (though not as wide-spread or generally not to the degree of degradation) people can have a profound impact to the land. However, people can be educated and regulated. In this planning effort ensure that a strong people education program is in place with emphasis on promoting land use ethics. In addition, there should be provisions in the plan to restrict or reduce certain types of visitor uses so that the natural integrity of the land is preserved and that high recreation experiences are continued.

--The destination places, as referred to in the plan, are places that initially should have specific prescriptions that preserve the land and provide for quality recreation experiences. Please develop specific prescriptions for SRMAs or high use site specific plans for known recreation locations in ERMAs.

--Actively manage ROS areas to maintain their classification. There are so few primitive areas available these days that these places become unique. Please manage primitive areas to protect their integrity and further, attempt to expand their size. Keep all vehicles out of primitive areas and only allow nonmotorized vehicles, like bicycles, in semiprimitive nonmotorized places. Manage all WSAs and Research Natural Areas with the primitive ROS classification.

Steens Mountain

--On Steens Mountain, it would be good to have some areas where there is a separation for types of recreation uses. Little Blitzen and Wildhorse canyons set aside just for hiking. All other places, where compatible or legal, could have all other uses occurring. Please don't allow over-use to occur in the magnificent gorges; regulate use if necessary in order to preserve the primitive integrity of these special places. Keep the trails in the gorges primitive. De-designate the gorges as portions of the Desert Trail System, it is okay to allow use in the canyons, but don't advertise or bring attention to them either. Allow people the opportunity to explore these areas on their own free will, which would give them a greater sense of discovery and maintain the wildness they now possess.

--Remove those intrusive interpretive signs on the mountain. It is good that BLM is educating people about the mountain, but many of these signs are out of place, out of character. Replace them with one brochure that would talk about each site that now has a sign.

--Hunting and general recreation use is at times conflicting and possess higher safety risks. Can BLM and ODFW work together better (see wildlife section for more on this subject) to reduce such high uses occurring on the mountain at the same time.

--Keep the road along the rooster comb area in its present condition, don't improve. It is nice not to be promoting use everywhere and sure enough good roads attract more people. Would be best if the area of the rooster comb road be closed, this area better serves for wilderness preservation where Little Blitzen Gorge and High Steens WSAs are connected to form one potential wilderness. The high values of wilderness preservation greatly outweighs all other uses in this particular area.

--Expand the Steens Mtns. Recreation Lands SRMA to include Page Springs, have the boundary follow the North Loop Road where it connects with the existing boundary, along Highway 205, following the South Loop Road until it meets up again with the existing SRMA boundary. This new boundary proposal would better cover the heart of the Recreation area for what that's worth! Or, just eliminate the SRMA designation. The term recreation lands serves to just attract more and more people plus the designation does not apparently mean anything.

--Provide for a day use area or small campground at the southern portion of Juniper Lake along the east side of Steens Mountain. The place is in need of some type of recreation management plus would be a good site to interpret the historic Alberson Stage Coach stop, wagon trails in the area, and cultural activities of Native American Indians associated with this area.

--Would like to see the vehicle road between the Riddle Brothers Ranch and the Nye place be designated a trail where full size 4X4 vehicles are excluded. Maybe call it the Steens Historic Trail!

--We like the idea that commercial outfitter's be required to be certified in Leave No Trace and Tread Lightly. Be sure that they teach their clients about minimum impact techniques and why these skills are necessary. On places like the Steens we don't want to see too many outfitter's, some are fine and provide a valuable service, but perhaps limit their numbers. No helicopter use on Steens unless for emergencies, in the back country these machines have no place and interfere and degrade on a primitive recreation experience as it surely must also disrupt nature (mainly to wildlife).

--During the winter let the mountain rest from human uses.

--Would be good if BLM and the Military could work together that restricts training flights over Steens Mountain. At least keep them at a high altitude. These low over-flights are frightening and interrupt my experience.

--Please ensure protection for Wildhorse Lake. This is such an interesting and fun place and a lot of use occurs there. Consider day use only at the lake and basin of the lake area.

--We like the recreation philosophy and plans in Alternative D better than the proposed alternative for Steens with the above exceptions. Make alternative D the preferred choice.

--Satisfied with existing recreation facilities on the Steens, which includes the new proposals, but please, no more others than mentioned above. We like the fir grove trail idea, but please, restrict motorized vehicles.

Other Areas

--Depending on what happens with wilderness, the Alvord Playa will probably need a higher intense recreation management strategy. Whatever the case, please protect/preserve the solitude and general natural setting of this place. We like the idea to exclude commercial operations on the Playa. Is there more you can do to protect this place over the long long term without making too many restrictions?

--Concern that Owyhee Springs and Jeff's Reservoir would no longer be designated as recreation sites. Why not? We would rather see these places continue to be managed properly for their recreation uses as opposed to without specified management. High use recreations sites require more intense management to safeguard natural resources! Please continue to keep the above places as managed recreation sites.

Off Highway Vehicles

--Seems like BLM is missing the boat here. In the preferred Alternative there's more acres open than what is presently the case! Odd. In this day and age vehicles going cross country are not acceptable especially for such large acreages that BLM is proposing. Maybe some places are okay to be open, but for the most part it seems more ecologically sound if most places were designated as "limited" to designated routes! In some cases and in other places in this document, BLM says how important ecological conditions are to be achieved, yet in the situation of open vehicle designations BLM is saying it's okay to potentially damage the environment as could well happen when vehicles travel cross country, especially in arid environments. Please reevaluate, be consistent on improving ecological conditions, and try again. don't be afraid BLM, do the responsible thing.

--Would like to see all vehicle routes classified as limited to be "designated" as opposed to being termed "existing". Reason is that designated routes better protect the environment and better restricts new routes from being created. Would also like to see a signed program that defines to the public which routes are really open for travel and which are closed. There's also a public educational opportunity here too by explaining your actions on why certain routes are not open or have restricted access utilizing the signing (interpretation) concept! Existing Limited use designations seem to be basically saying the area is open for travelling cross country unless we catch you!! Then if you are not caught the next day a new route exists because you went cross country and suddenly a new "existing" route has been created and fully acceptable for travel by the next person! Don't like the term "existing" in this context.

--The Blm also needs to follow their own policies and adhere to the law when travelling in restricted areas. Stop using administrative privilege as an excuse to do or go wherever you choose! Cross country travel is becoming more of a problem with BLM employees than it is with the public! Who will monitor the BLM?

--Primitive and semiprimitive nonmotorized ROS classified areas should be closed to vehicle travel as the type of recreation opportunity sought in these places is not consistent with motorized travel.

--Would like to see considerably more seasonal closures on BLM roads during the winter and spring months to prevent road/resource damage.

--Would like to see route closures (at least for the Steens, Pueblos, Trout Creeks/Oregon Canyon) during deer hunting seasons. Seems like there are an extra amount of vehicle use in the more remote locations of the above mentioned places during hunting seasons - maybe hunters don't need to drive everywhere!

--We like the idea that if WSAs are released their OHV rating stays the same. These places still have values worthy to take care of - good job.

--In Special Management Areas, only allow snowmachines on roads and then only when the road can be found. Don't really care for snow machines on Steens Mountain. I have concerns that they will accidentally venture into WSAs and plus there's concern with wintering deer! I'd rather see this use rescinded. Don't believe BLM has the ability to properly monitor this special use! There are plenty of other places of equal or better quality to snowmobile than Steens Mountain.

--Cross country ATV use is increasing, which stresses wildlife and degrades natural values, especially in Special Management Areas. We would like BLM to become more aggressive in dealing with these emerging ATV problems: BLM needs to work with ODFW to help reduce ATV intrusions during hunting seasons.

--BLM personnel should be subject to OHV rules and regulations just like the public!

Visual Resources:

--There really is not much to this section as outlined in this plan. Maintaining visual standards in scenic areas are important, but it seems BLM is remorse in proper visual management. In the future, please take visual resources more serious. BLM, become more pro-active in making visual resources better addressed. Maybe there are better ways to visually hide new projects or maybe BLM can become more active in improving landscapes that have been altered in the past through, for instance, restoring old mine sites, reclaiming or removing old range projects, rehabilitating closed roads or even closing visually impairing non-functional roads, etc..

--We would like to see wild rivers, WSAs, RNAs, and scenic ACECs to be Class I visual areas. This Class I definition seems to be more consistent with protecting values associated with these places!

--We would like to see BLM develop specific prescriptions per visual class in the entire planning area. The present visual class definitions and objectives are okay, but really don't say anything and fail to provide adequate protection especially in Special Management Areas.

--We like the idea that if WSAs are released their visual ratings remain the same - these places still have values worthy to protect/recognize. Good job BLM.

--We would like BLM to work with the State of Oregon to remove, acquire the land, or better camouflage the radio towers on top of Steens Mountain. They are very ugly and noticeable from a great distance from outstanding backcountry areas, such as from Wildhorse Lake.

Areas of Critical Environmental Concern (ACECs):

ACECs are the only positive actions of this plan with a few other very isolated exceptions. Compliments to the Vale District for their insight and courage to not only recognize special values, but to propose such an increase of ACECs that will protect those values. A refreshing and commendable action and shows the ability to practice responsible land use management. We are encouraged to see that true multiple use management is finally beginning to be applied. However, we do have additional thoughts on how to better improve the management of ACECs as explained below.

--ACECs have extensive management prescriptions which is good. Extend the detailed prescription approach into all special management areas and other areas of a sensitive nature.

--The specific management table has nothing about grazing, recreation or roads, why not? Grazing, recreation, and roads are significant in the proper management for ACECs and have a high potential to degrade values, please include and address.

--All activities inconsistent with the relevance and important values should be modified or cease to occur. Mineral and energy management or approach for ACECs looks good and serves as a strong statement for protection of these special places. Good job here.

--We support the Owyhee River ACEC dropping. The values that are special are now being protected by the National Wild River designation and dual protection in this case is not needed.

--We Don't support the Alvord Peak ACEC dropping. An interesting big horn sheep (a sensitive species) population exists there and being the WSA is only a temporary designation and plus there is a threat from mining (so says the Wilderness EIS), protection of the area via an ACEC is warranted. Mineral withdrawal will be necessary. Plus, the eastern side of Alvord Peak is very scenic and worthy of protection. The scenic qualities are also relevant and important, please add "scenic" as a value worthy to protect.

--We question the Picket Rim ACEC dropping. Simply because there are no current threats should not warrant dismissal of the relevance and importance values! If the relevance and importance values are present, then Picket Rim should remain an ACEC.

--Nominate a Lone Mountain (entire mountain) ACEC in the Andrews Resource Area. Lone Mountain has outstanding scenic values and is known to support big horn sheep, a sensitive species. The area has enough special features to warrant an ACEC designation with appropriate protection measures. Don't understand how BLM could not have recommended this place as wilderness because it possesses all the qualities of a spectacular wilderness that clearly outweigh all other uses for this area! Relevance and important values include scenic, wildlife, and geologic features worthy of long term protection.

--Promote educational avenues and outreach opportunities associated with ACECs in a manner that will teach and protect the values associated with these special management areas. Go beyond designations and management prescriptions and expand educational outreach efforts.

--Overall, existing and potential ACECs look good and we support the designation and management direction, except as mentioned above

Wild and Scenic Rivers:

--It is disappointing to see no more rivers were found to be suitable and is disheartening that BLM may lack the professional judgment to recognize national treasures.

Home and Wildhorse Creeks in Andrews and Willow Creek in Jordan are unique and interesting places with what appears to be ample outstanding remarkable values. We would like to see at least these three rivers/creeks above recommended to be National Wild Rivers.

Wilderness Study Areas:

It is good to see that the land outside WSAs that are being recommended for wilderness would be added to existing WSAs. Thank you and good job. However, this whole WSA section falls way short. One would have to wonder or question just how capable or knowledgeable BLM is in properly managing these very special places! We're not sure we trust BLM on how to manage WSAs let alone wilderness! In view of this we would like to see a commission or board be established to help BLM protect wilderness values in WSAs and eventually wildernesses. Perhaps the only way to force BLM to properly manage for wilderness values is to do it legislatively or allow another entity to take charge of these special and valuable places! It is in your hands BLM, do your job or we will fire you!!

Here are some short falls that should be included:

--There should be reclamation activities occurring in WSAs. While the WSAs have mostly been formed by the forces of nature there were some human developments present that were substantially unnoticeable. For those projects that were included in WSAs that are not functional please remove, reclaim rehabilitate. WSA reclamation actions or goals/objectives should be addressed in the SEORMP.

--WSA infractions or violations: BLM keeps WSA infractions/violations very quiet, but we know it happens and sometimes we even see the end results (new routes being pioneered, cross country travel occurring, new fences suddenly appearing, out-of-place recreation signing constructed inside WSAs, etc.). We would like to see an annual report presented to interested publics stating what WSA infractions/violations occur and courses of action taken to correct problems. The BLM Interim Management Policy makes a big deal out of monitoring and surveillance and rightfully so as patrolling/checking WSAs helps ensure wilderness values are protected. Please address WSA violation issues in this planning effort. We think BLM has been terribly slack in this important WSA management responsibility.

--Grazing in WSAs is a big deal in the Burns and Vale Districts. There should be stringent definitive grazing prescriptions within WSAs. After all, we are talking values of potential national interest and lets face it, grazing in eastern Oregon represents a significant threat to OUR potential wildernesses! Perhaps grazing is lawfully allowed, but it is essential that ecological conditions are held at their highest levels/priorities where WSAs are involved. STOP putting in grazing projects in WSAs - STOP managing WSAs as if they were just pasture land. Manage for the wilderness values that made these places special FIRST.

--STOP placing developments in WSAs. Maybe there are places where wilderness values can be made better by putting in a project, but only if it clearly protects or maintains the wilderness resource. STOP fencing us out!

--We like it that if WSAs are released from wilderness consideration that the Visual Resource will remain a Class II (seems like a class I would be more fitting and we would rather see the Class I applied) and that the Off Highway Vehicle Classes would also remain the same. Good job. However, we would like to see this same philosophy also applied to minerals and energy where the same restrictions now present would remain if the WSA was released from wilderness consideration. If the concept is to continue protecting certain values then it seems logical to continue with mineral/energy restrictions, please apply and lets be consistent.

--A long time has passed since the wilderness inventory occurred and changes outside WSAs have happened. Perhaps it is time for BLM to conduct another inventory (excluding those places already a WSA of course)! Isn't conducting an on-going land inventory part of the provisions of the FLPMA (Section 202)? At the very least, we want a new wilderness inventory conducted of those lands acquired within or immediately adjacent to all existing WSAs. Other public land, due to acquisitions, may now be eligible for WSA status and those places should also now be reviewed. Please do conduct another wilderness inventory. If it is found that new places do contain sufficient wilderness values, please add to WSAs or create new ones. Other places like Utah and Colorado are conducting new BLM wilderness inventories, why not Oregon? However, BLM (especially in the Burns District) are not known for their good WSA management or past inventory efforts. In view of this, please conduct the inventory, along with the decisions on whether to make it a WSA or not, in the hands that are outside the Burns District. In Utah, BLM brought in a team of experts to conduct a re-inventory. This team of outside experts seemed to have worked well in the Utah situation and thus to be fair we would like to see an outside team brought in to conduct the Burns District re-inventory effort. Where wilderness is at issue, the Burns District cannot be trusted to manage WSAs in a method that ensures wilderness values are safeguarded. Sorry, but this is just the way it seems to be.

--The Pueblo/Lone Mountain Allotment Management Plan (AMP) has been completed. Range conditions have improved and getting better every year. BLM did a good job in getting livestock under better control while, for the most part, did not degrade too many wilderness values that would impair wilderness suitability. Since the main reason not to recommend wilderness in the southern portion of the Rincon, eastern side of the Pueblo Mountains, and Basque Hills WSAs was mainly because of the need (desire) to place a high amount of grazing developments to better control livestock, we believe that because grazing is now under control and BLM has a good AMP in place, that another look at wilderness recommendations should now be re-evaluated! The above request is probably not possible for BLM to conduct even if they wanted, due to the stage of the wilderness review, but keep the above statement in mind when wilderness legislation is introduced. BLM's rationale for no wilderness in the above situation no longer has merit!

--Private and State inholdings, or in some cases land adjacent to WSAs, should be aggressively pursued for acquisitions (includes surface and subsurface ownership). These places are vulnerable to adverse outside threats and early aggressive action to prevent impairment is needed. Once acquired, a wilderness inventory should occur and if wilderness values are sufficiently present then add to the affected WSA. Even if not added to the WSA, strict land management prescriptions should be put in place to eliminate or significantly reduce present or future threats to wilderness values.

--There is concern with fire suppression, control burning, and fire rehabilitation in WSAs. Please see fire section for a better description.

Specific Projects in the South Steens Mountain Area:

Your help is especially needed to prevent BLM from placing an incredible amount of fencing within two side-by-side Wilderness Study Areas. If allowed to prevail, by the time it is all said and done, there will be around 20 miles of new fence constructed. That's not including the two miles of fence that had been originally inventoried in each WSA. Wilderness values would be devastated and essentially these places would become just federal livestock pasture lands. Tell the BLM NO WAY, Wilderness Study Areas are OUR potential wildernesses and WE want all of their wilderness values preserved instead of compromised, at least until Congress makes a decision.

--The amount of new fencing coupled with previous fencing constructed goes to far in the Home Creek and South Fork of the Donner und Blitzen River WSAs; the demise of critical wilderness values is imminent (naturalness and primitive recreation) if the amount of new permanent fencing is installed. The result of the fencing will dramatically change the natural character of a wilderness landscape. Stop fencing Oregon and stop fencing us out and stop managing special areas as pasture lands.

--BLM has made a terrible attempt to assess wilderness values. BLM has said that wilderness values would be enhanced, but we believe that 20 miles of new permanent fence does not constitute a wilderness benefitting action. Some wilderness values may be improved but other values, the key values, would be considerably degraded beyond those that would be enhanced. All one has to do to conclude wilderness values would be substantially degraded is to read the definitions of how BLM has defined primary wilderness values plus the definition of "Naturalness" as defined in the Wilderness Act (a place that has been primarily formed by the forces of nature where man's imprint is substantially unnoticeable).

--BLM is over stressing ecological values and allowing the term "ecological" to dominate all actions. Ecological conditions are critically important in WSAs, but it is how they are achieved that counts. Wilderness values do not evolve around grazing systems, but rather grazing systems evolve around wilderness values. BLM needs to adjust the way they perceive wilderness.

--Cumulative impacts are not properly addressed. New fences along with other fences are not substantially unnoticeable, but rather are noticeable as they are more than a small inconspicuous feather (lay of the land and vegetation are not adequate to hide this size of fence).

--The only clear ecological advantage is to fish and riparian, which is good, but the ecological integrity as a whole also needs to be clearly benefitted. Before ecological improvements actually enhance naturalness and primitive recreation, ecological benefits need to be comprehensive, which they are not in this case.

--Question and challenge BLM just where private property fences would be constructed and how much of the WSA would be impacted and which WSAs would be affected. Ask BLM how much existing fencing along private property already exist and have them show you on a map. By law, WSAs are managed as a separate unit and while an ecosystem approach is good, there exist very special values in WSAs that require a different management perspective.

--The entire fencing proposal is in violation with the FLPMA Section 603(c) as suitability for preservation of wilderness is impaired and thus constrains Congress's authority to designate the above two WSAs as potential wilderness. It is impairing because: (1) The fence(s) [Lauserica and Stephens] would be unquestionably substantially noticeable due to their mere large size plus the cumulative effects of all other fences [Pendland and Blitzen Protection] constructed since after the wilderness inventory occurred. The new fences coupled with all the other fences become significant and exceeds the threshold of acceptability, and (2) The fences hinder and impede free movement to people and wildlife. Not all fences would hinder free movement, but the size and overall amount of the proposed fences create obstacles that encumber movement in a relatively large area. The Wilderness Acts says that a wilderness is, at least in part, "untrammeled by man". BLM defines "Trammel" as, "anything that impedes or hinders free action". The BLM has stated in their analysis that the fence(s) would "hinder" travel, therefore, in their own admittance BLM would (have) willingly violated a wilderness mandate of a place being "untrammeled", which ultimately would constrain or alter Congress's authority to make a fair wilderness decision to the WSAs in question.

--Here is an interesting situation: How come BLM, via the Donner und Blitzen Wild and Scenic River law suit, allowed placement of the Blitzen Protection Fence, which is located in two WSAs, probably knowing all along that to make this fence work properly, significant large amounts of additional fencing would be necessary, which would also be required within the same WSAs? Most likely the Blitzen Protection Fence was a negotiated settlement between BLM and the Plaintiffs. Our question, did the BLM negotiate in bad faith and withhold information to the judge and plaintiffs that by placing the Blitzen Protection Fence a great deal of additional fencing would then be necessary to complete a grazing system! Appears that way, which places a question in our mind on just how capable BLM in Burns is on managing wilderness values in WSAs and ultimately wildernesses! If BLM did withhold information or negotiated in bad faith it is our opinion that this was underhanded and morally wrong and is further reason not to trust the agency when it comes to preserving wilderness values!

--One of the reasons BLM is not recommending that the South Fork of the Donner und Blitzen River WSA be designated as wilderness is because BLM believes the area needed more intense grazing management applied and that the extent of projects required is not consistent with wilderness. Based on the BLM wilderness rationale in the Oregon Wilderness EIS, why is BLM taking it on themselves to eradicate wilderness values in WSAs before Congress can take action? You need to challenge BLM and ask them to explain better their confusing rationale and don't take an explanation that it is only being done to protect redband trout as an answer. There is more than one avenue to protect sensitive fish and it need not be at the expense of degrading or losing wilderness values.

Keep us (you) informed on the development and progress of this South Steens grazing situation. Please keep us abreast and add my (your name) name to the mailing list to receive information as it unfolds.

Late Breaking News:

Wilderness Care has just found out that BLM is going to mostly abandon their South Steens livestock management proposal found in this planning effort! Instead, BLM is preparing a separate Environmental Assessment (EA). On what we know, it is as bad as the one being outlined in this EIS. We feel that our comments in this document would continue to apply to the new EA. We don't know what BLM is trying to do with all these proposals except to attempt to confuse us to the point that we will just throw up our hands in the name of confusion. With all these different plans (South Steens Allotment Management Plan, proposals contained in this EIS/RMP, and now a separate EA (all of the same area and topics) coming out, we wonder if BLM has even a clue on what they are doing on any front? If you want to have a say about what goes on in the South Steens area immediately ask BLM for the Lauserica Environmental Assessment (EA) and request that the comment period be extended because you need more time to evaluate the EA.

National Conservation Area (NCA):

--An NCA is interesting, but there is not much to this section and leaves us still wondering what exactly an NCA would do to or for Steens Mountain. Seems as though BLM is not providing the whole story. For instance, we would like to know more about the other proposals such as a park and NCAs, that have been submitted for Steens Mountain by various organizations or entities. Please address. We would also like to have explained to us, without a biased opinion, what are the differences (definitions and description) of the various national designations to include, National Parks, Monuments, NCA, National Scenic/Recreation Areas, and wilderness/rivers. Then we would like to have explained to us what might be the impacts that each of the above designations would have on Steens Mountain (please, don't be biased). We believe the above requests are fair and would like you to address our concerns/issues and explain the general designation differences along with their impacts.

--We would also like to see the Owyhee Canyon Lands addressed as a National designated place like how Steens Mountain is being considered. We know that there has been a proposal to designate the Owyhee Canyons Lands as an NCA and believe this area should also have equal consideration as with Steens Mountain.

Whether BLM wants to keep Steens Mountain or the Owyhee Canyon Lands under its jurisdiction is irrelevant. These are public lands and we the people along with mother nature will decide their destiny. BLM only represents stewards of our public land and needs to be reminded every now and then that they do not own these places. Nonetheless, BLM is to be commended for recognizing that Steens Mountain is indeed a special place worthy of National significance and protection for future generations. Thank you.

Other Areas of National Importance:

We recommend that Mickey Hot Springs in the Andrews Resource Area be designated as a National Natural Landmark under the authority of the Historic Sites, Buildings, and Antiquities Act of 1935. Mickey Hot Springs is a nationally significant area with a unique geologic feature, a complex array of various and interesting natural hot springs. Even BLM has said that this is a special place of unique character. By the way, BLM is to be commended for recognizing the exceptional values present at Mickey Hot Springs and taking some actions to protect this great place.

Human Uses and Values:

--Alternative D is more compatible with sustainability of nature and long term viability for communities. There needs to be careful consideration not to allow small communities to become too self reliant on the government as has happened in the past.

--We would like more detail on livestock grazing facts and figures on a local basis and also on an overall perspective. How much does BLM spend on administering grazing permits and how much does BLM spend on Range projects that are tied to grazing (averaged annually and include wages) situations. What are the specific economic contributions of ranching operations to local communities? Please breakdown per community.


--Pretty weak section! Livestock grazing has and does cause damage to cultural sites/resources, but little is mentioned about this impact. Where livestock grazing is causing damage or has the potential to cause damage (threats), grazing practices need changed or livestock excluded instead of the present standard of using mitigation measures to resolve dilemmas. Again, why must everything evolve around livestock grazing?

--Cultural/historic sites are truly windows to the past and their preservation is of critical importance. In special management Areas, especially WSAs, cultural sites should be left in place as opposed to being excavated. Cultural values are a special feature and adds to wilderness values. When sites are excavated, certain values that helped make the WSA unique are lost forevermore, plus it causes surface disturbance which is not acceptable. It's okay to study on-site, but coming across these places in potential wilderness serves as a fun primitive recreation experience and is a part of the natural history that should be kept in place.

Lands and Realty:

This section is mostly okay, but the following needs to be incorporated:

--Include as a new objective and develop actions to achieve something in the line that serves to clean-up, restore, rehabilitate, reclaim public land that has been damaged, contains trash, or has significantly been disturbed. BLM has mile after mile of old non-working fences, water facilities that never worked or have been abandoned, abandoned mines, abandoned roads, and probably many other past developments that scar the landscape. Even if the disturbance is relatively small reclamation efforts should be addressed and resolved. We would rather have tax money spent cleaning up public land from past failed endeavors as opposed to constructing more grazing projects!

--Create a new acquisition zone that is of the highest priority and aggressively pursues the acquisition of surface and subsurface properties within or adjacent to special management areas. Special Management Areas are unique places and deserve full management attention. Non-Federal areas and subsurface inholdings represent threats that may, and have in other places, devalued significant attributes of special management areas. Even if no immediate threat is seen or recognized regarding the lands mentioned above, one never knows what the future holds and it is better to be safe now than to be sorry later!

--Conservation or scenic easements are good especially for inholdings within special management areas or high recreation places, but make every attempt to acquire the land first.

--Regardless of why the land is acquired, always inventory the new property for its wilderness characteristics. If it obtains wilderness characteristics and fits established wilderness criteria then make it into a WSA or add to a WSA. Don't like the wording that newly acquired land will be managed as to why it was acquired. BLM is not oriented toward protecting the values found in SMAs; it is unlikely that BLM would ever acquire land to better protect special values, but rather the primary purpose being to promote better livestock grazing. Promoting better livestock grazing is admirable, but is not good enough and we the people deserve more than just good pasture lands!


We suppose addressing the road issue is acceptable in a Transportation Plan at a later date but with the following provisions:

--The Transportation Plan is made public where we the people will have the opportunity to make comments, provide feedback, and give you guidance on how we want roads to be managed on our public land.

--The Transportation Plan should include not only maintenance and access issues, but also the viability of roads and trails. For instance, in the Planning Area there are many roads/trails, some or most of them were created in an era that had no consideration for environmental issues and the results were poor location causing erosional problems, slope stabilization problems, scaring of the landscape, formation of new and unnatural stream channels, and adding higher sediment to streams and lakes. In other words, federal land in the planning area contain roads that probably should be closed and rehabilitated or relocated. Where roads are not consistent with special management area objectives or are causing degradation of their unique values then the routes should be closed and reclaimed without question.

It's okay to defer addressing roads in a Transportation plan, but be sure to include us, the people, and be sure to cover all aspects of the road issue. However, in the RMP we would like BLM to include at least some general road objectives of what the Transportation Plan will cover and address the following:

  • General road access and maintenance issues
  • Criteria for road/trail closure
  • Road/trail evaluation techniques where ecological conditions are addressed that will help determine when a route should be closed, reclaimed, left alone, or relocated
  • Reclamation standards or techniques
  • Allowing roads/routes to remain open for motorized vehicles just for hunting is NOT acceptable

--Routes that cause ecological damage and serve little to no purpose should be closed and reclaimed accordingly. Vehicle routes can be difficult to close in the desert, but nonetheless an effort should be made. After all, there is proof in the Pueblo and Steens Mountains within the Andrews Resource Area that roads can be successfully closed and are now nicely healing. Compliments to the Andrews Resource Area for your good, however small, efforts. We would like to see road reclamation efforts as a priority project over the next 20 years!

--It's okay to leave certain routes open to maintain established grazing projects, but these routes should only be used by permit and then only as needed to service the facility. The general public would not be allowed to access these routes unless by foot or horseback. The above action would protect ranching operations by helping safeguard livestock from theft and would reduce impacts on the environment by decreasing vehicle activity. The above permit system should at least be applied in Special Management Areas. Please apply the above stipulations on maintaining existing and working facilities.

--Please state when the Transportation Plan will be initiated and its anticipated completion date. Also state when the plan will be initiated once finalized. Please tell BLM to add your name to the mailing list to receive this Transportation Plan and allow an opportunity to comment. Any time past three years from now to complete the Transportation Plan and to begin its implementation is not acceptable.

Ecological Site Inventory (ESI)

--BLM in Burns needs to better utilize information gathered from the ecological site inventory regarding soil and range information. The BLM has some excellent data that resulted from the ESI, but seemingly fails to utilize this information in helping analyze situations. Please incorporate/include ESI data to help make land use decisions. ESI data really is using the best available science in making management decisions.

Thank you for the opportunity to comment and please address/include our issues and concerns.

About the Authors

We are Wilderness Care. An organization devoted in caring for our environment. We understand and appreciate the value of federal public land and believe these places belong to all Americans and are worthy to preserve.

Who is Wilderness Care? We are a group of retired federal employees who know about land management issues. We still care enough to try and make a difference in properly caring for our public lands. The unfortunate part is that many of us fear the heavy hand of our government as we did while being employed by the various natural resource agencies. Many of us have seen what the government can do when they want and are recipients of disciplinary actions for opposing destructive land management practices. We still have a reason to be cautious despite being retired and separated from federal service. Wilderness Care members have chosen to be a silent organization and you will not be able to track our organization. However, we are watching and listening about natural resource issues all the time and will at times provide you, our front line people, with valuable information as we have in this SEORMP.

We hope you find this review helpful and encourage you to take action by writing and explaining your thoughts to the BLM even if you don't agree with our review.

Our review team consisted of retired Biologists, Recreation and Wilderness Planners, Environmental Coordinators, Surface Protection Specialists, various Scientists, Landscape Architect, and a Sociologist. We might be old, but we still know a thing or two about proper natural resource management!

Good luck and let the government hear from you. Words, especially from a lot of us about the same things to the right people, will make a difference.

With Love
Wilderness Care


An open note to Wilderness Care:

Wilderness Care, please have mercy on a retired BLM Range Conservationist. This was one whale of a lot of retyping from a sometimes barely legible several generations copy that my failing eyes had difficulty reading, despite the large type used on the original. If you leak future white papers that would be appropriate for posting on the web at RangeBiome or RangeNet, it would make my life much easier if you would anonymously mail me a 3 1/2 inch IBM format floppy disk in any popular word processing format, or as a text file. Besides making my life easier, it would also reduce the time required to get the material on the net. You can mail the floppy to:

Larry Walker
2850 SW Cedar Hills Blvd., Suite 251
Beaverton, OR 97005

You are also welcome to post anonymous messages at A Public Rangeland Forum.