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[CDT-L] Malpais Routes

Since the "official route" was designated a few years ago, the feds have 
acquired some of the private lands to the east of El Malpais. This makes it 
possible to select an improved location for the CDT. We have urged BLM to 
take a fresh look. If members of the list agree with us, it would be helpful 
to send additional letters to BLM.  Our letter was as follows:

                                September 8, 1999 

El Malpais Plan Team Leader
Bureau of Land Management
Albuquerque Field Office
435 Montaño Road NE                 
Albuquerque, New Mexico 87107-4935

            Re: Draft Rio Puerco Resource Management Plan Amendment/EIS

Dear Sir:

    We have reviewed the subject RMP/EIS for the El Malpais National 
Conservation Area (NCA), Chain of Craters Wilderness Study Area, and 
contiguous lands (your 1610(010)).  

You have identified the purpose of the document to be "land use planning for 
the public lands and resources" of the NCA and certain adjacent lands.  As we 
understand the proposal, it is anticipated that prior decisions with respect 
to the location of the Continental Divide National Scenic Trail (CDNST) will 
continue to be implemented.  This is stated explicitly (p.2-23) with respect 
to Alternative A, but it seems to be implied for the other Alternatives as 

We consider the Plan to be deficient because of its failure to consider 
reasonable alternatives with respect to land use planning for the CDNST.  
Such consideration is called for in the light of both the Bureau's past 
statements and the recent land-tenure changes that have taken place in the 
NCA.  The reviews that are needed can be tiered to the EIS - i.e., they can 
be undertaken separately no matter whether Alternative B, C, or D is 
selected.  In the case of each of these alternatives, however, the planned 
action should be modified to assure that the location of the CDNST would be 
reviewed in a timely manner.

    The fundamental issue is one that is addressed in the 1992 Record of 
Decision.  With respect to the comment (which CDTS had made) that "hiking on 
roads (especially paved) highly detracts from the hiking experience," the 
response was: "We highly agree! …On Federal lands, all efforts will be made 
to get the trail off roads and out of site [sic] of roads."   The subsequent 
acquisition of additional lands within the NCA now makes it possible to 
implement this goal far more satisfactorily than was heretofore the case. 

    You may recall that our Society, on April 8, 1993, protested the 
decision.  In the response for the State Director (1617.2 (93513)) dated 
April 5, 1994, we were advised that the Bureau "would be willing to enter 
into an agreement with the Continental Divide Trail Society for you and your 
group to work on solving the challenges of this eastern route, thus providing 
the hiker a possible choice in routes at some future date." We responded, as 
we were invited to do, by letter dated April 21, 1994, to the attention of 
Mr. Overbaugh, in which we asked for the Bureau's "thoughts, particularly as 
to guidelines that might be used to define a relationship."  Although we did 
not receive a response to this letter, we remain eager and willing to 
cooperate with you.  The EIS should reflect the Bureau's continued 
willingness to honor its commitment.

    The existing route for the CDNST includes nearly 50 miles of walking 
along high-standard (largely paved) highways.  Based on your letter of July 
14, 1999, signed for Mr. Edwin J. Singleton (1610(010)), it appears that the 
CDNST could be located so as to traverse the NCA southeast along Cebolla 
Canyon and then southwest along BLM Road 2016 to the southern boundary of the 
NCA, with travel south to Pie Town, for slightly over 20 miles, mostly on 
county roads that we understand to be relatively lightly traveled.  (Any 
remaining private sections along BLM 2016 could be detoured around, if 
necessary.)  By relocating the trail in this manner, you would be enhancing 
the enjoyment of the Trail, reducing the serious safety risks associated with 
travel along high-speed roads, and implementing your previous undertakings.

    In our view, the reconsideration of the CDNST location should also 
include an examination of routes that would avoid the highway walk south of 
Grants (via either the Neck or the eastern part of the Zuñi Mountains).  
Moreover, because the desired use of the CDNST is for hikers and horsemen, we 
would welcome a fresh look at the Recreation Opportunity Spectrum 
classifications along the route, notably along BLM Road  2016.  If a portion 
of BLM Road 2003 is designated as a Back Country Byway, it should remain a 
low-standard way suited to high clearance vehicles only, as we understand 
from your letter of July 14, 1999 to be the case at present.  These matters 
need not be addressed now, but can await the separate review of the CDNST 
that we are calling for.

    I look forward to hearing from you with respect to the concerns that we 
have identified.  You can reach us by phone as indicated above or by e-mail 
at cdtsociety@aol.com.

                                James R. Wolf


If you do send in additional comments, please send us a copy (by e-mail would 
be fine).

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