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[cdt-l] Malpais EIS

In a message dated 2/14/01 11:24:31 PM Eastern Standard Time, 
spiritbear2k@hotmail.com writes:

<< We talked to the BLM rangers down there - they don't think much of the 
 "official' route either.  Not only because of the 42 mile waterless section, 
 but also because of the long subsequent roadwalk into Pie Town.
 We spent some time (11 miles) on a paved road (NM 117) south of the Zuni 
 Acoma Trail, but our route minimized that time/distance.  The Chain of 
 Craters route maximizes the road walk --- on paved (and busy) NM 117 (about 
 50 miles total) and NM 36 (another 5 or 6 miles) and then more on the back 
 roads heading east to Pie Town. >>

I think you can get off the pavement south of the Zuni Acoma Trail, 
especially if you are willing to attempt the excessively steep climb at La 
Ventana.  Although the approach to Pie Town from Cebolla Canyon is on 
high-standard gravel, at least that is better than using a paved highway.  

Anyone wanting to sound off to BLM can write to the address as it appears in 
our appeal, reprinted below:

                                October 9, 2000

Director (WO-210)
Bureau of Land Management
Attention: Brenda Williams
1849 C Street, NW
Washington, DC 20240

Dear Ms. Williams:

    We have received the Proposed El Malpais Plan and Final Environmental 
Impact Statement (BLM reference 1610(010)).

    We are protesting the decision at page 1-11 (Plan Amendments) for its 
failure to include a commitment to take a fresh look at the selection of a 
route for the Continental Divide National Scenic Trail. As we stated in our 
original comments of September 6, 1999 (See Comment Letter No. 19), such a 
review of the CDT "can be undertaken separately no matter whether Alternative 
B, C, or D is selected." We also urged, explicitly, that "the planned action 
should be modified to assure that the location of the CDNST would be reviewed 
in a timely manner."

    The point is very simple. The previously selected corridor relies far too 
much on high-standard roads. This may not be so obviously the case within the 
El Malpais Planning Area, but it is certainly true in the segment to the 
south, as far as Pie Town. At the time of the original selection decision (as 
cited in your response comment 19-A), the Chain of Craters option was the 
most practicable one, as private lands elsewhere blocked the way. Now, 
however, with the completed acquisition of Federal lands within the Planning 
Area, there is an entirely new situation. 

    Under the present conditions, one very good option - though perhaps not 
the only one - would be 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" (as stated in our 
earlier comment letter). 

Given the changed circumstances attributable to the land acquisitions, it is 
arbitrary for BLM to take the position presented in Response Comment 19-A 
that "the corridor location that had already been evaluated through the NEPA 
process would stand."

    Moreover, the current BLM position represents an about-face from its 
earlier commitment "to work on solving the challenges of this eastern route," 
as recalled in our comment letter. If BLM were willing to solve the 
challenges of an eastern route, as it said, then it should certainly not 
merely assume that the prior location should stand. The need for a 
reexamination should be recognized, as we proposed, in the El Malpais Plan, 
though the actual identification and review of alternative locations should 
follow at a later date. BLM should be true to its word.

    In addition to the statutes recited at page 1-1, we rely upon the 
policies set out in the National Trails System Act of 1968, as amended, as 
well as the Comprehensive Management Plan adopted pursuant thereto with the 
concurrence of the Bureau of Land Management.  The Trails Act contemplates 
that national scenic trails, such as the CDNST, are to be "located as to 
provide for maximum outdoor recreation potential and for conservation and 
enjoyment of the nationally significant scenic, historic, natural, or 
cultural qualities of the areas through which such trails may pass."   While 
the statute recognized that portions of the Trail might be located on roads, 
the general policy for national scenic trails is that "the use of motorized 
vehicles by the general public shall be prohibited." 

The Comprehensive Plan accordingly recognizes (p.34) that one of the location 
criteria for the Trail should be "enhancement of nonmotorized recreation 
opportunities" - with the further explanation that where motorized use occurs 
on one side of the Divide and reasonable potential nonmotorized trail 
opportunities are available on the other side with essentially equal scenic 
qualities, the latter route should be selected. This guideline applies 
exactly to our situation (with the exception that we would be substituting 
very low-standard jeep roads for the nonmotorized paths in the cited 
example.) As the Plan recognizes (p.38), "trail relocations on existing 
National Scenic Trails have been fairly common over time." Under the Trails 
Act, a relocation may be made where "necessary to promote a sound land 
management program in accordance with established multiple use principles" or 
"to preserve the purposes for which the trail was established." Either of 
these criteria would fully justify the action that we propose.

The Continental Divide Trail Society has been dedicated to issues related to 
the management of the Continental Divide National Scenic Trail since its 
designation by Congress in 1978.  We are a membership society, with 250 
members in 45 states and several foreign countries.  Many of our members have 
hiked great distances on the Trail and have a sincere interest in assuring 
that it should provide the outstanding recreational experience contemplated 
by law.  We include this information so as to satisfy the requirement that 
the "interest of the person filing the protest" be expressed.  We believe 
that all other formal requirements for a protest have been satisfied, but we 
would be pleased to respond to any additional requests you may have.


                                James R. Wolf