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[cdt-l] Malpais EIS
In a message dated 2/14/01 11:24:31 PM Eastern Standard Time,
<< 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
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