Please accept my comment as a private citizen opposing the proposed 60% fee increase for the Imperial Sand Dunes.

The BLM has taken virtually zero public input regarding this increase, releasing their proposal less than three weeks prior to the RRAC meeting. This shows complete contempt for the requirements to take public input contained within the requirements of the Federal Lands Enhanced Recreation Act (FLERA). Contrast the BLM proposal to the Plumas Campground proposal on the very same agenda which very clearly documents the necessary public input to their proposal with adequate time for the users to digest and comment on the proposal. The contrast grows even larger when one considers the ISDRA is the most attended non-national park federal land area in the entire country.

When analyzing BLM's own figures in their proposal, they show a nearly 40% reduction in anticipated pass sales between 2007 and 2009, and still propose a 60% increase in fees. With such a reduction in visitation should come a significant reduction in needed and expensive services like law enforcement (the second largest budget line item) yet their budget projections assume the same amount of law enforcement is required in the future. This is also counter intuitive to the BLM's own claim that they have returned the ISDRA to a "family friendly" environment. While a certain amount of law enforcement will always be necessary, it certainly is not the same amount as needed for 40% less visitors who are well behaved. A huge cost savings can be realized here, reducing the need for operations funding, and certainly not supporting their proposed increase.

It appears the single largest budget item (nearly 20%) of their proposed budget is simply overhead used to collect the fees. Certainly the RAC should see this as an excessive cost, and should be rejected in the computation of any fee's until it is brought under reasonable cost constraints.

BLM's own budget projections indicate that should this increase be approved, even with the extravagant expenditures contained within their budget of which I've cited just two glaring examples of excess, that they will have a surplus. No government agency spending money provided by the taxpayers should be budgeting to a surplus.

And last, but not least, the BLM is not complying with the requirements in FLERA, as the fees they are charging are not truly for recreation, but are rather applied as an "admission" fee. The BLM's response is that this is "easier" for them rather than complying with the law. I would strongly urge the RAC to not approve a fee for an agency that is not following the laws of the very country they are supposed to be serving simply because it is not convenient for them.

I ask that the RAC disapprove the fee increase sought by the BLM and require them to comply with both the requirement to consider public input in a timely manner, but the very law they seek to use to collect the said fees before you consider any future fee modifications.

Thank you very much for taking the time to listen to my input.

Did these words actually come from Neil's mouth????

I hope that all of those who have an opinion regarding this 11th hour fee proposal will submit their own comments. Feel free to post them here too...it might help others formulate their own comments.

Prolog:

I'm not supporting the fee increase. I've never been a proponent of any fees. I make these statements here, at the top, so you can refer to them before you pull your knives out for the comments that follow.


1. While, on the face of it, Ms Woods comments "It's easier" certainly rankle (that means pi$$ off), the fact is, it IS easier, for US. And quite likely cheaper FOR US!. Before you guys get all hot and bothered about HOW they are currently collecting the fees and force a radical change, please save this post. Just exactly HOW do you expect them to do it different? I'll tell you. It's called FENCES AND GATES. With strict in and out times. No more showing up at 2AM and finding a spot. For those of you who are major cry-whining about Disneyland, I suggest you really, deeply consider how they are going to do it different that is BETTER for US. The BLM sells theses passes with no real control over who uses them. I've had (4) different people borrow one or more of my passes this year for a Glamis trip. Expect that to go away. You want to make sure they charge per the law? Expect those fences and gates. Expect the fees to be higher to staff those gates. Expect that access will only be granted during certain times. This will happen whether they charge by the person, or if we have to buy a 'blue FEDERAL' sticker to put on our toys. They'll need to check our toys on the way in. Which will then include an 'inspection' to insure that the toy meets ALL federal and state requirements, including sound and emissions. Is the current process perfect? Nope. No process is. What we need to consider is what is the best evil we wish to live with.

2. Trash. Bottom line is, regardless of how good many of us are, it is my repeated opinion that we can't claim that Glamis is the LARGEST non-national park in the country and NOT have trash service. I can (and often do) pack my trash home and/or leave it in a dumpster, as most of the people here do, and yet, the dunes are STILL TRASHED!! Just how bad do you think it will be with NO dumpsters?

Mr. Anderson,

Thank you for your comments. I will share them with the Recreation -RAC.


Marlene Finley
Regional Director
Recreation, Lands, Wilderness and Heritage Resources
Pacific Southwest Region (California)
work phone (707) 562-8856
Cell: (707) 246-9644
mfinley01@fs.fed.us

Bob, can you post a link to the info that was disseminated at the meeting? Thank you.

Now however, this does not mean that YOU should not also send the RAC a letter with your comments. If you read this page:

http://www.fs.fed.us/r5/passes/rrac/meetin...ay2009/blm6.php

it is almost word for word the presentation the BLM gave the ASA BOD last night, and it was my impression (maybe wrong) that this is what they will be presenting the RAC in 12 days or so when they ask for this fee increase. If you choose to comment, either for or against this proposed increase, it will be best if you address the reasoning that the proposal is based upon, rather than simply relying on the emotion of this ill timed proposal (IMHO of course).

Prolog:

I’m not supporting the fee increase. I’ve never been a proponent of any fees. I make these statements here, at the top, so you can refer to them before you pull your knives out for the comments that follow.


1. While, on the face of it, Ms Woods comments “It’s easier” certainly rankle (that means pi$$ off), the fact is, it IS easier, for US. And quite likely cheaper FOR US!. Before you guys get all hot and bothered about HOW they are currently collecting the fees and force a radical change, please save this post. Just exactly HOW do you expect them to do it different? I’ll tell you. It’s called FENCES AND GATES. With strict in and out times. No more showing up at 2AM and finding a spot. For those of you who are major cry-whining about Disneyland, I suggest you really, deeply consider how they are going to do it different that is BETTER for US. The BLM sells theses passes with no real control over who uses them. I’ve had (4) different people borrow one or more of my passes this year for a Glamis trip. Expect that to go away. You want to make sure they charge per the law? Expect those fences and gates. Expect the fees to be higher to staff those gates. Expect that access will only be granted during certain times. This will happen whether they charge by the person, or if we have to buy a ‘blue FEDERAL’ sticker to put on our toys. They’ll need to check our toys on the way in. Which will then include an ‘inspection’ to insure that the toy meets ALL federal and state requirements, including sound and emissions. Is the current process perfect? Nope. No process is. What we need to consider is what is the best evil we wish to live with.

2. Trash. Bottom line is, regardless of how good many of us are, it is my repeated opinion that we can’t claim that Glamis is the LARGEST non-national park in the country and NOT have trash service. I can (and often do) pack my trash home and/or leave it in a dumpster, as most of the people here do, and yet, the dunes are STILL TRASHED!! Just how bad do you think it will be with NO dumpsters?

Lloyd what your saying is STILL against the law. The BLM is simply not allowed to charge an entrance fee. Period. Unless they add picnic awnings, firepits, showers and a bunch of other stuff that they REALLY don't have the money to add.

The only thing they're allowed to charge for (and according to Viki Woods this was added to the FLERA specifically for the ISDRA) is motorized recreation that puts an extra burden on the BLM.

They are allowed to charge. But they aren't allowed to setup gates and charge that as an entrance fee. The law doesn't say anything about it needing to be easy for the BLM to assure compliance nor does it give them any concessions to make it easier for them.

If they do fix the problem and start charging a legal fee through some kind of per-OHV sticker program they're still not allowed to charge it as an entrance fee and would find them selves back in court again.

There's also the issue of the BLM charging fees to people camped east of the tracks who have no legal way to actually access the dunes. They're being charged for something that legally they aren't even allowed to do.





And as I've pointed out several times. Dumpsters are back in the budget. And the BLM is taking steps to minimize the cost of them in the future in several ways:

1) Making the new contract flexible so if visitation continues to drop and the number of trash collections necessary goes down the price will go down as well.

2) Using a partnership with the UDG to avoid a lot of red tape and associated fees dramatically lowering the cost.

3) In the new RAMP they are trying to get rid of the need for raven proof dumpsters. Apparently FWS is claiming it was BLM who put that in and BLM is claiming it was FWS. Neither claim to support that need now. Plus there's a LOT of new studies available thanks to the mesquite landfill going in east of the dunes that show there's no need for the more expensive lower capacity dumpsters we're currently stuck with.

After re-reading the link above.( I did so some years ago when this issue was debated before) I'll have to retract my admission that the process the BLM is using to collect the 'Special Recreation Permit' fee is illegal. IMO, it is not.

The fact that they apply it to EVERYONE, whether they recreate with OHV's or not, probably is, depending on how the 'Special Recreation Permit' is written. Be that as it may, if you force the change through the courts, part of their solution will be fences and gates.

OTOH, I distinctly remember how ecstatic we all were a few years ago when Danny Boy and Co. got tagged for not buying a pass when they had their organized hike in the dunes. Remember? It made Ch 5 news.