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| October 27, 2004 The Honorable Gale Norton Secretary U.S. Department of the Interior 1849 C. Street Northwest Washington, DC 20240 Dear Secretary Norton: The purpose of this correspondence is to convey our concerns regarding the current level of funding to the Imperial Sand Dunes Recreation Area. (ISDRA) The 9 members of the Imperial Sand Dunes Recreation Area (ISDRA) Technical Review Team (TRT) encourage you to address a very serious problem that exists at the ISDRA. This extremely popular recreation area is one of the 12 most encouraged U.S. recreation sites promoted in the joint document prepared by the BLM and the Forest Service. And, as such, the ISDRA’s annual estimated visitation exceeds 1.4 million visitors and is growing each year. Unfortunately, the ISDRA has become a battleground pitting organized anti-access environmental groups against the Off Highway vehicle (OHV) community which includes the businesses and those seeking to enjoy recreation on their public land. The 1994 California Desert Protection Act closed about 30,000 acres of the Algodones Sand Dunes and designated them as wilderness. At that time, Congress expressed its intent that the remaining approximately 100,000 acres at the ISDRA would be left open for OHV recreation. More recently, as a result of lawsuit settlements between the BLM and several radical environmental groups, about half of the remaining sand dune chain has been closed to protect the Peirson’s Milk Vetch Plant. This was accomplished using a non-scientific approach and manipulation of the Endangered Species Act. Additionally, the new Management Plan for the ISDRA is being held up awaiting a Biological Opinion from USFWS even after peer reviewed scientific information was provided clearly showing that the Pierson’s Milk Vetch plant is not endangered and in fact is thriving in the OHV area’s. Enclosed is a comprehensive report, prepared by the El Centro BLM Field Office, which shows the income and expenditures, related to the operation of the ISDRA for the 2003-2004 season. As you can see, with the Recreation Area Management Plan (RAMP) NOT in place, it takes a bare-bones budget of about $4.5 million dollars just to keep the area open to the public and provide absolute basic services. None of the additional mandated monitoring efforts or proposed facility improvements contained in the new management plan have been initiated. Once the RAMP is approved, the operating costs rise to $6.1 million dollars per year. With documentation in hand, we discovered that Congressional appropriated funding to the ISDRA is only $200,000. Many other sites managed by the BLM receive this amount of money just to put in picnic tables or education kiosks. Fees paid by users under the Demo Fee Program tripled last year at the ISDRA to an astounding figure of $90 per primary vehicle, while users saw no improvements to facilities or recreation opportunities. Without the special appropriation of $500,000 from Congress and a last-minute funding of $450,000 this year, the bare-bones operation would have experienced a deficit of almost a million dollars. The consequences, had the BLM not received the special appropriation it would have seriously impacted visitor services, Law Enforcement and Medical services. After the California State office of the BLM notified ISDRA users that it would not be raising fees this season, this re-directed the Fee Demo program from a site improvement program to a cost recovery program. With no means to seek their required budget request, this leaves the El Centro BLM office with the astronomical problem of how to fund the required operation, maintenance, visitor services, law enforcement and medical aid. There is no guarantee that Congress will again provide one-time grants to the ISDRA. Which leads us to the question “Where will the money come from to make up the pre-RAMP $4.5 million required to run the ISDRA?” Worse yet, how will the BLM implement the new RAMP, whose budget is $6.1 million if the Biological Opinion is favorable and the Plan gets its Record of Decision? To make a bad situation worse, a recent 9th District Federal Court ruling disallows OHV use in designated critical habitat areas – which might include the habitat designated in the ISDRA for the Pierson’s Milk Vetch Plant. The same court ruled that the BLM must now provide recovery plans for species having designated habitat – another costly effort that the BLM has no funds for. On top of that problem, the environmental groups that filed the lawsuit that led to the closures in the ISDRA to protect the PMV, have petitioned USFWS to list 16 more species that they say only exist in the ISDRA, however I might add that no scientific evidence exists to verify their claim. It is clear to us that, unless the BLM is funded adequately to operate the ISDRA, the anti-access organizations who are doing everything possible to put an end to OHV recreation in this area will, in effect, be assisted in their efforts by the inability of the BLM to respond to the needs of the public at this world class recreation site – one of the Department of Interior’s twelve most publicized recreation areas. On the positive side, the gateway communities in the Imperial Valley have responded to BLM Director Clarke’s plea for user groups and communities to partner with the BLM to support the promotion and operation of recreation sites. Recognizing the important economic contribution made by ISDRA visitors to their communities, the Chamber of Commerce from Brawley, El Centro, and Yuma, have formed the United Desert Gateway Coalition and signed an assistance agreement. The charter of this organization is to promote this area as a world class riding area and thus, this would help with their economy and provide a greater level of understanding to their respective communities. These communities already recognize the vast number of dollars spent by OHV enthusiasts as they pass through these cities on their way to the ISDRA. Without a viable, adequately funded operation at the ISDRA, these efforts will be for naught. OHV leaders and community representatives will be petitioning Congressional Representatives from California to solicit additional funding of at least $4 million dollars annually for the ISDRA – hopefully with a provision for an increase when the RAMP is put in the Record of Decision. We desperately need your support to help make this happen. If the groups opposed to vehicle access to public lands succeed in closing the ISDRA to OHV recreation, the impact will be felt nationwide! A lack of funding at the ISDRA will, without a doubt, be a tool used by such groups to have the area permanently closed to OHV activity. The economic stimulus from OHV recreation in California alone is estimated to be $9 billion dollars per year. We need to do everything we can, together, to see that the resources are available to continue the operation of an area that has become the most popular OHV recreation area in the United States – The Imperial Sand Dunes Recreation Area! Thank you in advance for your attention to this very critical problem. Your ISDRA TRT (Signed by all 9 TRT members) Attachment: 2005 FY budget Cc Governor Arnold Schwarzenegger |