Fremency of Surveillance

sented field checking of each wilderness study area (WSA) will be conducted at least two times per year by Resource Area Staff. The Area Manager will determine it more frequent field checking might be needed in some WSA's to assure full compliance with the Interim Management Policy. Area staff will also be trained so they have an understanding of what to look for while conducting interim management patrols specifically, or in addition to other work responsibilities.

Field Checking will include:

A. Traveling the ways within the unit by vehicle, as well as viewing portions inaccessible by vehicle.

B. Completion of the WSA Field/Activity Evaluation Form, (#0-05-8500-1 see copy attached to this memo).

C. Placing this form in the appropriate WSA Interim Management Casefile, and

D. Reporting one unit of accomplishment for each complete field review under Job Code 4332-10.

IV. Record-keeping Procedures

A WSA Interim Management Casefile will be given to each Area Manager. This casefile will include a map of each WSA within the respective Resource Areas, and a list of known, existing improvements. The following items should be contained within the WSA Interim Management Casefile;

1. Documented Fieldchecks (District Form 40-05-8500-1)

2. Documented BLM & non-BLM activities whether they are authorized of unauthorized. This includes careful documentation of written and verbal communications with people and agencies outside BLM.

3. Documentation of contact with groups who have expressed an interest in knowing about proposed activities within a WSA.

4. Photo documentation will be used to:

a. Visually document the type and degree of impacts occurring on the landscape resulting from an activity. Enhancing the wilderness characteristics of an area through projects such as spring developments, etc. should also be visually documented.

b. Document compliance or non compliance to the special stipulations or condltions allowing a given activity to occur within a WSA.

c. Visually document the rehabilitation or enhancement of an area, over time, to a condition that is consistent with the IMP Handbook.

5. Color prints should be used to accurately portray the visual aesthetics of the activity and its influence upon the wilderness values of a WSA. These color prints should:

a. be supplemented by a map identifying the locatious of the pictures taken.

b. include the date the pictute was taken.

c. Be accompanied by a short narrative, explaining what the picture illustrates and why it was taken. (This narrative will help avoid the potential for confusion.) .

d. The negatives of these prints should be filed in the event duplicate prints are requested by the public, other governmental agencies (such as the IBLA), or Congress.

e. Supplemental SO or WO guidelines pertaining to the IMP should also be retained within each Resource Area.

If the Area Manager determines that an activity is not consistent with the Interim Management Policy, the activity will need to be modified. If modification is not successful, the Enforcement guidelines on page 16 of the IMP Handbook will be implemented promptly after receiving approval from the District Manager,

Actions consistent with the IMP that would enhance and/or diversify the wilderness qualities of a WSA may also be implemented. (For example, a small spring development may enhance the diversity of wildlife in the WSA.)

The procedures for keeping a record of activities occurring within a WSA are identified on pages 16-17 of the IMP Handbook. Additional guidance regarding the District IMP Implementation Plan such as State Office directives, will be attached to this plan.

V. Other

1. Grazing permittees having allotments within WSA's or the Steelhead Falls area, will have a interim management stipulation on their permit. This will require them to notify the Area Manager for approval before any maintenance, construction of range improvements, or any surface disturbing activities

occur.

2. Visitor use data will also be collected in WSA': if funds are available. ORV use will be restricted or eliminated if unacceptable resource damage is occurring.

WAS THE ACTIVITY AUTHORIZED BY PERMIT, LICENSE, GRANDFATHERED, ETC? (IDENTIFY BY PERMIT, EA, ETC. NUMBER)

WAS THE ACTIVITY JUDGED TO BE OF AN IMPAIRING OR ENHANCING NATURE?

BLM FOLLOW-UP ACTION TAKEN TO CORRECT UNAUTHORIZED ACTIVITY:

STATEMENT OF PETER BURK

My name is Peter Burk, from Barstow, California--the heart of the Mojave Desert. We are very concerned about BLM mismanagement of the East Mojave National Scenic Area (EMNSA), our Nation's first National Scenic Area. There are many instances of BLM mismanagement of EMNSA, but we want to bring to your attention four examples.

I have served on BLM's Route Designation Ad Hoc Committees for both the Barstow and Needles Resource Areas and have attended all of their meetings. The route designation process for the Needles Resource Area is an example of how BLM allows uses that will grieviously impair WSAs (Wilderness Study Areas), even BLM recommended suitable WSAs. As you can see in our visual example, the routes being supported by BLM show a spaghetti plate of roads in WSAs throughout the East Mojave National Scenic Area. And BLM proposes the same distribution of routes of travel through all five resource areas throughout the California Desert Conservation Area (CDCA). We cannot allow BLM to impair the public's WSAs before Congress has its opportunity to make decisions on wilderness suitability for these maginificent public lands. BLM action viclates and prejudices Congressional options.

Secondly, BLM's wilderness review made major errors on the differences between "roads" and "ways" and then used these errors to justify dividing WSA's. An example of this criticism can be seen in the Cima Dome Joshua Tree Forest WSAS (235A, 237A, 237B, 238A, and 238B). From the enclosed photographs, it is obvious to see that the "way" between WSAS 235A/237B is obviously not a "road"; The "way" between 238A/238B is obviously not a "road"; And the "way" between WSAs 237A/237B is not a "road." The Cima Dome Joshua Tree Forest is the world's largest and densest Joshua Tree Forest and merits the best possible BLM wilderness protection. Congress deserves its option to consider this area in its entirety, not in segments created by BLM with indefensible boundaries.

Thirdly, we are very concerned about BLM mismanagement of ACECs (Areas of Critical Environmental Concern) in the California Desert. We are concerned because, one, BLM views ACECs as an alternative for proposed wilderness areas when there is no justification for doing so, (such as the New York Mountains WSA 265, and Clark Mountain WSA 227). And, two, because BLM does not presently manage ACEC's in a manner that protects the "Environmental Concerns", themselves. For example, BLM permitted a motorcycle race to go through Mesquite Lake ACEC on January 12, 1985 (the Whiskey Pete Championship Race II). Hardly an event that would protect the cultural resources.

We continue to have enormous problems when we exercise our rights as citizens by trying to participate in BLM's decision making process. When we learned of this proposed race we protested to BLM verbally and wrote a letter restating our concerns to them some three weeks before the event. At that time I requested the Needles Resource Area office to inform me as soon as possible of BLM's decision on issuing the permit for the race (made by the Stateline BLM office in Las Vegas, Nevada--even though 60% of the proposed race takes place in California). I told BLM the Sierra Club would make an IBLA appeal if the decision went against protecting the resources of the Mesquite Lake ACEC. The BLM's Needles office phoned me at 2:00 p.m. on January 11, 1985 and said the decision for the race had been made an hour earlier to permit the race. I asked BLM, "How can we possibly file an IBLA appeal 18 hours before the race starts?" BLM had no answer. We were again stuck by a fait accompli. And this has happened before in this same area when BLM has permitted other motorcycle races without providing adequate public review or even public information of a proposed event.