As you read this article, almost one million dollars of fees collected from campers at the Imperial Sand Dunes Recreation Area (ISDRA), also known as Glamis, is being spent to conduct an intensive four-month monitoring program in the ISDRA to evaluate the status of the Peirson's milk-vetch (PMV) plant and other species of concern. Most dunes enthusiasts do not have a problem with the monitoring program itself, but with the source of the funds paying for it. Monitoring for species listed under the Endangered Species Act (ESA) has always been paid for by the federal government. Why is this case different?
Let me offer a few salient points to ponder:
1) A new Recreation Area Management Plan (RAMP) has been prepared for the ISDRA that involved extensive input from many OHV organizations. Implementation of the plan is being held up pending a biological decision from the U.S. Fish & Wildlife Service (USFWS). This means that the BLM is not proceeding with the construction of camping pads and toilet facilities called for in the RAMP. They are, however, proceeding with the intensive biological monitoring effort called for in the RAMP!
2) The RAMP shows the "funding source" for this study to include a combination of OHMVR grants, federal appropriations and user fees. Instead, the study is being paid for solely by user camping fees for a very simple reason: that's the only place the BLM can find the money!
In past years the ISDRA has received around $1 million from the State Off-Highway Motor Vehicle Recreation (OHMVR) program (the "Green Sticker" Fund) to help with the operation and maintenance of the ISDRA facility. Since the current majority of the OHMVR Commissioners are environmental advocates, all funding to the ISDRA has been withdrawn.
The total amount of appropriated funding from the federal government to operate the ISDRA is $200,000 per year. With the recovery from 9/11 and the war going on, the Fed's are not very anxious to provide more money to a recreation area. So, all costs above the appropriated $200K must be paid from user fees collected. That's why user fees tripled this year.
3) Have you heard of "taxation without representation?" Wars have started in the past over this action by governments. Funding for the million-dollar monitoring program has been approved by the BLM without user input and without the benefit of a vote by the Technical Review Team (TRT), whose purpose is to advise the BLM on the use of fees collected. No negotiations, as to the scope of effort necessary, have taken place.
4) Over the past three years, OHV organizations have paid a well-known respected biologist to perform serious scientific studies to determine the status of the PMV. The current million-dollar study repeats that effort from scratch and also addresses other "species of concern" that are not listed as threatened or endangered. The BLM explains that this is necessary to help prevent them from becoming candidates for listing. The past studies, paid for by the OHV Community are not being utilized as a component, or a baseline, for the current effort even though USFWS has acknowledged that the information provided by those studies is significant enough for USFWS to consider the OHV community's petition to remove the PMV from the threatened species list. In fact, a decision regarding the delisting is due by the end of May - well before the completion of the current monitoring effort.
5) A decision by USFWS regarding the ISDRA RAMP was expected months ago. A "no jeopardy" decision means the plan can be implemented as written. The environmental organizations that sued for the ISDRA closures in the first place have made it clear that, if a "no jeopardy" decision is offered, they will file a new lawsuit to prevent implementation of the plan. A "jeopardy" decision means that implementation of the RAMP would jeopardize the survival of the PMV. The BLM would be required to go back to the drawing board and develop a brand new plan.
6) To rub salt in the wound, the BLM has purchased a brand new high-performance, long-travel sand rail, and an enclosed trailer to haul it in, to transport the small army of hired hands supplied for this project by a Boston-based group called Environmental Careers Organization. Any concerns about budgeting for this project would have suggested that a used 4-wheel drive Suburban might have been more efficient and certainly more cost effective.
What does all of this mean? It most likely means that, whatever happens, the USFWS decision on the RAMP is still some time off. Considering likely further delays and pending lawsuits, it is doubtful the RAMP will be ready for implementation by next year's duning season! Furthermore, due to the cost of the current monitoring study, and other costs to manage the ISDRA, FEES WILL GO UP SIGNIFICANTLY AT THE ISDRA FOR THE NEXT SEASON! In addition, users will still not see a single improvement to enhance the recreational experience at the ISDRA while the "temporary" closures remain in place!
What can you do about it? Call or write your Congressman and tell him/her that you seriously object to the idea that the BLM is writing checks out of your checkbook, in whatever amount they see fit, without your approval. If the environmental extremist organizations or the Federal Government want to mandate environmental studies at the ISDRA, LET THEM PAY FOR THEM!
