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Leigh D.Espy,Deputy State Director <br /> Dave Stout,Field Manager <br /> Karl Mendonca,Acting Field Manager <br /> U.S.Bureau of Land Management <br /> February 11,2011 <br /> Page 2 <br /> The key protective elements of the plan have not changed significantly since the October <br /> 1, 2009 Implementation Outline that was submitted to BLM. In particular, the Tier 1 Long-Term <br /> Protection Measures explained in the 2009 submittal will continue to form the backbone of the <br /> SG Plan. The primary items that I anticipate will be included in the plan that were not included <br /> in the 2009 Implementation Outline include (1) floatboating Resource Guides for Segments 4-7, <br /> (2) details of the ORV monitoring plan, (3) a section on governance that explains how the <br /> Stakeholder Group will make formal decisions, (4) a section on funding of the Stakeholder <br /> Group plan, and (5) a section describing how the Stakeholder Group anticipates coordinating <br /> with federal agencies. <br /> There are some additions to the plan and a few proposed changes in how parts of the plan <br /> will work(as compared to the 2009 Implementation Outline)that warrant mention: <br /> 1. The Stakeholder Group supports the neutral deferral of a suitability determination <br /> under the Wild and Scenic Rivers Act by BLM/USFS under the Stakeholder Group Plan. <br /> 2. As with the 2009 Implementation Outline, the plan will include ORV Indicators <br /> and Resource Guides. However,the version the Stakeholders will submit on February 28th likely <br /> will not trigger an "elevation" process (or any other affirmative action) if the Resource Guides <br /> are not met. Instead, the Resource Guides will be used, as with other available information, to <br /> guide and inform the Stakeholder Group's discussions about the ORVs. The Guides are not <br /> intended to be used as a test for plan success, nor for use by agencies or entities as the criterion <br /> for evaluating a project's effects on the ORVs, understanding that this will not limit the use of <br /> any data regardless of whether such data was used in the negotiation of the Guides. <br /> 3. The plan will not provide for the "elevation" of unresolved issues to the BLM for <br /> resolution, as we expect that the BLM/USFS will participate as non-voting members of the <br /> Stakeholder Group. Instead, the plan will continue to have an "internal" Stakeholder Group <br /> elevation process that includes potential mediation and referral of unresolved issues to `Board- <br /> level" representatives. If those efforts do not resolve the issue, the plan allows the Stakeholder <br /> Group to decide whether the dispute is substantial enough to terminate the plan (although we <br /> hope that would not occur). <br /> 4. The plan will not require new projects to demonstrate to the Stakeholder Group <br /> that the project can be operated consistent with the Resource Guides. Instead, the plan <br /> contemplates that the appropriate permitting agencies will consider the impacts of new projects <br /> based on statutory standards. For example, the proponent of a new project will have to <br /> demonstrate to the agencies that the project will not unreasonably diminish the ORVs, or <br /> demonstrate that project operations will be subject to mitigation to avoid unreasonably <br /> diminishing the ORVs. The plan is not meant to be used as a component of any demonstration <br /> that a project meets the statutory standards for protection of the ORVs (unless the Stakeholder <br /> Group agrees otherwise). Proponents of new projects also may"opt-in"to the plan and seek the <br /> endorsement of the Stakeholder Group (but are not required to so). <br />