**From:** \<Patrushkha@aol.com\>

**To:** \<LandUseRuleComments@do.usbr.gov\>,

**Date:** 10/12/07 7:01AM

**Subject:** BOR 1006‑AA51

\> I am writing to voice my opposition to the proposed wording regarding
the

\> prohibited use of private cabin sites on Bureau of Reclamation (BOR)
land in

\> the Federal Register dated Wednesday July 18, 2007.

\>

\> I believe the intent of the new regulations is to eliminate all
private use

\> and that the Bureau is taking a hard handed approach toward the
renewal of

\> all permits.

\>

I have experienced a restrictive new attitude in the CA area where my
cabin

exists.

\>

\> Employees of the Bureau of Reclamation interpret the rule wording as

\> indicating that private permit sites at BOR Reservoir sites would
most likely not

\> be renewed when they expire.

\>

\> It appears that employees of the Bureau of Reclamation have a bias
against

\> private use and wish to see all private use removed.

\>

\> The BOR is opposed to all private use and calls this \"exclusive
use.\" They

\> are not taking into account all the people, visitors, relatives and
friends

\> that can stay at BOR lakes because of the cabins and homes provided
by

\> permittees.

\>

\> It is my view that removing cabins, homes and private use will
actually

\> reduce the use of BOR lakes and make the lakes unusable during bad
weather with

\> little cover or protection.

\>

\> Bureau of Reclamation employees really do not want to enhance use of
these

\> recreational facilities and view any private use as an inappropriate

\> exclusive use of Federal lands. They seem to place no value on the
investment

\> cabinowners and permittees have made.

\>

\> BOR employees appear to be completely unaware of the large amount of

\> volunteer amount of sweat equity investment permittees make at the
various lakes in

\> terms of trash collection, clean up and maintenance that the BOR does
not

\> have the funds to carry out.

\>

\> The BOR is making the same mistake the National Park Service did in

\> Yosemite. Because Yosemite gets crowded three weekends a year, the
Park Service is

\> closing off access, eliminating thousands of campgrounds, parking
places and

\> other facilities. They are making a \"blanket policy\" as an over
reaction to a

\> relatively small problem at Lake Berryessa in California. The BOR
appears to

\> be trying to outdo the National Park Service.

\>

\> One section of the new rule states, Title 43 Section 21.4 (2) states
in

\> part \"Whenever the Authorized Officer determines the public need for
use of a

\> recreation or conservation area has grown to a point where continued
private

\> cabin site use is no longer in the public interest, the procedures
set forth in

\> paragraph (b) of this section will be invoked . ..\" This provides a
lot of

\> opportunity for bias and subjective judgments that do not take into
account

\> the effect of decisions on local small businesses and local
communities.

\>

\> At most BOR lakes, private cabins take up such a small percentage of
land

\> and access as to provide virtually no impact on the visiting public.

\>

\> Any analysis at any lake that recommends the removal or non‑renewal
of

\> cabins or other structures should have to be part of a land
protection plan that

\> requires an actual analysis of the impacts of cabin owner
improvements on

\> visitors and access.

\>

\> This land protection plan must analyze the economic impacts on local

\> business and local communities as well as actual impacts on
recreational use. Not

\> the personal bias of agency managers. It must also evaluate the loss
of income

\> to the local BOR management by cabin removal and provide a plan for

\> replacing that income.

\>

\> I would like it noted Federal guidelines recommend the values held by
the

\> individuals who hold the permits count; not the values of a manager,
planner,

\> or any other representative of the Bureau.

\>

\> To validate your comments please fill in completely (PRINT or TYPE)
and be

\> sure to sign.

\>

\> Name\_\_\_\_\_Patrushkha
Mierzwa\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\>