Clear Creek Management Area 

Proposed RMP and Final EIS – Volume II 

U.S. DEPARTMENT OF THE INTERIOR
 

BUREAU OF LAND MANAGEMENT
 

CLEAR CREEK MANAGEMENT AREA
 

PROPOSED RESOURCE MANAGEMENT PLAN 

&
 

FINAL ENVIRONMENTAL IMPACT STATEMENT 

HOLLISTER, CALIFORNIA 

VOLUME II 

Prepared by the
 

Hollister Field Office
 

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Clear Creek Management Area
 

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Contents 

Appendix II – Route Designation ......................................................................................... 11
 

A. Route Designation Worksheet............................................................................... 12
 

B. Route Designation Criteria ..................................................................................... 13
 

C. Data Element Dictionary.......................................................................................... 17
 

D. Route Designation under the Range of Alternatives and the Proposed Action 

................................................................................................................................................... 20
 

ALTERNATIVE A & B: ROUTE DESIGNATION ......................................................... 20
 

ALTERNATIVE C: ROUTE DESIGNATION TABLE................................................... 21
 

ALTERNATIVE D: ROUTE DESIGNATION TABLE................................................... 40
 

ALTERNATIVE E: ROUTE DESIGNATION TABLE ................................................... 62
 

ALTERNATIVES F & G: ROUTE DESIGNATION TABLE ........................................ 83
 

PROPOSED ACTION: ROUTE DESIGNATION TABLE.......................................... 104
 

Appendix III - San Benito Mountain Research Natural Area Management Plan ... 125
 

1.1 Introduction .............................................................................................................. 125
 

1.2 Planning........................................................................................................................ 126
 

1.2.1 Management Goals ............................................................................................... 126
 

1.2.2 Management Objectives........................................................................................ 127
 

1.3 Natural Resource Inventory ......................................................................................... 128
 

1.3.1 Air ............................................................................................................................. 128
 

1.3.2 Water......................................................................................................................... 128
 

1.3.3 Geology and Soils..................................................................................................... 128
 

1.3.4 Lichen Species .......................................................................................................... 129
 

1.3.5 Plant Species and Habitats........................................................................................ 129
 

1.3.6 Vegetation ................................................................................................................. 130
 

1.3.7 Invertebrate Species.................................................................................................. 130
 

1.3.8 Vertebrate Species .................................................................................................... 131
 

1.4 Natural Resource Monitoring....................................................................................... 131
 

1.4.1 Air ............................................................................................................................. 132
 

1.4.2 Water......................................................................................................................... 132
 

1.4.3 Geology and Soils..................................................................................................... 132
 

1.4.4 Lichen Species .......................................................................................................... 133
 

1.4.5 Plant Species and Habitats........................................................................................ 133
 

1.4.6 Vegetation ................................................................................................................. 134
 

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1.4.7 Invertebrate Species.................................................................................................. 134
 

1.4.8 Vertebrate Species .................................................................................................... 134
 

1.5 Natural Resource Research .......................................................................................... 135
 

1.5.1 Air ............................................................................................................................. 135
 

1.5.2 Water......................................................................................................................... 135
 

1.5.3 Geology and Soils..................................................................................................... 135
 

1.5.4 Lichen Species .......................................................................................................... 135
 

1.5.5 Plant Species and Habitats........................................................................................ 136
 

1.5.6 Vegetation ................................................................................................................. 136
 

1.5.7 Invertebrate Species.................................................................................................. 136
 

1.5.8 Vertebrate Species .................................................................................................... 136
 

1.5.9 Partnerships............................................................................................................... 136
 

1.6 Fire Management.......................................................................................................... 138
 

1.6.1 Characteristics........................................................................................................... 138
 

1.6.2 Fire History ............................................................................................................... 138
 

1.6.3 Fire Management Objectives .................................................................................... 138
 

1.7 Allowable Uses ............................................................................................................ 141
 

1.8 References .................................................................................................................... 141
 

Appendix IV - Camissonia benitensis Compliance Monitoring & Adaptive
 

Management Plan................................................................................................................... 144
 

1.0 Introduction ................................................................................................................. 144
 

2.0 Definitions .................................................................................................................... 147
 

2.1 Population Terminology .............................................................................................. 147
 

2.2 Habitat Terminology.................................................................................................... 148
 

2.3 Noncompliance Terminology ...................................................................................... 150
 

3.0 Habitat and Compliance Monitoring Program ..................................................... 152
 

3.1 Plant Counts................................................................................................................. 152
 

3.2 Habitat Condition and Compliance Monitoring .......................................................... 152
 

3.3 Reporting...................................................................................................................... 154
 

4.0 Adaptive Management .............................................................................................. 154
 

5.0 Annual review with the U.S. Fish and Wildlife Service ..................................... 155
 

6.0 References ................................................................................................................... 155
 

A. Watershed Management & Restoration............................................................. 157
 

B. Barren Areas Management & Restoration........................................................ 159
 

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C. Transportation & Roads ........................................................................................ 162
 

D. Abandoned Mine Lands & Mining Related Activities .................................... 166
 

E. Recreation Facilities............................................................................................... 167
 

Appendix VI - Wild & Scenic River Inventory ................................................................. 169
 

i. Wild and Scenic River System ................................................................................ 169
 

ii. Eligibility of Planning Area Rivers & Streams................................................. 169
 

iii. Suitability of Hollister Field Office Stream Segments................................... 172
 

iv. Protective Management......................................................................................... 176
 

Appendix VII - Best Management Practices for Wind Energy Development on 

Public Lands............................................................................................................................ 177
 

Site Monitoring and Testing........................................................................................ 177
 

Plan of Development Preparation.............................................................................. 178
 

Construction.................................................................................................................... 183
 

Operation.......................................................................................................................... 186
 

Decommissioning .......................................................................................................... 187
 

Appendix VIII - Hollister Field Office Reasonably Foreseeable Development
 

Scenario for Oil and Gas...................................................................................................... 189
 

I. Summary ............................................................................................................................ 189
 

II. Introduction...................................................................................................................... 189
 

III. Petroleum Geology of the Hollister Field Office Area ................................................ 190
 

IV. Past and Present Oil and Gas Exploration and Development Activity ..................... 190
 

V. Oil and gas Occurrence and Development Potential .................................................... 190
 

VI. RFD Baseline Scenario Assumptions, Discussion, and Estimated Surface Disturbance 

from Oil and Gas Activity on Federal Mineral Estate in the Hollister Field Office Area 

................................................................................................................................................. 192
 

APPENDIX IX - CONFORMITY ANALYSIS CERTIFICATION ....................................... 197
 

Appendix X - Public Comments on the CCMA Draft RMP/EIS & BLM Responses207
 

Comment Code Legend ...................................................................................................... 208
 

I. BLM’S COMMON RESPONSES TO PUBLIC COMMENTS ................................ 209
 

Section 1: Non-NEPA/BLM Issues...................................................................................... 210
 

A. Definition of Asbestos and Chrysotile Toxicity....................................................... 210
 

Response: ........................................................................................................................... 211
 

B. Amphiboles Detected in EPA Air Samples.............................................................. 211
 

Response: ........................................................................................................................... 211
 

C. EPA Risk Assessment Methodology........................................................................ 212
 

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Response: ........................................................................................................................... 212
 

D. EPA Risk Assessment Results.................................................................................. 216
 

Response: ........................................................................................................................... 216
 

E. R.S. 2477 .................................................................................................................. 217
 

Response: ........................................................................................................................... 217
 

F. Issues Considered, but Not Analyzed....................................................................... 219
 

G. General Comments, Non-Substantive ...................................................................... 221
 

Response: ........................................................................................................................... 222
 

Section 2: Purpose and Need................................................................................................ 222
 

A. EPA Risk Assessment .............................................................................................. 222
 

Response: ........................................................................................................................... 223
 

B. Endangered Species Act ........................................................................................... 223
 

Response: ........................................................................................................................... 224
 

C. Social and Economic Conditions.............................................................................. 225
 

Response: ........................................................................................................................... 225
 

Section 3: Project Alternatives ............................................................................................ 226
 

A. Range of Alternatives ............................................................................................... 226
 

Response: ........................................................................................................................... 227
 

B. No Action Alternative .............................................................................................. 227
 

Response: ........................................................................................................................... 228
 

C. Alternative D ............................................................................................................ 228
 

Response: ........................................................................................................................... 229
 

D. Preferred Alternative ................................................................................................ 229
 

Response: ........................................................................................................................... 230
 

E. Alternatives Considered, but Not Analyzed in Detail ............................................. 230
 

Response: ........................................................................................................................... 230
 

Section 4: Impact Analysis ................................................................................................... 231
 

A. Risk Assessments & Uncertainty ............................................................................. 231
 

Response: ........................................................................................................................... 231
 

B. Impacts to OHV Recreation ..................................................................................... 232
 

Response: ........................................................................................................................... 232
 

C. Impacts to Non-ACEC Zones................................................................................... 232
 

Response: ........................................................................................................................... 233
 

D. Social and Economic Effects.................................................................................... 234
 

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Proposed RMP and Final EIS – Volume II
 

Response: ........................................................................................................................... 234

E. Cumulative Effects ................................................................................................... 235
 

Response: ........................................................................................................................... 235
 

II. AGENCY AND ORGANIZATION COMMENTS................................................. 236
 

Table X-1; Commenting Agency and Organization List........................................................ 236
 

Table X-2; Agency and Organization Comment Summary and Response............................. 239
 

AG-EPA: United States Environmental Protection Agency............................................... 239
 

AG-USFWS: United States Fish & Wildlife Service [Sacramento Field Office] .............. 242
 

AG-USFWS: United States Fish & Wildlife Service [Ventura Field Office] .................... 243
 

AG-USGS: United States Geological Survey..................................................................... 245
 

AG-DTSC: Department of Toxic Substances Control........................................................ 245
 

AG-DPR-OHMVRD: Department of Parks and Recreation .............................................. 246
 

AG-CALFIRE: Department of Forestry and Fire Protection ............................................. 252
 

AG-DWR: Department of Water Resources....................................................................... 252
 

AG-OPR: California Governor’s Office of Planning and Research, State Clearinghouse. 254
 

AG-MBUAPCD: Monterey Bay Unified Air Pollution Control District ........................... 254
 

AG-SBC: County of San Benito ......................................................................................... 257
 

AG-CAOHVC: California State Off-Highway Motor Vehicle Recreation Commission... 262
 

AG-CANAHC: California Native American Heritage Commission.................................. 263
 

AG-WRCD: Westside Resource Conservation District ..................................................... 264
 

AG-SJVRCD: San Joaquin Valley Resource Conservation and Development Council .... 265
 

Table X-2 (cont.) Comments from Organizations and BLM’s Response .............................. 266
 

ORG-AMA36: American Motorcycle Association, District 36 ......................................... 266
 

ORG-ALAA: American Land Access Association ............................................................ 271
 

ORG-BAM: Bay Area Mineralogists ................................................................................. 272
 

ORG-BRC: BlueRibbon Coalition ..................................................................................... 282
 

MSBT-LAW: Moore, Smith, Buxton, Turcke, Chartered .................................................. 286
 

ORG-CA4WDC: California Association of Four Wheel Drive Clubs, Inc........................ 293
 

ORG-CERA: California Enduro Riders Association.......................................................... 298
 

ORG-CFMS: California Federation of Mineralogical Societies ........................................ 303
 

ORG-CMDA: California Motor Dealers Association ........................................................ 303
 

ORG-CNPS: California Native Plant Society..................................................................... 304
 

ORG-CORVA: California Off-Road Vehicle Association................................................. 305
 

ORG-CBD: Center for Biological Diversity....................................................................... 307
 


 

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ORG-CRS: Coalinga Rockhound Society .......................................................................... 310
 

ORG-FOCCMA: Friends of Clear Creek Management Area............................................. 313
 

ORG-FGMS: Fresno Gems and Mineral Society ............................................................... 314
 

ORG-GRMC: Ghost Riders Motorcycle Club.................................................................... 314
 

ORG-LADBR: Los Altos Dirt Bike Riders ........................................................................ 314
 

ORG-LGMC(1) Lemoore Gems and Mineral Club............................................................ 314
 

ORG-LGMC(2): Los Gatos Motorcycle Club.................................................................... 315
 

ORG-RUTS: Racers Under The Son .................................................................................. 315
 

ORG-RRMC: Ridge Runners Motorcycle Club ................................................................. 315
 

ORG-SRMC: Salinas Ramblers Motorcycle Club ............................................................. 315
 

ORG-SVRGC: Salinas Valley Rock and Gem Club .......................................................... 319
 

ORG-SFGMS: San Francisco Gem and Mineral Society................................................... 320
 

ORG-SCVGMS: Santa Clara Valley Gem and Mineral Society........................................ 320
 

ORG-SCGMS: Santa Cruz Gem and Mineral Society ....................................................... 320
 

ORG-SCC: SaveClearCreek.org......................................................................................... 320
 

ORG-TMC: Timekeepers Motorcycle Club ....................................................................... 331
 

ORG-3ROCKS: Three Rocks Research ............................................................................. 344
 

ORG-TGMC: Tule Gems and Mineral Club ...................................................................... 355
 

ORG-VWA: Ventana Wilderness Alliance ........................................................................ 355
 

ORG-WOHVA: Wisconsin Off-Highway Vehicle Association......................................... 357
 

III. PUBLIC COMMENTS AND FORM LETTERS ................................................... 358
 

Table X-3; Individual Comment Author List (Written and e-mail) ................................ 358
 

Table X-4; Individual Comment Summary & Responses................................................. 361
 

Table X-5; Form Letter Author List (Written and e-mail)............................................... 469
 

Extend Public Comment Period Form Letter...................................................................... 469
 

Save the Trails Form Letter ................................................................................................ 470
 

Blue Ribbon Coalition Form Letter .................................................................................... 475
 

Center for Biological Diversity Form Letter ...................................................................... 527
 

Hobby Gem and Minerals Collectors Form Letter ............................................................. 584
 

Hernandez Valley Property Owners Form Letter ............................................................... 584
 

Table X-6; Form Letter Comment Summary & Responses.................................................... 587
 

Extend Public Comment Period Form Letter...................................................................... 587
 

Save the Trails Form Letter ................................................................................................ 587
 

Blue Ribbon Coalition Form Letter .................................................................................... 589
 

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Proposed RMP and Final EIS – Volume II
 

Center for Biological Diversity Form Letter ...................................................................... 590
 

ATTACHMENT 3 -- CA Department of Parks and Recreation – Science Review
 

Correspondence and Contributions to BLM's EIS Process and Alternative
 

Hobby Gem and Minerals Collectors Form Letter ............................................................. 590
 

Hernandez Valley Property Owners Form Letter ............................................................... 592
 

ATTACHMENT 1 – CCMA Draft RMP/EIS Public Meetings Report ....................... 593
 

ATTACHMENT 2 – CCMA Draft RMP/EIS Socioeconomic Workshop Report.... 594
 

Development ....................................................................................................................... 595
 

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Appendix II – Route Designation 

Vehicle use in the Planning Area is managed under the direction and authority in 43 CFR Part 8340 “OffRoad Vehicles,” and Subpart 8342, “Designation of Roads and Trails.” The off-highway vehicle (OHV) 

regulations apply to use of routes by the general public. Certain other routes may be open to private 

landholders, and grazing or other permittees, to meet specific access needs and/or legal rights. 

The BLM’s 2006 Record of Decision for CCMA RMP Amendment and Route Designation addressed a 

variety of concerns related to vehicle use, roadways, and resource protection, and provided guidelines for 

future road improvements, maintenance activities, and management decisions. The baseline for analysis 

of transportation in this RMP/EIS is the designated route network that was approved in the 2006 Record 

of Decision for the CCMA RMP Amendment and Route Designation. 

All of the designated routes under each management alternative, including the Proposed Action, were 

selected from routes previously designated as open in the 2006 CCMA RMP amendment. The Hollister 

Field Office developed the vehicle use area and route designation criteria described in this appendix (and 

in Chapter 2, Section 2.2.1) to minimize conflicts with other resource values and public land uses. These 

designation criteria address a variety of management issues, concerns, and resource condition objectives; 

including the protection of resources of the public lands, the promotion of safety of the users of the public 

lands, and strive to minimize conflicts among the various users of the public lands. 

Designation decisions are be based on a variety of data, including previous studies, field inventory data, 

biological, environmental, cultural, natural and recreation resources, land use, and land ownership. This 

process is standardized, repeatable, and can be logically followed; it assesses each route and area, and 

documents that assessment; and establishes a clear link between the designation decision and the rational 

for that decision. 

In compliance with 43 CFR 8342.1, this standardized and stepwise process is designed specifically to 

address identified minimization criteria; whereby routes were evaluated relative to a list of criteria such 

as, resource sensitivity, soil loss, manageability, intended route use, and recreation opportunity. The 

criteria were combined into four tiers (described below), roughly corresponding to the criteria’s likelihood 

of requiring route closure. 

As a result, the routes designated open under each alternative in this PRMP/FEIS, including the Proposed 

Action, have been screened through the minimization criteria using the route designation worksheet 

illustrated on the following page. 

Route designations tables depicting the data elements for each route under Alternatives C, D, E, F, G, and 

the Proposed Action, are presented at the end of this appendix. Route designation tables for Alternatives 

A and B are not included in this appendix because they can be located in Appendix A of the 2006 ROD 

for CCMA Plan Amendment and Route Designation. 

Maps showing the designated route networks under each alternative, including the Proposed Action, are 

included in Appendix I of this PRMP/FEIS. 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

A. Route Designation Worksheet 

HOLLISTER FIELD OFFICE
 

CLEAR CREEK MANAGEMENT AREA
 

ROUTE DESIGNATION WORKSHEET
 

Route Number: 

Route Characteristics 

 Length 

 Continuity 

 Description 

 Trail Maintenance Objective 

Topographic Map(s): 

EVALUATION CRITERIA 

Level Criteria Name Criteria 

Value1 

Determination 

Date 

Mitigation 

Tier 1 Private/state lands/mines 

Tier 1 Sensitive species and Cultural 

Tier 1 RNA/WSA 

Tier 1 Barrens Interface 

Tier 1 Riparian Areas 

Tier 2 Erosion, Soil Loss Standard 

Tier 3 OHV use/use spectrum 

Tier 4 Transportation/manageability 

Tier 4 Admin Use/ROW’s 

Tier 4 Route 

Proliferation/redundancy 

Tier 4 Route Continuity 

ROUTE DESIGNATION: (If Limited, Describe Limitation) 

ROUTE DESIGNATION DATE: 

 Other Proposed Actions
 

 Route Specific Rationale:
 

 Land Use Plan Conformance:
 

 Decision Criteria: Includes all criteria identified in 43 CFR 8342.1 parts (a) 

through (d) and the Proposed Action. 

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B. Route Designation Criteria 

The following criteria represent the data on which decisions about the authorized recreation use of 

routes is based. The data element dictionary (ref. Appendix II, Section C) describes the allowed 

responses for each criterion. The information on each route will be entered into an electronic 

database for analysis and query. 

The criteria have been combined into four tiers, roughly corresponding to the criteria’s likelihood of 

requiring route closure. Where possible, mitigation measures are discussed that can be used to reduce 

the expected motorized OHV impacts under each criterion. Mitigation, as used in the process, refers 

to management actions that BLM can undertake to alleviate the effects of OHV use with respect to 

the designation criteria. 

Tier One 

These factors can individually result in a closure decisions for a given route. Nevertheless, some of 

the detrimental characteristics identified by these criteria can be successfully mitigated, given 

sufficient funding, staffing, and recreation interest. 

Private Land, State Lands and Mines 

Private and state lands occur throughout the CCMA. To date, managed routes have been maintained 

to reduce erosion by the Bureau without regard to ownership unless the Bureau has specifically been 

asked to assist in preventing OHV and other uses. Where routes desirable for recreation traverse 

private land, the Bureau will seek clarification from landowners about whether or not they wish to 

allow for OHV use. Should a landowner request it, the Bureau will close routes that traverse nonBureau lands by closing the route back to the nearest intersections. The Bureau will seek reciprocal 

rights-of-way with private landowners as appropriate to provide access on primary route connectors. 

Reroutes to avoid non-Bureau lands will be evaluated under a separate Environmental Analysis, given 

sufficient recreation interest, adequate staff and sufficient funds. Mines will be avoided by closing 

routes leading to or through mined areas to avoid subjecting recreation users to increased levels of 

hazardous materials. 

Mitigation. The Bureau will seek reciprocal rights-of-way with private landowners as appropriate to 

provide access on primary route connectors. Possible mitigation for mined lands will be to 

sufficiently prevent off route travel. Complete fencing of a route, to prevent public access to 

hazardous mine areas can be considered mitigation. Route closure due to private/state lands can 

possibly be avoided by building a new portion of route. New route construction is not analyzed under 

this DEIS. 

Sensitive Species and Cultural Resources 

Federal laws and BLM policy require protection of sensitive resources, such as threatened and 

endangered species and their habitat and cultural resources. Areas that OHV recreation may 

adversely impact are best protected from such use by avoidance. These types of resources are best 

protected by not having routes bisect occupied or moderate- to high-potential habitat. Sensitive 

species and their habitat are also best protected by distance and adequate natural barriers. Cultural 

resources are similarly sensitive to OHV use impacts and can be managed in a manner analogous to 

sensitive plants and animals. 

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Mitigation. While avoidance is the preferred method to manage OHV use impacts, several strategies 

have also been documented to be successful in protecting sensitive resources. A combination of welldesigned erosion control structures and corridor fencing has greatly reduced OHV use impacts to San 

Benito evening-primrose along the Clear Creek Canyon Road. It is not currently practical to 

eliminate the county road from the trail system. It is a well established route and OHV use impacts 

can generally be ameliorated by corridor fencing. Elsewhere, routes should be selected that do not 

bisect sensitive species habitat or cultural resources. 

SBMRNA/ACEC/WSA 

The management of the expanded San Benito Mountain Research Natural Area (approximately 4,147 

acres), including the Wilderness Study Area (WSA) CA-040-309 (1500ac), requires more restrictive 

use of OHV’s. Pursuant to 43 CFR 8342.1(d) routes shall be located in Research Natural Areas only 

if the authorized officer determines that off-road vehicle use in such locations would not adversely 

affect the natural, esthetic, scenic, or other values for which the area was established. All affected 

routes were evaluated following the criteria presented for the SBMRNA/ACEC designation and are 

consistent with the SBMRNA/ACEC expansion criteria. 

Mitigation. The primary objective of WSA management is to return the WSA’s natural character 

essentially unaltered by humans during the time it is being managed as a WSA. The existing WSA 

designation allows vehicle use only on the county route (R011) and the “Ridge Route,” now called 

R010, R012 and R013. No other routes will be considered within this 1500 acre area. For the 

existing RNA and proposed expanded RNA, designated routes may need to be fenced or otherwise 

limited to reduce potential impacts of OHV use off the designated route. No mitigation for 

considering additional routes is possible for the WSA, since only the current routes are authorized. 

Interface with Closed and Proposed Closed Barrens 

A number of barrens have been closed along riparian corridors and within the WSA. Routes through 

barren areas are particularly susceptible to route proliferation and off route vehicle use. Routes 

through closed barrens will be avoided where possible. 

Mitigation. Construction of fence or other barriers that control off-route use can be considered as 

mitigation for this criterion. Reroutes to avoid a particular barren or to change the location of the 

route to minimize impacts can also be considered. 

Riparian Areas 

Riparian areas provide specialized habitat for several sensitive species and can act to filter sediments. 

Therefore, riparian areas are to be avoided and impacts from OHV use minimized to the extent 

practicable. Historically, a number of trails used streams as the primary route of travel and resulted in 

impacts to sensitive resources. This past practice is too destructive to be continued. Routes crossing 

streams can also be resource impairing, therefore the number of such crossings should be minimized. 

Sediment modeling conducted by PTI Environmental Services identified a number of sub-watersheds 

within the Clear Creek watershed that are projected to contribute particularly high levels of sediment 

into Clear Creek. It is especially important that these sub-watersheds be evaluated for opportunities 

to reduce sediment delivery into an active drainage. 

Mitigation. Impacts to riparian zones can be minimized by reducing the number of stream crossings, 

changing their location and/or orientation of the crossing to the stream, or by changing the actual 

crossing by appropriate hardening or utilizing bridges. In using these mitigation measures, it is 

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important to design stream crossings that maintain an adequate flow rate so as to discourage yellowlegged frogs from attaching egg masses at these high use areas. 

Tier Two 

Criteria within this tier can also result in closure of a route. However, given sufficient recreation 

interest and available funds, actions can be taken to ameliorate most potential negative effects. 

Erosion and Soil Loss Standards 

Routes can cause erosion within the route tread, and through concentrated runoff, to off-tread 

locations. The data for this criterion is gathered following guidance found in the California State Soil 

Loss Standards. Besides requirements for signing, route design, and soil sustainability, the standards 

also require corrective actions within specified timeframes. 

Mitigation. Many of the implementation strategies are designed to reduce route use impacts, direct 

and indirect. Most maintenance and corrective actions are relatively inexpensive and can be 

accomplished in a timely manner with existing staff. Some corrective actions will need to be 

carefully justified by comparing costs with benefits. Other problem areas can be avoided by 

constructing reroutes. 

Tier Three 

The criteria within this tier describe the level of recreation interest of a given route, and whether it 

contributes to the recreation opportunity and diversity of recreation experience within the entire 

CCMA. 

OHV Use/Recreation Spectrum 

Route selection will consider linking visitor desires with recreation opportunities. Nearly all routes 

have some recreation value. Nevertheless, it is important that the open route network contributes to 

achieving the CCMA plan’s resource condition objectives. Routes should be selected that provide a 

wide spectrum of recreation use throughout the CCMA and provide a variety of difficulty levels. 

Consideration will be given to the level of recreation interest, providing a diversity of trail types and 

experiences, and allowing for a variety of recreation activities. 

Tier Four 

This tier describes criteria focused on basic issues of route management, including maintenance, 

conflicting uses, official and administrative use, existing rights-of-way, and contribution to the overall 

route network. Consideration may be given, weighing of the costs of managing routes versus the 

recreation benefits of those routes. 

Route Management Objective (RMO) 

While the trail maintenance objective will not trigger a decision on whether to open or close a route, 

the objective does impact the cost (personnel and equipment) of keeping a route open. Similarly, the 

manageability of a route does not necessarily affect the resource impacts of its use, assuming the 

route is adequately managed. However, routes that are difficult to manage/maintain will be costly 

and given current budget constraints may need to be closed for this reason alone. Changing a route’s 

management objective may sufficiently reduce the cost of its maintenance to allow for OHV use. 

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Mitigation. The primary way to mitigate the effect of this criteria on route closure are to reduce costs 

of maintenance, through either improved efficiency or use of volunteers, or by reducing the level of 

required maintenance by changing the route management objective. 

Administrative Use/Rights of Way 

This criterion considers non-recreation uses of a route such as access to a communication site, access 

to state or private lands, authorized uses, and valid existing rights-of-way. Recreation may not 

always be appropriate for these maintained routes. When this is the case, the route will be Limited to 

Administrative Use. Administrative use designations will not be available for casual recreation use. 

Use will be restricted to permittees, licensees, rights-of-way holders, Federal government and its’ 

authorized representatives. These routes differ from closed routes in that they will be regularly 

maintained and will not be considered for reclamation. 

Mitigation. Designation as administrative use with appropriate restrictions may reduce potential 

OHV impacts. 

Proliferation and Redundancy 

Route proliferation is clearly prohibited by the 1999 ROD. To the extent practicable, route 

designations should be used to reduce route proliferation. As it applies to this criterion, route 

proliferation pertains to whether the individual route may contribute to unauthorized use and the 

creation of new routes, or whether unauthorized use itself created the route. Determining whether or 

not a route is redundant requires considering several factors, including, RMO/trail type, proximity to 

sensitive resources, resource and user conflicts, proliferation, and contribution to route network. 

Mitigation. Route proliferation can be reduced in some situations by barrier construction. Beyond 

the scope of this Final EIS is the possibility of rerouting a portion of a route to take advantage of 

existing natural or human-made barriers. 

Route Continuity 

Recreation use of OHV’s is the dominant form of recreation in the CCMA. However, a variety of 

recreation uses need to be accommodated through the route designation process. On a given trail, 

these various uses may be in conflict, possibly creating safety concerns in addition to visitor 

frustration. Some routes are dead ends which are advantageous for some uses, such as hunting or 

camping, but may result in route proliferation at the dead end by OHV use. Logically connecting 

routes are emphasized when considering recreational OHV use. Certain dead end routes and spur 

routes may be desirable with appropriate limitations on the use or types of vehicles. 

Mitigation. Rather than arbitrarily close all dead end routes, BLM may install signs letting users 

know the route is a dead end, closed ahead, or designating certain limitations on OHV use. 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

C. Data Element Dictionary 

Tier 1 

1. Private/state lands/mines 

Code Definition 

11000 All BLM. 

11010 Some private, use o.k. 

11020 Some state, use o.k. 

11030 Some mine, use o.k. 

11040 Some private and state, use o.k. 

11050 Some private and mine, use o.k. 

11060 Some state and mine, use o.k. 

11070 Some private, state and mine, use o.k. 

11119 Some private, use NOT o.k. 

11129 Some state, use NOT o.k. 

11139 Some mine, use NOT o.k. 

11149 Some private and state, use NOT o.k. 

11159 Some private and mine, use NOT o.k. 

11169 Some state and mine, use NOT o.k. 

11179 Some private, state and mine, use NOT o.k. 

11111 Some private, use UNKNOWN. 

11121 Some state, use UNKNOWN. 

11131 Some mine, use UNKNOWN. 

11141 Some private and state, use UNKNOWN. 

11151 Some private and mine, use UNKNOWN. 

11161 Some state and mine, use UNKNOWN. 

11171 Some private, state and mine, use UNKNOWN. 

11212 Some private, POTENTIAL MITIGATION 

11222 Some state, POTENTIAL MITIGATION. 

11232 Some mine, POTENTIAL MITIGATION. 

11242 Some private and state, POTENTIAL MITIGATION. 

11252 Some private and mine, POTENTIAL MITIGATION. 

11262 Some state and mine, POTENTIAL MITIGATION. 

11272 Some private, state and mine, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

2. Sensitive species and Cultural 

Code Definition 

12000 No known conflicts. 

12010 Plants nearby, use o.k. 

12020 Animals nearby, use o.k. 

12030 Cultural nearby, use o.k. 

12040 Plants and animals nearby, use o.k. 

12050 Plants and cultural nearby, use o.k. 

12060 Animals and cultural nearby, use o.k. 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

12070 Plants, animals and cultural nearby, use o.k. 

12119 Plants nearby, use NOT o.k. 

12129 Animals nearby, use NOT o.k. 

12139 Cultural nearby, use NOT o.k. 

12149 Plants and animals nearby, use NOT o.k. 

12159 Plants and cultural nearby, use NOT o.k. 

12169 Animals and cultural nearby, use NOT o.k. 

12179 Plants, animals and cultural nearby, use NOT o.k. 

12212 Plants nearby, POTENTIAL MITIGATION. 

12222 Animals nearby, POTENTIAL MITIGATION. 

12232 Cultural nearby, POTENTIAL MITIGATION. 

12242 Plants and animals nearby, POTENTIAL MITIGATION. 

12252 Plants and cultural nearby, POTENTIAL MITIGATION. 

12262 Animals and cultural nearby, POTENTIAL MITIGATION. 

12272 Plants, animals and cultural nearby, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

3. RNA/WSA
 

Code Definition 

13000 No known conflicts. 

13010 RNA nearby, use o.k. 

13020 WSA nearby, use o.k. 

13030 RNA and WSA nearby, use o.k. 

13119 RNA nearby, use NOT o.k. 

13129 WSA nearby, use NOT o.k. 

13139 RNA and WSA nearby, use NOT o.k. 

13212 RNA nearby, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

4. Barrens Interface 

Code Definition 

14000 No known conflicts. 

14010 Barren nearby, use o.k. 

14119 Barren nearby, use NOT o.k. 

14212 Barren nearby, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

5. Riparian Areas 

Code Definition 

15000 No known conflicts. 

15010 Riparian nearby, use o.k. 

15119 Riparian nearby, use NOT o.k. 

15212 Riparian nearby, POTENTIAL MITIGATION. 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

Tier 2 

6. Erosion, Soil Loss Standard 

Code Definition 

16000 No known conflicts (Green) 

16010 Yellow, use o.k. 

16020 Red, use o.k. 

16119 Red, use NOT o.k. 

16212 Red, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

Tier 3 

7. OHV use/use spectrum 

Code Definition 

17000 No known conflicts – contributes to use spectrum. 

17119 Does NOT contribute to use spectrum. 

17010 Recreation Conflicts – Limited Use o.k. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

Tier 4 

8. Route Management Objective (RMO) 

Code Definition 

18000 No known conflicts – manageable given current RMO and funding/staffing 

levels. 

18119 Not manageable due to physical conditions, use NOT o.k. 

18212 Not manageable due to physical conditions, POTENTIAL MITIGATION 

(reroute) 

18222 Not manageable due to RMO, POTENTIAL MITIGATION. 

18232 Not manageable due to funding/staffing, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

9. Admin Use/ROW’s 

Code Definition 

19000 No known conflicts 

19119 Traverses private, no public access, use NOT o.k. 

19129 Unprotected facility, use NOT o.k. 

19212 Private route, POTENTIAL MITIGATION. 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

19222 Unprotected facility, POTENTIAL MITIGATION. 

19139 Other Conflicts (specify below), use NOT o.k. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

10. Route Proliferation/redundancy 

Code Definition 

110000 No known conflicts 

110119 Presently excessive route proliferation, use NOT o.k. 

110129 Route is redundant, use NOT o.k. 

110212 Route proliferation, POTENTIAL MITIGATION. 

110222 Route redundant, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

11. Route Continuity 

Code Definition 

111000 No known conflicts, promotes OHV continuity/connectivity. 

111010 Dead end route, all use o.k. 

111020 Dead end route, Limited Use o.k. 

111119 Dead end route, OHV use NOT o.k. 

111212 Dead end route, POTENTIAL MITIGATION. 

9999 NO DATA AVAILABLE 

TEXT TEXT DESCRIPTION OF MITIGATION PROPOSAL 

D. Route Designation under the Range of Alternatives and the 

Proposed Action 

ALTERNATIVE A & B: ROUTE DESIGNATION 

Under Alternative A, vehicle use in the Planning Area is limited to designated ‘open’ routes and 

designated ‘open play areas’ (i.e. barrens) identified in Appendix A of the 2006 Record of Decision 

(ROD) for the CCMA RMP Amendment and Route Designation. 

Under Alternative B, vehicle use in the Planning Area is limited to designated ‘open’ routes identified 

in Appendix A of the 2006 Record of Decision for the CCMA RMP Amendment and Route Designation. 

All ‘open play areas’ (i.e. barrens) would be designated ‘closed’ to promote overall protection of human 

health and the environment by minimizing the impacts of vehicle use on public land resources and 

conflicts among motorized and non-motorized uses. 

Refer to Appendix A of the 2006 ROD for a complete listing of the vehicle use are and route designations 

under these alternatives. 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

ALTERNATIVE C: ROUTE DESIGNATION TABLE
 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R001 9.4 IMP OPEN* 11010 12212 13010 14212 15010 16010 17000 18000 19000 110000 111000 

R002 6.9 4WD OPEN* 11050 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

R003 0.3 IMP OPEN* 11000 12212 13000 14212 15000 16010 17000 18000 19000 110000 111000 

R004 1.0 4WD CLOSED 11010 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

R005 5.8 4WD OPEN* 11020 12000 13000 14212 15212 16000 17000 18000 19000 110000 111000 

R006 1.0 4WD OPEN* 11000 12000 13000 14010 15212 16212 17000 18000 19000 110000 111000 

R007A 2.25 4WD OPEN* 11000 12000 13000 14212 15010 16212 17000 18000 19000 110000 111010 

R008A 1.5 4WD OPEN* 11000 12212 13000 14212 15212 16212 17000 18000 19000 110000 111000 

R010A 1.6 JEEP OPEN* 11020 12212 13212 14212 15000 16010 17000 18000 19000 110222 111000 

R010B 0.9 4WD OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R011 14.1 JEEP OPEN* 11010 12212 13212 14212 15212 16010 17000 18212 19000 110000 111000 

R013 1.1 JEEP OPEN* 11000 12000 13010 14000 15000 16010 17000 18000 19000 110000 111000 

R014 1.3 IMPR OPEN* 11030 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

R015A 2.7 4WD CLOSED 11010 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R015B 2.1 JEEP CLOSED 11010 12212 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R016 2.5 IMPR CLOSED 11070 9999 13000 14000 15000 16010 17119 18222 19000 110129 111010 

R017 1.8 IMPR OPEN* 11020 12232 13000 14000 15212 16212 17010 18000 19000 110000 111000 

R018 2.8 JEEP OPEN* 11020 12010 13000 14000 15000 16010 17010 18232 19000 110000 111020 

R019C 0.15 JEEP OPEN* 11010 12000 13000 14000 15000 16000 17000 18232 19000 110000 111000 

R019F 0.4 JEEP CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T101 1.5 IMPR OPEN* 11000 12000 13000 14000 15000 16010 17000 18222 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T103 1.4 JEEP OPEN* 11000 12212 13000 14000 15000 16010 17000 18222 19000 110000 111000 

T104 4.5 JEEP OPEN* 11000 12212 13000 14212 15000 16212 17000 18222 19000 110000 111000 

T105 1.0 STT OPEN* 11000 12212 13000 14000 15000 16010 17000 18222 19000 110000 111000 

T106 0.9 ATV CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T107 1.55 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18222 19000 110000 111000 

T108 1.0 STT OPEN* 11000 12000 13000 14000 15212 16010 17000 18222 19000 110000 111000 

T109 0.7 STT OPEN* 11000 12000 13000 14000 15000 16212 17000 18222 19000 110000 111000 

T111 0.9 STT OPEN* 11000 12000 13000 14010 15000 16010 17000 18222 19000 110000 111000 

T112 0.5 STT OPEN* 11000 12212 13000 14212 15000 16212 17000 18222 19000 110000 111000 

T113 1.5 STT OPEN* 11010 12212 13000 14212 15010 16212 17000 18222 19000 110222 111000 

T114 1.2 STT OPEN* 11000 12010 13000 14212 15000 16010 17000 18222 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T115 2.1 STT OPEN* 11010 12212 13000 14212 15000 16212 17000 18222 19000 110000 111000 

T116 2.6 STT OPEN* 11000 12000 13000 14000 15000 16212 17000 18222 19000 110000 111000 

T117 1.3 STT CLOSED 11010 12000 13000 14212 15212 16212 17119 18222 19000 110129 111000 

T119 1.2 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18222 19000 110000 111000 

T120 1.7 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18222 19000 110000 111000 

T121 0.4 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T122 0.5 STT OPEN* 11000 12000 13000 14000 15212 16000 17000 18222 19000 110000 111000 

T123 0.3 STT OPEN* 11000 12212 13000 14000 15212 16000 17000 18222 19000 110000 111000 

T124A 1.5 STT OPEN* 11000 12000 13000 14212 15000 16000 17000 18222 19000 110000 111000 

T127 0.4 STT CLOSED 11010 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T128 1.9 ATV CLOSED 11010 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T129 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T132 1.2 JEEP CLOSED 11010 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T133 0.3 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T134 1.1 STT OPEN* 11000 12212 13000 14212 15212 16010 17000 18000 19000 110000 111000 

T135 1.1 STT OPEN* 11000 12212 13000 14212 15212 16010 17000 18000 19000 110000 111000 

T137 2.7 STT OPEN* 11010 12000 13000 14212 15212 16010 17000 18000 19000 110000 111000 

T138 0.7 STT OPEN* 11000 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

T139 0.8 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T140 0.8 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T141 1.0 STT OPEN* 11030 12000 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T142 0.7 STT OPEN* 11000 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T143 1.3 JEEP CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T147 1.0 STT OPEN* 11000 12212 13000 14212 15000 16010 17000 18000 19000 110000 111000 

T148 1.5 JEEP CLOSED 11020 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T149A 0.3 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T150 1.2 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T151A 5.1 4WD OPEN* 11142 12212 13000 14212 15212 16010 17000 18000 19000 110000 111000 

T153 3.0 JEEP CLOSED 11252 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

T158 A 1.4 4WD OPEN* 11010 12212 13212 14212 15212 16212 17010 18000 19000 110000 111000 

T158B 1.0 4WD CLOSED 11000 12212 13212 14212 15212 16212 17119 18222 19000 110129 111000 

T159 3.5 STT OPEN* 11000 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

T162 0.6 STT OPEN* 11000 12000 13212 14000 15212 16010 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T163 1.5 STT OPEN* 11000 12000 13000 14212 15000 16212 17000 18000 19000 110000 111000 

T164 1.6 STT OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T165 1.0 STT OPEN* 11000 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

T166 5.0 STT OPEN* 11010 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T167 0.8 STT OPEN* 11000 12000 13000 14212 15000 16212 17000 18000 19000 110000 111000 

T168 1.1 STT OPEN* 11010 12000 13000 14000 15000 16212 17000 18000 19000 110000 111000 

T169 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T170 0.4 Paved CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T171A 2.3 ATV CLOSED 11000 12030 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T171B 2.2 JEEP CLOSED 11000 12030 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T175 0.9 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T176 1.1 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T178 2.0 STT OPEN* 11000 12010 13000 14212 15212 16000 17000 18000 19000 110000 111000 

T179 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T181 3.2 STT OPEN* 11000 12010 13000 14000 15212 16212 17000 18000 19000 110000 111000 

T182 0.7 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T183 1.3 STT OPEN* 11000 12000 13000 14000 15000 16212 17000 18000 19000 110000 111000 

T184 6.0 STT OPEN* 11000 12212 13000 14212 15212 16212 17000 18000 19000 110000 111000 

T185 0.6 STT OPEN* 11000 12212 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T189A 0.9 STT OPEN* 11000 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

T189B 0.6 STT OPEN* 11000 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

T189C 3.2 STT OPEN* 11000 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T191 2.1 STT OPEN* 11000 12000 13000 14000 15000 16212 17000 18000 19000 110000 111000 

T192 0.3 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T193 2.8 STT OPEN* 11000 12000 13212 14212 15000 16000 17000 18000 19000 110000 111000 

T194 2.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T195 .8 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T196 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T197 0.5 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T198 2.4 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T199 0.6 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T200 0.6 STT OPEN* 11000 12000 13000 14000 15212 16212 17000 18000 19000 110000 111000 

T201 0.5 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T202 0.6 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T203 1.5 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T204 0.8 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T205 0.8 STT OPEN* 11010 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T206 1.4 STT OPEN* 11000 12000 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T206 1.3 JEEP OPEN* 11232 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T207 0.4 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T208 2.3 STT OPEN* 11010 12000 13000 14000 15000 16212 17000 18000 19000 110000 111000 

T209 2.0 ATV OPEN* 11000 12000 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T210 1.6 STT OPEN* 11000 12000 13000 14000 15212 16000 17000 18000 19000 110000 111000 

T211 1.2 STT OPEN* 11000 12000 13000 14000 15212 16212 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T213 1.5 ATV OPEN* 11000 12000 13000 14000 15212 16000 17000 18000 19000 110000 111000 

T214 0.4 STT OPEN* 11000 12000 13000 14000 15000 16212 17000 18000 19000 110000 111000 

T215 1.1 ATV OPEN* 11000 12000 13000 14000 15212 16000 17000 18000 19000 110000 111000 

T216 2.3 ATV OPEN* 11000 12000 13000 14000 15212 16000 17000 18000 19000 110000 111000 

T216 3.8 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T218 1.5 STT OPEN* 11000 12212 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T219 1.1 ATV OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T220 3.6 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T221 .7 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T222 0.8 STT OPEN* 11020 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T223 0.70 STT OPEN* 11020 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

31
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T224 1.7 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T225 1.1 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T226 1.6 STT OPEN* 11000 12212 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T227 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T228 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T229 0.7 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T230 0.1 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T231 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T232 0.3 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T233 0.3 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T234 0.7 ATV OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

32
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T235 1.5 STT OPEN* 11000 12000 13000 14000 15000 16212 17000 18000 19000 110000 111000 

T236 1.0 STT OPEN* 11000 12000 13000 14000 15212 16000 17000 18000 19000 110000 111000 

T237 1.8 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T238 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T239 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T241 0.6 STT CLOSED 11010 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T243 1.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T244 0.5 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T245 0.7 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T246 0.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T247 0.3 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

33
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T248 0.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T249 0.23 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T250 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T251 0.3 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T252 0.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T253 0.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T254 0.4 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T255 0.38 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T256 0.43 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T257 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T258 0.36 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

34
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T259 0.39 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T260 0.3 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T261 0.87 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T262 0.11 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T263 0.61 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T264 0.66 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

T265 0.24 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR017 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR070 0.21 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR111 0..32 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR200 0.29 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

35
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR208 0.84 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR241 0.29 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR245 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR326 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR327 0..31 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR385 0.08 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR396 0.14 STT OPEN* 11000 12000 13000 14000 15000 16000 17110 18000 19000 110000 

OR438 0.1 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR439 0.1 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR485 0.19 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR488 0.38 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

36
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR516 0.22 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR565 0.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17110 18000 19000 110000 

OR 610 0.2 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 611 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 612 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 613 0.02 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 614 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 615 0.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 616 0.03 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 617 0.01 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 619 0.07 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

37
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 635 0.27 JEEP OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 642 0.39 STT OPEN* 11000 12212 13000 14000 15000 16010 17000 18000 19000 110000 111000 

OR 707 0.14 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 714 0.65 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 715 0.33 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 716 0.10 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 743 0.18 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 751 0.06 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 752 0.10 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 755 0.24 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 759 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

38
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 784 0.97 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 786 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 788 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111119 

OR 794 0.20 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 795 0.40 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 810 0.32 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 825 0.22 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 826 0.18 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 827 0.44 STT OPEN* 11000 12000 13000 14000 15000 16002 17000 18000 19000 110000 111000 

OR 830 0.14 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 831 0.59 STT OPEN* 11000 12000 13000 14000 15000 16002 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

39
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route 

Designation 

Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 836 0.14 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 839 0.10 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 844 0.2 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

OR 865 0.15 STT OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

ALTERNATIVE D: ROUTE DESIGNATION TABLE
 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R001 9.4 IMPR OPEN* 11010 12212 13010 14212 15010 16010 17000 18000 19000 110000 111000 

R002A 2.5 4WD OPEN* 11050 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

40
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R002B 4.6 4WD CLOSED 11050 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010B 0.93 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

R011A 1.9 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011B 9.5 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011C 2.6 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011D .15 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R013 1.1 IMPR CLOSED 11000 12000 13010 14000 15000 16010 17119 18222 19000 110129 111000 

R014 1.3 IMPR OPEN* 11030 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

R015A 2.7 IMPR OPEN* 11010 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

R015B 2.1 IMPR OPEN* 11010 12212 13000 14212 15212 16000 17000 18000 19000 110000 111000 

R016 2.5 JEEP OPEN* 11070 9999 13000 14000 15000 16010 17000 18000 19000 110000 111010 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

41
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R017 1.8 IMPR OPEN* 11020 12232 13000 14000 15212 16212 17010 18000 19000 110000 111000 

R018 2.8 IMPR OPEN* 11020 12010 13000 14000 15000 16010 17010 18000 19000 110000 111020 

T103 1.4 IMPR CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T104A 1.1 IMPR CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T104B 3.4 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T151BSegment 1.8 IMPR CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T153 1.5 IMPR OPEN* 11252 12212 13212 14212 15000 16010 17000 18000 19000 110000 111000 

T153 1.5 IMPR CLOSED 11252 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

T158A 0.5 IMPR CLOSED 11000 12212 13212 14212 15212 16212 17119 18222 19000 110129 111000 

T171A 2.3 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T171B 2.2 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

42
 
 

 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T219 1.1 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T220 3.6 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

T221 0.7 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

R003 0.3 4WD CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R004 1.0 4WD CLOSED 11010 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

R005 5.8 4WD CLOSED 11020 12000 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R006 1.0 4WD CLOSED 11000 12000 13000 14010 15212 16212 17119 18222 19000 110129 111000 

R007A 2.1 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111010 

R007B 1.8 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111000 

R008A 1.5 4WD CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

R008B 2.0 4WD CLOSED 11010 12212 13000 14212 15212 16119 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

43
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R009 0.9 IMPR CLOSED 11010 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010A 1.6 JEEP CLOSED 11020 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

R010C 2.7 JEEP CLOSED 11000 12149 13119 14000 15000 16000 17119 18222 19000 110129 111000 

R012 0.4 4WD CLOSED 11000 12000 13212 14000 15000 16000 17119 18222 19000 110129 111000 

R019A 6.8 IMPR CLOSED 11139 12119 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019B 1.4 IMPR CLOSED 11139 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019C 0.2 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

R019F 0.4 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T101 1.5 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T105 1.0 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T106 0.9 ATV CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

44
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T107 1.55 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T108 1.0 ATV CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T109 0.7 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T111 0.9 JEEP CLOSED 11000 12000 13000 14010 15000 16010 17119 18222 19000 110129 111000 

T112 0.5 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T113 1.5 ATV CLOSED 11010 12212 13000 14212 15010 16212 17119 18222 19000 110129 111000 

T114 1.2 STT CLOSED 11000 12010 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T115 2.1 JEEP CLOSED 11010 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T116 2.6 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T117 1.3 STT CLOSED 11010 12000 13000 14212 15212 16212 17119 18222 19000 110129 111000 

T119 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

45
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T120 1.7 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T121 0.4 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T122 0.5 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T123 0.3 STT CLOSED 11000 12212 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T124A 1.5 STT CLOSED 11000 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T127 0.4 STT CLOSED 11010 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T128 1.9 ATV CLOSED 11010 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T129 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T132 1.2 JEEP CLOSED 11010 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T133 0.3 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T134 1.1 JEEP CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

46
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T135 1.1 STT CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T137 2.7 STT CLOSED 11010 12000 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T138 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T139 0.8 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T140 0.8 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T141 1.0 JEEP CLOSED 11030 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T142 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T143 1.3 JEEP CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T147 1.0 JEEP CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T148 1.5 JEEP CLOSED 11020 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T149A 0.3 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

47
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T150 1.2 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T151A 5.1 4WD CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T159 3.5 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T162 0.6 STT CLOSED 11000 12000 13212 14000 15212 16010 17119 18222 19000 110129 111000 

T163 1.5 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T164 1.6 STT CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T165 1.0 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T166 5.0 STT CLOSED 11010 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T167 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T168 1.1 JEEP CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T169 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

48
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T170 0.4 Paved CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T175 0.9 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T176 1.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T178 2.0 ATV CLOSED 11000 12010 13000 14212 15212 16000 17119 18222 19000 110129 111000 

T179 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T181 3.2 STT CLOSED 11000 12010 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T182 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T183 1.3 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T184 6.0 STT CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

T185 0.6 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T189A 0.9 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

49
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T189B 0.6 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189C 3.2 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T191 2.1 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T192 0.3 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T193 2.8 STT CLOSED 11000 12000 13212 14212 15000 16000 17119 18222 19000 110129 111000 

T194 2.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T195 .8 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T196 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T197 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T198 2.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T199 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

50
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T200 0.6 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T201 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T202 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T203 1.5 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T204 0.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T205 0.8 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T206 1.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T206 1.3 JEEP CLOSED 11232 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T207 0.4 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T208 2.3 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T209 2.0 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

51
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T210 1.6 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T211 1.2 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T213 1.5 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T214 0.4 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T215 1.1 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 2.3 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 3.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T218 1.5 STT CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T222 0.8 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T223 0.70 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T224 1.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

52
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T225 1.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T226 1.6 STT CLOSED 11000 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T227 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T228 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T229 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T230 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T231 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T232 0.3 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T233 0.3 4WD CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T234 0.7 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T235 1.5 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

53
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T236 1.0 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T237 1.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T238 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T239 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T241 0.6 STT CLOSED 11010 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T243 1.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T244 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T245 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T246 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T247 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T248 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T249 0.23 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T250 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T251 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T252 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T253 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T254 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T255 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T256 0.43 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T257 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T258 0.36 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T259 0.39 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T260 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T261 0.87 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T262 0.11 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T263 0.61 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T264 0.66 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T265 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR017 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR070 0.21 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR111 0..32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR200 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR208 0.84 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR241 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR245 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR326 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR327 0..31 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR385 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR396 0.14 STT CLOSED 16000 17119 18222 110129 

OR438 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR439 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR485 0.19 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR488 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR516 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR565 0.2 STT CLOSED 16000 17119 18222 110129 

OR 610 0.2 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 611 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 612 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 613 0.02 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 614 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 615 0.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 616 0.03 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 617 0.01 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 619 0.07 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 635 0.27 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 642 0.39 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

OR 707 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 714 0.65 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 715 0.33 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 716 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 743 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 751 0.06 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 752 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 755 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 759 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 784 0.97 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 786 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 788 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111119 

OR 794 0.20 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 795 0.40 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 810 0.32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 825 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 826 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 827 0.44 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 830 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 831 0.59 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 836 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route Route Route Route Designation Route Evaluation Criteria 1,2 

Number Length RMO 

Tier 1 2 3 Tier 4 

Miles 

1 2 3 4 5 6 7 8 9 10 11 

OR 839 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 844 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 865 0.15 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

ALTERNATIVE E: ROUTE DESIGNATION TABLE
 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R001A 2.0 IMPR OPEN* 11010 12212 13010 14212 15010 16010 17000 18000 19000 110000 111000 

R001B 7.4 IMPR CLOSED 11010 12212 13010 14212 15010 16010 17119 18222 19000 110129 111000 

R002 7.1 4WD CLOSED 11050 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010B** 0.93 IMPR OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

R011A 1.9 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011B 9.5 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011C 2.6 IMPR CLOSED 11010 12212 13212 14212 15212 16010 17119 18222 19000 110129 111000 

R011D .15 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R013 1.1 IMPR CLOSED 11000 12000 13010 14000 15000 16010 17119 18222 19000 110129 111000 

R014 1.3 IMPR CLOSED 11030 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R015A 2.7 IMPR CLOSED 11010 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R015B 2.1 IMPR CLOSED 11010 12212 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R016 2.5 JEEP CLOSED 11070 9999 13000 14000 15000 16010 17119 18222 19000 110129 111010 

R017 1.8 IMPR OPEN* 11020 12232 13000 14000 15212 16212 17010 18000 19000 110000 111000 

R018 2.8 IMPR OPEN* 11020 12010 13000 14000 15000 16010 17010 18000 19000 110000 111020 

T103 1.4 IMPR CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T104A 1.1 IMPR CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T104B 3.4 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T151BSegment 1.8 IMPR CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T153 ** 3.0 IMPR OPEN* 11252 12212 13212 14212 15000 16010 17000 18000 19000 110000 111000 

T158A 0.5 IMPR CLOSED 11000 12212 13212 14212 15212 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T171A 2.3 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T171B 2.2 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T219 1.1 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T220 3.6 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

T221 0.7 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

R003 0.3 4WD CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R004 1.0 4WD CLOSED 11010 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

R005 5.8 4WD CLOSED 11020 12000 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R006 1.0 4WD CLOSED 11000 12000 13000 14010 15212 16212 17119 18222 19000 110129 111000 

R007A 2.1 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111010 

R007B 1.8 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R008A 1.5 4WD CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

R008B 2.0 4WD CLOSED 11010 12212 13000 14212 15212 16119 17119 18222 19000 110129 111000 

R009 0.9 IMPR CLOSED 11010 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010A 1.6 JEEP CLOSED 11020 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

R010C 2.7 JEEP CLOSED 11000 12149 13119 14000 15000 16000 17119 18222 19000 110129 111000 

R012 0.4 4WD CLOSED 11000 12000 13212 14000 15000 16000 17119 18222 19000 110129 111000 

R019A 6.8 IMPR CLOSED 11139 12119 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019B 1.4 IMPR CLOSED 11139 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019C 0.2 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

R019F 0.4 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T101 1.5 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T105 1.0 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T106 0.9 ATV CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T107 1.55 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T108 1.0 ATV CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T109 0.7 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T111 0.9 JEEP CLOSED 11000 12000 13000 14010 15000 16010 17119 18222 19000 110129 111000 

T112 0.5 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T113 1.5 ATV CLOSED 11010 12212 13000 14212 15010 16212 17119 18222 19000 110129 111000 

T114 1.2 STT CLOSED 11000 12010 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T115 2.1 JEEP CLOSED 11010 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T116 2.6 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T117 1.3 STT CLOSED 11010 12000 13000 14212 15212 16212 17119 18222 19000 110129 111000 

T119 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T120 1.7 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T121 0.4 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T122 0.5 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T123 0.3 STT CLOSED 11000 12212 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T124A 1.5 STT CLOSED 11000 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T127 0.4 STT CLOSED 11010 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T128 1.9 ATV CLOSED 11010 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T129 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T132 1.2 JEEP CLOSED 11010 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T133 0.3 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T134 1.1 JEEP CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T135 1.1 STT CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T137 2.7 STT CLOSED 11010 12000 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T138 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T139 0.8 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T140 0.8 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T141 1.0 JEEP CLOSED 11030 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T142 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T143 1.3 JEEP CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T147 1.0 JEEP CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T148 1.5 JEEP CLOSED 11020 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T149A 0.3 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T150 1.2 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T151A 5.1 4WD CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T159 3.5 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T162 0.6 STT CLOSED 11000 12000 13212 14000 15212 16010 17119 18222 19000 110129 111000 

T163 1.5 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T164 1.6 STT CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T165 1.0 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T166 5.0 STT CLOSED 11010 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T167 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

69
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T168 1.1 JEEP CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T169 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T170 0.4 Paved CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T175 0.9 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T176 1.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T178 2.0 ATV CLOSED 11000 12010 13000 14212 15212 16000 17119 18222 19000 110129 111000 

T179 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T181 3.2 STT CLOSED 11000 12010 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T182 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T183 1.3 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T184 6.0 STT CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T185 0.6 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T189A 0.9 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189B 0.6 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189C 3.2 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T191 2.1 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T192 0.3 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T193 2.8 STT CLOSED 11000 12000 13212 14212 15000 16000 17119 18222 19000 110129 111000 

T194 2.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T195 .8 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T196 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T197 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T198 2.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T199 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T200 0.6 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T201 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T202 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T203 1.5 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T204 0.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T205 0.8 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T206 1.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T206 1.3 JEEP CLOSED 11232 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T207 0.4 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T208 2.3 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T209 2.0 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T210 1.6 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T211 1.2 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T213 1.5 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T214 0.4 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T215 1.1 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 2.3 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 3.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T218 1.5 STT CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T222 0.8 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T223 0.70 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T224 1.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T225 1.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T226 1.6 STT CLOSED 11000 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T227 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T228 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T229 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T230 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T231 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T232 0.3 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T233 0.3 4WD CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T234 0.7 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T235 1.5 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T236 1.0 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T237 1.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T238 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T239 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T241 0.6 STT CLOSED 11010 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T243 1.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T244 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T245 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T246 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

75
 
 

 

 

 

 

 

 

Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T247 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T248 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T249 0.23 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T250 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T251 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T252 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T253 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T254 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T255 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T256 0.43 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T257 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T258 0.36 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T259 0.39 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T260 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T261 0.87 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T262 0.11 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T263 0.61 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T264 0.66 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T265 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR017 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR070 0.21 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR111 0..32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR200 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR208 0.84 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR241 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR245 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR326 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR327 0..31 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR385 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR396 0.14 STT CLOSED 16000 17119 18222 110129 

OR438 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR439 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR485 0.19 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR488 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR516 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR565 0.2 STT CLOSED 16000 17119 18222 110129 

OR 610 0.2 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 611 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 612 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 613 0.02 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 614 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 615 0.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 616 0.03 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 617 0.01 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 619 0.07 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 635 0.27 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 642 0.39 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

OR 707 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 714 0.65 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 715 0.33 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 716 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 743 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 751 0.06 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 752 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 755 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 759 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 784 0.97 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 786 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 788 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111119 

OR 794 0.20 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 795 0.40 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 810 0.32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 825 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 826 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 827 0.44 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 830 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 831 0.59 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 836 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 839 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 844 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 865 0.15 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

ALTERNATIVES F & G: ROUTE DESIGNATION TABLE
 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R001 2.0 IMPR OPEN* 11010 12212 13010 14212 15010 16010 17000 18000 19000 110000 111000 

R001 7.4 IMPR CLOSED 11010 12212 13010 14212 15010 16010 17119 18222 19000 110129 111000 

R002 7.1 4WD CLOSED 11050 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010B 0.93 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

R011A 1.9 IMPR CLOSED 11010 12212 13212 14212 15212 16010 17119 18222 19000 110129 111000 

R011B 9.5 IMPR CLOSED 11010 12212 13212 14212 15212 16010 17119 18222 19000 110129 111000 

R011C 2.6 IMPR CLOSED 11010 12212 13212 14212 15212 16010 17119 18222 19000 110129 111000 

R011D .15 IMPR CLOSED 11010 12212 13212 14212 15212 16010 17119 18222 19000 110129 111000 

R013 1.1 IMPR CLOSED 11000 12000 13010 14000 15000 16010 17119 18222 19000 110129 111000 

R014 1.3 IMPR CLOSED 11030 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R015A 2.7 IMPR CLOSED 11010 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R015B 2.1 IMPR CLOSED 11010 12212 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R016 2.5 JEEP CLOSED 11070 9999 13000 14000 15000 16010 17119 18222 19000 110129 111010 

R017 1.8 IMPR OPEN* 11020 12232 13000 14000 15212 16212 17010 18000 19000 110000 111000 

R018 2.8 IMPR OPEN* 11020 12010 13000 14000 15000 16010 17010 18000 19000 110000 111020 

T103 1.4 IMPR CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T104A 1.1 IMPR CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T104B 3.4 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T151BSegment 1.8 IMPR CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T153 3.0 IMPR CLOSED 11252 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

T158A 0.5 IMPR CLOSED 11000 12212 13212 14212 15212 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T171A 2.3 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T171B 2.2 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T219 1.1 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

T220 3.6 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

T221 0.7 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

R003 0.3 4WD CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R004 1.0 4WD CLOSED 11010 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

R005 5.8 4WD CLOSED 11020 12000 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R006 1.0 4WD CLOSED 11000 12000 13000 14010 15212 16212 17119 18222 19000 110129 111000 

R007A 2.1 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111010 

R007B 1.8 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R008A 1.5 4WD CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

R008B 2.0 4WD CLOSED 11010 12212 13000 14212 15212 16119 17119 18222 19000 110129 111000 

R009 0.9 IMPR CLOSED 11010 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010A 1.6 JEEP CLOSED 11020 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

R010C 2.7 JEEP CLOSED 11000 12149 13119 14000 15000 16000 17119 18222 19000 110129 111000 

R012 0.4 4WD CLOSED 11000 12000 13212 14000 15000 16000 17119 18222 19000 110129 111000 

R019A 6.8 IMPR CLOSED 11139 12119 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019B 1.4 IMPR CLOSED 11139 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019C 0.2 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

R019F 0.4 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T101 1.5 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T105 1.0 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T106 0.9 ATV CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T107 1.55 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T108 1.0 ATV CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T109 0.7 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T111 0.9 JEEP CLOSED 11000 12000 13000 14010 15000 16010 17119 18222 19000 110129 111000 

T112 0.5 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T113 1.5 ATV CLOSED 11010 12212 13000 14212 15010 16212 17119 18222 19000 110129 111000 

T114 1.2 STT CLOSED 11000 12010 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T115 2.1 JEEP CLOSED 11010 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T116 2.6 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T117 1.3 STT CLOSED 11010 12000 13000 14212 15212 16212 17119 18222 19000 110129 111000 

T119 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T120 1.7 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T121 0.4 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T122 0.5 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T123 0.3 STT CLOSED 11000 12212 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T124A 1.5 STT CLOSED 11000 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T127 0.4 STT CLOSED 11010 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T128 1.9 ATV CLOSED 11010 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T129 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T132 1.2 JEEP CLOSED 11010 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T133 0.3 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T134 1.1 JEEP CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T135 1.1 STT CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T137 2.7 STT CLOSED 11010 12000 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T138 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T139 0.8 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T140 0.8 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T141 1.0 JEEP CLOSED 11030 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T142 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T143 1.3 JEEP CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T147 1.0 JEEP CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T148 1.5 JEEP CLOSED 11020 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T149A 0.3 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T150 1.2 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T151A 5.1 4WD CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T159 3.5 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T162 0.6 STT CLOSED 11000 12000 13212 14000 15212 16010 17119 18222 19000 110129 111000 

T163 1.5 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T164 1.6 STT CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T165 1.0 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T166 5.0 STT CLOSED 11010 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T167 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T168 1.1 JEEP CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T169 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T170 0.4 Paved CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T175 0.9 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T176 1.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T178 2.0 ATV CLOSED 11000 12010 13000 14212 15212 16000 17119 18222 19000 110129 111000 

T179 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T181 3.2 STT CLOSED 11000 12010 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T182 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T183 1.3 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T184 6.0 STT CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T185 0.6 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T189A 0.9 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189B 0.6 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189C 3.2 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T191 2.1 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T192 0.3 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T193 2.8 STT CLOSED 11000 12000 13212 14212 15000 16000 17119 18222 19000 110129 111000 

T194 2.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T195 .8 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T196 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T197 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T198 2.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T199 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T200 0.6 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T201 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T202 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T203 1.5 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T204 0.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T205 0.8 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T206 1.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T206 1.3 JEEP CLOSED 11232 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T207 0.4 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T208 2.3 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T209 2.0 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T210 1.6 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T211 1.2 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T213 1.5 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T214 0.4 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T215 1.1 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 2.3 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 3.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T218 1.5 STT CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T222 0.8 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T223 0.70 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T224 1.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T225 1.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T226 1.6 STT CLOSED 11000 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T227 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T228 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T229 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T230 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T231 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T232 0.3 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T233 0.3 4WD CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T234 0.7 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T235 1.5 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T236 1.0 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T237 1.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T238 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T239 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T241 0.6 STT CLOSED 11010 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T243 1.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T244 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T245 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T246 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T247 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T248 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T249 0.23 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T250 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T251 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T252 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T253 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T254 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T255 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T256 0.43 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T257 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T258 0.36 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T259 0.39 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T260 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T261 0.87 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T262 0.11 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T263 0.61 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T264 0.66 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T265 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR017 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR070 0.21 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR111 0..32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR200 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR208 0.84 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR241 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR245 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR326 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR327 0..31 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR385 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR396 0.14 STT CLOSED 16000 17110 18222 110129 

OR438 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR439 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR485 0.19 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR488 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR516 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR565 0.2 STT CLOSED 16000 17110 18222 110129 

OR 610 0.2 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 611 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 612 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 613 0.02 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 614 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 615 0.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 616 0.03 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 617 0.01 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 619 0.07 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 635 0.27 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 642 0.39 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

OR 707 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 714 0.65 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 715 0.33 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 716 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 743 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 751 0.06 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 752 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 755 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 759 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 784 0.97 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 786 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 788 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111119 

OR 794 0.20 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 795 0.40 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 810 0.32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 825 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 826 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 827 0.44 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 830 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 831 0.59 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 836 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 839 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 844 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 865 0.15 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Proposed RMP and Final EIS – Volume II 

PROPOSED ACTION: ROUTE DESIGNATION TABLE
 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R001 9.4 IMPR OPEN* 11010 12212 13010 14212 15010 16010 17000 18000 19000 110000 111000 

R010B** 0.93 IMPR OPEN* 11000 12000 13000 14000 15000 16000 17000 18000 19000 110000 111000 

R011A 1.9 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011B 9.5 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R011C 2.6 IMPR CLOSED 11010 12212 13212 14212 15212 16119 17119 18222 19000 110129 111000 

R011D .15 IMPR OPEN* 11010 12212 13212 14212 15212 16010 17000 18000 19000 110000 111000 

R013 1.1 IMPR OPEN* 11000 12000 13010 14000 15000 16010 17000 18000 19000 110000 111000 

R014 1.3 IMPR OPEN* 11030 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

R015A 2.7 IMPR OPEN* 11010 12000 13000 14212 15000 16010 17000 18000 19000 110000 111000 

R015B 2.1 IMPR OPEN* 11010 12212 13000 14212 15212 16000 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R017 1.8 IMPR OPEN* 11020 12232 13000 14000 15212 16212 17010 18000 19000 110000 111000 

R018 2.8 IMPR OPEN* 11020 12010 13000 14000 15000 16010 17010 18000 19000 110000 111020 

T103 1.4 IMPR OPEN* 11000 12212 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T104A 1.1 IMPR OPEN* 11000 12212 13000 14212 15000 16212 17000 18000 19000 110000 111000 

T104B 3.4 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T151BSegment 1.8 IMPR OPEN* 11142 12212 13000 14212 15212 16010 17000 18000 19000 110000 111000 

T153 ** 3.0 IMPR OPEN* 11252 12212 13212 14212 15000 16010 17000 18000 19000 110000 111000 

T158A 0.5 IMPR OPEN* 11000 12212 13212 14212 15212 16212 17010 18000 19000 110000 111000 

T171A 2.3 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T171B 2.2 JEEP OPEN* 11000 12030 13000 14000 15000 16010 17000 18000 19000 110000 111000 

T219 1.1 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19000 110000 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T220 3.6 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

T221 0.7 JEEP OPEN* 11000 12000 13000 14000 15212 16010 17000 18000 19222 110000 111000 

R002 6.9 4WD CLOSED 11050 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R003 0.3 4WD CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

R004 1.0 4WD CLOSED 11010 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

R005 5.8 4WD CLOSED 11020 12000 13000 14212 15212 16000 17119 18222 19000 110129 111000 

R006 1.0 4WD CLOSED 11000 12000 13000 14010 15212 16212 17119 18222 19000 110129 111000 

R007A 2.1 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111010 

R007B 1.8 JEEP CLOSED 11000 12000 13000 14212 15010 16212 17119 18222 19000 110129 111000 

R008A 1.5 4WD CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

R008B 2.0 4WD CLOSED 11010 12212 13000 14212 15212 16119 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

R009 0.9 IMPR CLOSED 11010 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

R010A 1.6 JEEP CLOSED 11020 12212 13212 14212 15000 16010 17119 18222 19000 110129 111000 

R010C 2.7 JEEP CLOSED 11000 12149 13119 14000 15000 16000 17119 18222 19000 110129 111000 

R012 0.4 4WD CLOSED 11000 12000 13212 14000 15000 16000 17119 18222 19000 110129 111000 

R016 2.5 JEEP CLOSED 11070 9999 13000 14000 15000 16010 17119 18222 19000 110129 111010 

R019A 6.8 IMPR CLOSED 11139 12119 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019B 1.4 IMPR CLOSED 11139 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

R019C 0.2 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

R019F 0.4 IMPR CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T101 1.5 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T105 1.0 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T106 0.9 ATV CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T107 1.55 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T108 1.0 ATV CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T109 0.7 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T111 0.9 JEEP CLOSED 11000 12000 13000 14010 15000 16010 17119 18222 19000 110129 111000 

T112 0.5 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T113 1.5 ATV CLOSED 11010 12212 13000 14212 15010 16212 17119 18222 19000 110129 111000 

T114 1.2 STT CLOSED 11000 12010 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T115 2.1 JEEP CLOSED 11010 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T116 2.6 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T117 1.3 STT CLOSED 11010 12000 13000 14212 15212 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T119 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T120 1.7 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T121 0.4 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T122 0.5 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T123 0.3 STT CLOSED 11000 12212 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T124A 1.5 STT CLOSED 11000 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

T127 0.4 STT CLOSED 11010 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T128 1.9 ATV CLOSED 11010 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T129 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T132 1.2 JEEP CLOSED 11010 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T133 0.3 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T134 1.1 JEEP CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T135 1.1 STT CLOSED 11000 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T137 2.7 STT CLOSED 11010 12000 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T138 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T139 0.8 JEEP CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T140 0.8 JEEP CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T141 1.0 JEEP CLOSED 11030 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T142 0.7 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T143 1.3 JEEP CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T147 1.0 JEEP CLOSED 11000 12212 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T148 1.5 JEEP CLOSED 11020 12000 13000 14212 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T149A 0.3 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T150 1.2 JEEP CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T151A 5.1 4WD CLOSED 11142 12212 13000 14212 15212 16010 17119 18222 19000 110129 111000 

T159 3.5 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T162 0.6 STT CLOSED 11000 12000 13212 14000 15212 16010 17119 18222 19000 110129 111000 

T163 1.5 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T164 1.6 STT CLOSED 11000 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T165 1.0 STT CLOSED 11000 12000 13000 14212 15000 16010 17119 18222 19000 110129 111000 

T166 5.0 STT CLOSED 11010 12000 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T167 0.8 STT CLOSED 11000 12000 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T168 1.1 JEEP CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T169 1.2 ATV CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T170 0.4 Paved CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T175 0.9 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T176 1.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T178 2.0 ATV CLOSED 11000 12010 13000 14212 15212 16000 17119 18222 19000 110129 111000 

T179 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T181 3.2 STT CLOSED 11000 12010 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T182 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T183 1.3 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T184 6.0 STT CLOSED 11000 12212 13000 14212 15212 16212 17119 18222 19000 110129 111000 

T185 0.6 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix II 

Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T189A 0.9 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189B 0.6 JEEP CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T189C 3.2 ATV CLOSED 11000 12212 13000 14212 15000 16212 17119 18222 19000 110129 111000 

T191 2.1 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T192 0.3 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T193 2.8 STT CLOSED 11000 12000 13212 14212 15000 16000 17119 18222 19000 110129 111000 

T194 2.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T195 .8 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T196 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T197 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T198 2.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Proposed RMP and Final EIS – Volume II 

Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T199 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T200 0.6 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T201 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T202 0.6 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T203 1.5 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T204 0.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T205 0.8 STT CLOSED 11010 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T206 1.4 STT CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T206 1.3 JEEP CLOSED 11232 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T207 0.4 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T208 2.3 STT CLOSED 11010 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T209 2.0 ATV CLOSED 11000 12000 13000 14000 15000 16010 17119 18222 19000 110129 111000 

T210 1.6 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T211 1.2 STT CLOSED 11000 12000 13000 14000 15212 16212 17119 18222 19000 110129 111000 

T213 1.5 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T214 0.4 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T215 1.1 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 2.3 ATV CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T216 3.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T218 1.5 STT CLOSED 11000 12212 13000 14000 15212 16010 17119 18222 19000 110129 111000 

T222 0.8 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T223 0.70 STT CLOSED 11020 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T224 1.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T225 1.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T226 1.6 STT CLOSED 11000 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T227 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T228 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T229 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T230 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T231 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T232 0.3 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T233 0.3 4WD CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T234 0.7 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T235 1.5 STT CLOSED 11000 12000 13000 14000 15000 16212 17119 18222 19000 110129 111000 

T236 1.0 STT CLOSED 11000 12000 13000 14000 15212 16000 17119 18222 19000 110129 111000 

T237 1.8 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T238 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T239 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T241 0.6 STT CLOSED 11010 12212 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T243 1.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T244 0.5 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T245 0.7 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T246 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T247 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T248 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T249 0.23 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T250 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T251 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T252 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T253 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T254 0.4 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T255 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T256 0.43 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T257 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T258 0.36 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

T259 0.39 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T260 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T261 0.87 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T262 0.11 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T263 0.61 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T264 0.66 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

T265 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR017 0.1 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR070 0.21 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR111 0..32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR200 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR208 0.84 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR241 0.29 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR245 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR326 0.25 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR327 0..31 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR385 0.08 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR396 0.14 STT CLOSED 16000 17119 18222 110129 

OR438 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR439 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR485 0.19 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR488 0.38 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR516 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR565 0.2 STT CLOSED 16000 17119 18222 110129 

OR 610 0.2 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 611 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 612 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 613 0.02 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 614 0.1 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 615 0.1 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 616 0.03 ATV CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 617 0.01 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 619 0.07 IMPR CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 635 0.27 JEEP CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 642 0.39 STT CLOSED 11000 12212 13000 14000 15000 16010 17119 18222 19000 110129 111000 

OR 707 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 714 0.65 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 715 0.33 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 716 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 743 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 751 0.06 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 752 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 755 0.24 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 759 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route 

Number 

Route 

Length 

Miles 

Route 

RMO 

Route Designation Route Evaluation Criteria 1,2 

Tier 1 2 3 Tier 4 

1 2 3 4 5 6 7 8 9 10 11 

OR 784 0.97 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 786 0.3 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 788 0.1 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111119 

OR 794 0.20 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 795 0.40 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 810 0.32 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 825 0.22 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 826 0.18 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 827 0.44 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

OR 830 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 831 0.59 STT CLOSED 11000 12000 13000 14000 15000 16002 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Route Route Route Route Designation Route Evaluation Criteria 1,2 

Number Length RMO 

Tier 1 2 3 Tier 4 

Miles 

1 2 3 4 5 6 7 8 9 10 11 

OR 836 0.14 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 839 0.10 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 844 0.2 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

OR 865 0.15 STT CLOSED 11000 12000 13000 14000 15000 16000 17119 18222 19000 110129 111000 

Route Evaluation Criteria: 1, Private/state lands/mines; 2, Sensitive Species and Cultural; 3, RNA/WSA; 4, Barrens Interface; 5, 

Riparian Areas; 6, Erosion, Soil Loss Standard; 7, OHV use/use spectrum; 8, RMO; 9, Admin Use/ROW’s; 10, Route 

Proliferation/redundancy; 11, Route Continuity. 

* Designated routes are “OPEN” subject to the “LIMITED” vehicle use area designations under each alternative. Refer to 

Chapter 2 for specific limits on vehicle use under each alternative, including the Proposed Action (i.e. access by permit only, 

highway-licensed vehicles, etc.)
 

** Indicates route/segment to be combined with another route for new naming (i.e. T153 will become R11 since R011C is to be
 

designated closed)
 

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Clear Creek Management Area Appendix III 

Proposed RMP and Final EIS – Volume II 

Appendix III - San Benito Mountain Research Natural Area 

Management Plan
 

The San Benito Mountain Research Natural Area (SBMRNA), located within the Clear Creek 

Management Area (CCMA), was designated by the BLM in 1999 to encourage research and 

provide protection of the unique conifer forest and vegetation communities on and around San 

Benito Mountain (BLM 1999). The boundaries of the existing SBMRNA were subsequently 

expanded as identified in the Clear Creek Management Area Resource Management Plan 

Amendment and Route Designation Record of Decision (BLM 2006). This Research Natural 

Area Management Plan guides management of the SBMRNA and identifies management goals 

and objectives that will permit natural processes to continue without interference. 

1.1 Introduction 

The Bureau of Land Management establishes and maintains Research Natural Areas (RNAs) for 

the primary purpose of research and education. RNAs have one or more of the following 

characteristics (43 CFR 8223 – Research Natural Areas): 

 A typical representation of a common plant or animal association;
 

 An unusual representation of a common plant or animal association;
 

 A threatened or endangered plant or animal species;
 

 A typical representation of common geologic, soil, or water features;
 

 Outstanding or unusual geologic, soil, or water features.
 

Dr. James R. Griffin made the original recommendation to establish the San Benito Mountain 

Natural Area in 1970, declaring that “...it would in no way duplicate any North Coast Range 

serpentine natural area and would be a highly desirable contrast with them.” The San Benito 

Mountain Research Natural Area (SBMRNA) has outstanding features including geology, soils, 

ecology, and threatened plant species. 

Ultramafic areas are distributed throughout California, primarily in the Sierra Nevada, Klamath 

Mountains, and Coast Ranges. Ultramafic rock (henceforth referred to as “serpentine”) is an 

igneous rock with very low silica content (less than 45%), generally >18% magnesium oxide, 

high iron oxide, low potassium, and composed of usually greater than 90% mafic minerals (dark 

colored, high magnesium and iron content) (Brooks 1987; Alexander et al. 2007). Ultramafic 

rock types include peridotite and serpentinite (hydrothermally altered). The New Idria 

serpentine mass (synonymous with the BLM designation “Serpentine ACEC”) is outstanding as 

a geologic feature among the serpentine areas of California. It is the largest serpentine area in 

the South Coast Range at approximately 30,000 acres in size. The New Idria serpentine mass 

was formed from peridotite (harzburgite or dunite) which has been completely mineralogicallyaltered, sheared, and crushed to yield a nearly incoherent mass of serpentinite (Coleman 1957, 

1986, 1996; Mumpton and Thompson 1975; Van Baalen 1995). Metamorphism within the New 

Idria serpentine mass has generated several rare serpentinite-associated minerals which the area 

is globally famous for, including fresnoite, joaquinite, neptunite, and benitoite (Louderback 

1907, 1909, Bradley 1909; Pabst 1951; Coleman 1957, 1986; Laird and Albee 1972). The New 

Idria serpentine mass also contains many economically-important minerals including cinnabar 

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Clear Creek Management Area Appendix III 

Proposed RMP and Final EIS – Volume II 

(mercury sulfide), chromite (iron-chromium oxide), and chrysotile asbestos, which have all been 

commercially mined during the past 150 years (Coleman 1957, 1986, 1996; Eckel and Meyers 

1946; Matthews 1961; Merritt 1962). Cinnabar was extensively mined adjacent to the SBMRNA 

(Aurora Mine; San Carlos peak mine pit) when New Idria was active. Due to its unique geology 

and mineral suites, the New Idria serpentine mass is a popular mineral collection locality and 

geological research study site. 

The extremely sheared and pulverized serpentinite bedrock of the New Idria serpentine mass 

weathers to produce soils with adverse chemistry including nutrient deficiency (nitrogen, 

phosphorus, potassium, calcium) and heavy metal toxicity (magnesium, nickel) (Kruckeberg 

1984; Alexander et al. 2007; Arroues 2006; Reinsch and Arroues 2010). The pulverized nature 

of the bedrock, in combination with the extreme adverse soil conditions have resulted in large 

areas of natural, moonscape barrens completely devoid of vegetation. Areas with greater 

stability and more soil development support unique vegetation types including serpentine 

willow/riparian, serpentine chaparral, and mixed conifer forest. The San Benito Mountain mixed 

conifer forest is the only forest in the world that includes Jeffrey (Pinus jeffreyi), Coulter (Pinus 

coulteri), and foothill (Pinus sabiniana) pines, and incense cedar (Calocedrus decurrens) at the 

same location (Griffin 1974). The presence of Jeffrey and Coulter pines in such close proximity 

has resulted in Jeffrey x Coulter pine hybrids (Zobel 1951a, 1951b; Libby 1958; Griffin 1974; 

Ledig 2000). The area comprising the SBMRNA was clear cut when New Idria was active to 

supply mine support timbers (particularly incense cedar) and cord wood to fuel the retorts at 

New Idria (Sloane 1914; Griffin 1974). Very few old growth trees remain in the SBMRNA. 

Chaparral was also extensively cut to supply cord wood for the retorts. Most of the vegetation 

has since recovered and represents secondary forest (Griffin 1974). 

1.2 Planning 

1.2.1 Management Goals 

The following management goals will contribute to preserving the values for which the 

SBMRNA was established: 

	 To protect the globally unique San Benito Mountain mixed conifer forest ecosystem, special 

status species, and the adjacent ecotones in their natural state for science research and 

educational purposes. The San Benito Mountain mixed conifer forest contains conifer tree 

species that occurs nowhere else together in the world (Griffin 1974; Evans et al. 2006). This 

forest also contains many serpentine endemic herb and shrub species. 

	 To define and create an environment for research designed (1) to investigate and better 

understand the geology, biology, ecology, and archaeology, and (2) to build an information 

base for guiding management of this and other serpentine ecosystems on BLM lands. 

	 To allow uses inside the SBMRNA compatible with the primary purpose of the Research 

Natural Area for scientific research and education. 

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1.2.2 Management Objectives 

Management objectives result in actions that the BLM and the public evaluate as measures of 

success in attaining the management goals. Because new information will become a part of 

adaptive management of the SBMRNA and nearby ecosystems, the management objectives may 

evolve over to time to meet legal requirements and public expectations. 

The following list includes management objectives that will contribute to permitting natural 

processes to continue within the SBMRNA: 

	 Include and maintain within management constraints, the core area of the San Benito 

Mountain forest and a buffer with the transitional chaparral/woodland habitats that border 

the Forest for the purpose of conservation. 

	 Establish SBMRNA boundaries on the basis of watershed or other natural features. The 

BLM policy for its Research Natural Areas is to “Permit natural processes to continue 

without interference.” and to “Determine the boundaries for all vegetation series 

representatives. In order to preserve the greatest diversity possible, the boundaries will 

include a variety of elevation, slope, and aspect features, and should follow natural 

boundaries.” 

	 Protect known suboccurrences and potential habitat of San Benito evening primrose and 

provide conditions within the SBMRNA in support of the Recovery Plan that conforms to 

the Biological Opinion for the San Benito evening primrose issued by the U.S. Fish and 

Wildlife Service (FWS 2005). 

	 Protect existing suboccurrences and habitat of all other known BLM sensitive species that 

occur within the SBMRNA boundaries. 

	 Protect all cultural resources and encourage public partnerships for research and 

educational use of the SBMRNA. 

	 Consult with Native Americans from local tribes for management consistent with 

traditional Native American culture and for full tribal participation in planning, research 

and environmental education. 

	 Facilitate quality research overseen by a knowledgeable committee selected from: 

universities and colleges; other private research institutions; the Native American 

community; federal and State of California government research and regulatory agencies; 

and public interest groups and advisory committees. The committee will identify 

research needs and guide proposed research. Establishment and function of the committee 

shall meet the provisions established by the Federal Advisory Committee Act (FACA). 

	 Foster other uses of the SBMRNA that are compatible with its primary purpose. Provide 

for continued authorized uses such as rights-of-way and easements that are compatible 

with management values for the SBMRNA. 

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	 Implement the CCMA Resource Management Plan and Record of Decision as they 

specifically apply to the SBMRNA for the protection and improvement of soil, air, water, 

and biological resources. 

	 Develop a Fire Management Plan for the SBMRNA so that the FMO is aware of the 

sensitive species habitat locations and vehicle access routes. 

	 Develop a barren area monitoring and restoration plan that will enable BLM staff to 

understand factors that influence erosion rates on serpentine barrens in order to reduce 

erosion, sediment transport, and restore vegetation buffers. 

	 Develop a natural resource research program to determine characteristics of the unique 

ecosystem that are important and what the management response will be to changes in 

these characteristics. 

1.3 Natural Resource Inventory 

A comprehensive inventory of the natural resources of SBMRNA is necessary to understand 

what resources are present there and to effectively manage those resources. Natural resources of 

the SBMRNA that have had little to no inventory to date include lichen species, invertebrate 

species, and bat species. 

1.3.1 Air 

The SBMRNA is located within the North Central Coast air basin. Airborne chrysotile asbestos 

originating from the New Idria serpentine mass portion of the SBMRNA has the potential to 

adversely affect human health (EPA 2008). Chrysotile asbestos is classified as a hazardous air 

pollutant under the Clean Air Act Amendments of 1990. 

1.3.2 Water 

The SBMRNA includes four major perennial streams including San Carlos Creek, Clear Creek 

(headwaters), Sawmill Creek, and Cantua Creek (headwaters; Cañada Azul). The streams are 

important habitat for riparian zone plant and animal species of CCMA, some of which are rare 

and federally-listed. All four streams originate from the New Idria serpentine mass. Rocks and 

soils of the New Idria serpentine mass contain chrysotile asbestos as well as high concentrations 

of heavy metals including nickel, chromium, cobalt, and mercury (Dynamac Corporation 1998; 

EPA 2008). Streams of the SBMRNA may transport chrysotile asbestos and mercury in 

sediment loads, adversely impacting wildlife and humans. Clear Creek is classified as an 

impaired watershed due to high levels of mercury. 

1.3.3 Geology and Soils 

The SBMRNA includes the northeastern portion of New Idria serpentine mass and includes a 

flanking portion of the Franciscan formation (sedimentary rock). The geology of CCMA, 

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including the SBMRNA, has been mapped by Eckel and Meyers (1946), Coleman (1961), and 

Van Baalen (1995). The BLM has since mapped (2010 and 2011) serpentine masses (tectonic) 

and serpentine landslides in a high level of detail. 

Large areas of the New Idria serpentine mass (particularly the barrens) are generally mapped as 

Henneke soil series and Igneous rock land in the San Benito county soil survey (Isgrig 1969). 

The USDA Natural Resource Conservation Service (NRCS) recently completed a detailed soil 

survey for the CCMA in San Benito county in 2011 to resolve soil series polygon mapping 

discrepancies across the San Benito - Fresno county line and to more accurately describe soils of 

the New Idria serpentine mass (Reinsch and Arroues 2010). The survey resulted in the 

description of five soil series derived from serpentine including Duckworth, Cascara, Flomack, 

Delmexico, and Idriapeak. Additionally two new soil series derived from nonserpentine 

(sedimentary) rock were described including Sancarlos and Borreguero. 

1.3.4 Lichen Species 

Lichens are present on rocks, shrubs, and trees within the SBMRNA. Globally, information 

about lichens present on serpentine rocks and soil is scarce. Some studies have found lichen 

species that appear to be unique or endemic to serpentine substrates (Sirois et al. 1988; Harris et 

al. 2007). A baseline lichen survey was conducted of serpentine and nonserpentine rocks in the 

CCMA in 2011 (Rajakaruna et al. in press). There were ten collection sites (5 serpentine, 5 

nonserpentine) total distributed throughout the northern CCMA. Three collection localities were 

in close proximity to the SBMRNA: New Idria reservoir (serpentinite; immediately north of the 

SBMRNA), San Benito Mountain peak (serpentinite; within SBMRNA), and San Carlos peak 

(shale; immediately north of the SBMRNA). Of the 119 saxicolous lichen species collected, six 

including Buellia aethalea, Buellia ocellata, Caloplaca oblongula, Rhizocarpon suarinum, 

Thelocarpon laureri, and Trapelia obtegens, are reported new to California. Additionally, an 

apparently previously undescribed Solenopsora sp. is being genetically sequenced to confirm its 

taxonomic status. The rest of the species encountered are relatively frequent in the lichen flora 

of southern and central California, except Aspicilia praecrenata, a lichen considered to be 

extirpated from the South Coast Range. Although 60 of the lichen species sampled from the 10 

collection suites were present only on serpentine rocks, it is unclear if any of the species may be 

regarded as unique or endemic to serpentine. Further studies (more extensive collection 

throughout the CCMA and other nearby serpentine areas) are needed to determine if any 

serpentine endemic lichen species are present. 

1.3.5 Plant Species and Habitats 

The diversity of rare vascular plants is one of the most remarkable features of the CCMA. Rare 

plant species that are known to occur or may occur within the SBMRNA include the federallylisted threatened San Benito evening primrose (Camissonia benitensis); CNPS list 1B rayless 

layia (Layia discoidea), talus fritillary (Fritillaria falcata), San Benito fritillary (Fritillaria 

viridea), Mariposa cryptantha (Cryptantha mariposae), Mt. Diablo phacelia (Phacelia 

phacelioides); and CNPS list 4 Guirado’s goldenrod (Solidago guiradonis), serpentine 

leptosiphon (Leptosiphon ambiguus), San Benito monardella (Monardella antonina ssp. 

benitensis), Hernandez bluecurls (Trichostemma rubisepalum), Andrew’s bedstraw (Galium 

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andrewsii ssp. gatense), Brewer’s blarkia (Clarkia breweri), sulphur flower buckwheat 

(Eriogonum umbellatum var. bahiiforme), one-sided monkeyflower (Mimulus fremontii), and 

Santa Clara thorn mint (Acanthomintha lanceolata). 

Inventories of plant species in the SBMRNA will serve as a baseline for GIS analyses describing 

the ranges of habitat characteristics in which rare plants currently exist, previously existed, or 

might exist under BLM management. These inventories will also serve as a baseline for tracking 

and mapping non-native invasive plants of concern to the BLM and to the California Department 

of Agriculture. 

Existing information sources from herbarium holdings, expert knowledge, and inventory results 

will describe: 

 historically known sites 

 historically known sites outside the CCMA, but useful to define critical habitat features 

inside the CCMA 

 delineation of first approximations of suitable habitat for each rare species 

 plant searches for suitable and occupied habitats 

 refinement of criteria used to delineate suitable and occupied habitats 

 identification of habitat locations that have a high probability to sustain populations 

without directed BLM management or with species-specific directed management. 

1.3.6 Vegetation 

Detailed vegetation classification and mapping has been completed for the SBMRNA and the 

entire CCMA (Evans et al. 2006). 

1.3.6.1 San Benito Mountain Mixed Conifer Forest 

Currently, the USDA Forest Service, Pacific Northwest Research Station Forest Inventory and 

Analysis (FI&A) Program has permanent plots, systematically selected throughout the Pacific 

Coast States. To understand changes in the San Benito Mountain mixed conifer forest, the BLM 

may review data collected over the span of several decades by the Forest Service. 

Small isolated populations of conifer tree species in the Central California Coast Region are 

important globally as genetic resources. Jeffrey pine, Coulter pine, and incense cedar from San 

Benito Mountain resemble island-like distributions analogous to that of Monterey pine in the 

Central Coast Region. As such, they resemble unique genetic sources. Ledig (2000) has found 

that the unique hybrids between Coulter pine and Jeffrey pine from San Benito Mountain, first 

described by Zobel (1951a, 1951b), may have altered the genetic structure of Coulter pines 

through introgression. 

1.3.7 Invertebrate Species 

Little information exists about the diversity or uniqueness of arthropod species present on 

serpentine soils or in streams within the SBMRNA and the entire CCMA. Serpentine endemic 

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insect species have been found at several serpentine areas in California (Harrison and Shapiro 

1988; Gervais and Shapiro 1999; Schwartz and Wall 2001; Boyd 2009). The isolated San Benito 

Mountain mixed conifer forest within the New Idria serpentine mass represents a forest island 

within a geologic island, providing conditions conducive to specialized adaptation and 

speciation. 

1.3.8 Vertebrate Species 

Amphibians and Reptiles 

Perennial creeks including San Carlos Creek, Clear Creek, and Sawmill Creek are known to 

harbor BLM sensitive foothill yellow-legged frog (Rana boylii) and two-striped garter snake 

(Thamnophis hammondii). Uplands in the SBMRNA are habitat for California horned lizard 

(Phrynosoma blainvillii). 

Birds 

San Benito Mountain is an important migratory stop for many rare and infrequently seen bird 

species. The high elevation San Benito Mountain mixed conifer forest provides habitat islands 

for several bird species found nowhere else in the Central Coast Range (Johnson and Cicero 

1985). Rare migratory birds that stop at San Benito Mountain include olive-sided flycatcher 

(Contopus cooperi), loggerhead shrike (Lanis ludovicianus), yellow-breasted chat (Ichteria 

virens), and grasshopper sparrow (Ammodramus savannarum). Other uncommon bird species 

include mountain quail (Oreortyx pictus), gray flycatcher (Empidonax wrightii), Hammond’s 

flycatcher (E. hammondii), California thrasher (Toxostoma redivivum), rufous-crowned sparrow 

(Aimophila ruficeps), Bell’s sage sparrow (Amphispiza belli spp. belli), and black-chinned 

sparrow (Spizella atrogularis). 

Mammals 

Presently, no data are available about bats resident in the SBMRNA or in the rest of the CCMA. 

BLM lands elsewhere in California with a history of mining have frequently become important 

habitats for bats. Abandoned mines host bats, mostly as single-species colonies, and perhaps 

only seasonally as maternity dens, migration rest stops, hibernation sites, and colonial roosts 

during the day. Many bat species are BLM California species of management concern. BLM 

sensitive bats that may be present within the SBMRNA include western mastiff-bat (Eumops 

perotis californicus), Townsend’s western big-eared bat (Corynorhinus townsendi townsendi), 

pallid bat (Antrozus pallidus), Yuma myotis (Myotis yumanensis), long-eared myotis (Myotis 

evotis), fringed myotis (Myotis thysanoides), and small-footed myotis (Myotis ciliolabrum). 

1.4 Natural Resource Monitoring 

Natural resource monitoring is essential to determine how ecological processes and species 

change over time. Monitoring results can be used to interpret effects of human activities. 

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1.4.1 Air 

Wind erosion and aerial suspension of chrysotile asbestos presents a human health risk. 

Sampling and modeling of human health risk for asbestos under natural conditions has been 

conducted at the CCMA by research groups and the EPA (PTI Environmental Services 1992; 

EPA 2008). The BLM has an ongoing air sampling program for monitoring human exposure to 

chrysotile asbestos at the CCMA. BLM employees are required to conduct air monitoring for 

personal exposure to chrysotile asbestos whenever they work within the Serpentine ACEC (New 

Idria serpentine mass). Some air monitoring samples are collected within the SBMRNA. 

1.4.2 Water 

Serpentine rocks and soils of the SBMRNA and CCMA contain high concentrations of heavy 

metals including nickel, chromium, cobalt, and mercury (Kruckeberg 1984; Alexander et al. 

2007; Arroues 2006; Reinsch and Arroues 2010). Clear Creek is classified as an impaired 

watershed due to high levels of mercury. Trends in heavy metal cycling in aquatic ecosystems 

are important to the overall health of the ecosystem. Concentrations of heavy metals often 

display a seasonal pattern in watersheds. In order to manage watersheds to reduce environmental 

pollutants, it is important to know what environmental pollutants exist and what their 

concentrations and seasonal patterns are. The US Geological Survey monitors water from Clear 

Creek at a gauging station near Oak Flat Campground. 

In addition to heavy metals, erosion and liquid-suspended transport of chrysotile asbestos to 

water sources also presents a human health risk. Water transport of asbestos to the California 

Aqueduct from the CCMA was detected in 1980 (EPA 1991). The asbestos was believed to have 

originated from the Atlas Mine and was transported by water in White Creek to Los Gatos Creek 

and finally into the aqueduct. The EPA responded with remediation of the Atlas Mine in order to 

prevent further introduction of asbestos into the aqueduct. Large quantities of chrysotile asbestos 

are transported by water out of CCMA into streams and rivers annually. 

Water quality is best monitored by establishing permanent measurement (gauging) stations. 

Currently, there is no formal program by the BLM to monitor water flow, sediment load, or 

water quality of streams within the SBMRNA or elsewhere in the CCMA. 

1.4.3 Geology and Soils 

Organic matter accumulation is an important factor in serpentine soil development and fertility 

(Alexander et al. 2007). Pioneer plant species such as buckbrush (Ceanothus cuneatus), 

manzanita (Arctostaphylos glauca, A. pungens), and pines (Pinus sabiniana, P. coulteri, and P. 

jeffreyi) can establish on barren serpentine soils and produce large amounts of leaf litter which 

decomposes and becomes incorporated into the soil. Increases in soil organic matter improve soil 

conditions for the establishment of secondary plant species such as leather oak (Quercus durata), 

silktassel (Garrya congdonii), toyon (Heteromeles arbutifolia), and many grass and forb species 

to become established within the serpentine plant community. 

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Little is known about organic matter cycling and accumulation on the serpentine soils of the 

SBMRNA. An understanding of organic matter cycling is important in understanding how 

vegetation becomes established on serpentine soils. Organic matter accumulation is best 

monitored by establishing permanent study plots. 

Soil erosion is of great concern to BLM managers due to the high proportion of natural 

serpentine barrens within the SBMRNA and CCMA. Implementing standardized hydrological 

monitoring for sediment flows and for water quality will provide objective and comparable 

measures of the success of ecosystem management in the SBMRNA to minimize sediment flows 

and erosion. Long-term monitoring results can provide watershed-scale models of water and 

sediment flow, as well as changes to stream channel morphology. Water and sediment flows and 

stream morphology are critical factors in the formation and degradation of rare plant habitat such 

as the stream terraces frequently occupied by San Benito evening primrose. 

Soil erosion can be quantified in two ways including soil depth loss as measured by staff gauge 

grid established upon the area of interest, or collection (basin or silt fence) of the sediment 

eroded from a particular area, downhill of that area. Sediment collection is the easiest method. 

One easy way to measure soil erosion is to establish silt fences at key sites of overland erosion 

(Robichaud and Brown 2002). 

Currently, there is no formal program by the BLM to monitor soil development or erosion within 

the SBMRNA or elsewhere in the CCMA. 

1.4.4 Lichen Species 

Lichens are a sensitive indicator of environmental pollutants. Lichen health can be measured by 

total cover on rock or woody plant surfaces. Lichen colony growth on surfaces can be tracked by 

measuring its diameter. 

Currently, there is no formal program by the BLM to monitor lichen species within the 

SBMRNA or elsewhere in the CCMA. 

1.4.5 Plant Species and Habitats 

Federally-listed plant species – San Benito evening primrose 

Federally-listed threatened San Benito evening primrose has been monitored by the BLM since 

1979. Complete monitoring details for San Benito evening primrose can be found in the San 

Benito evening primrose (Camissonia benitensis) Compliance Monitoring and Adaptive 

Management Plan (Appendix IV) of the Clear Creek Management Area Resource Management 

Plan (2012). Monitoring includes plant counts and documentation of habitat condition. A 

monitoring report is submitted to the Ventura FWS annually. 

San Benito evening primrose is currently monitored by the BLM within the SBMRNA and 

throughout the CCMA. 

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Other rare plant species 

Rare CNPS List 1B species including rayless layia, talus fritillary, and San Benito fritillary are 

currently monitored within the SBMRNA and throughout the CCMA. Monitoring by the BLM 

includes plant counts and documentation of habitat condition. 

1.4.6 Vegetation 

Vegetation is casually monitored by the BLM within SBMRNA and throughout the CCMA to 

evaluate human impacts and prevent non-allowable human uses (logging/woodcutting; off route 

vehicle travel). 

1.4.7 Invertebrate Species 

Monitoring of any BLM sensitive invertebrate species populations discovered within SBMRNA 

and the CCMA may be conducted following inventory. 

1.4.8 Vertebrate Species 

Amphibians and Reptiles 

Foothill yellow-legged frog (Rana boylii) is a BLM sensitive species. Although foothill yellowlegged frog is declining over its entire range, populations in Clear Creek Management Area 

appear to be self-sustaining. The BLM developed a monitoring protocol for foothill yellowlegged frog in 2001 and monitoring is conducted annually throughout the CCMA. 

Birds 

Populations of passerine birds in chaparral and forest are of particular concern because these 

habitats are increasingly rare and fragmented. The high-elevation San Benito Mountain mixed 

conifer forest provides habitat islands for several bird species found nowhere else in the Central 

Coast Range (Johnson and Cicero 1985). Changes in the populations of rare bird species that 

nest in the conifer forest may be an indicator that habitat conditions are changing. 

Breeding bird surveys have been conducted annually by the BLM within the SBMRNA and the 

CCMA since 1995. Species monitored include olive-sided flycatcher (Contopus cooperi), 

loggerhead shrike (Lanis ludovicianus), yellow-breasted chat (Ichteria virens), grasshopper 

sparrow (Ammodramus savannarum), mountain quail (Oreortyx pictus), gray flycatcher 

(Empidonax wrightii), Hammond’s flycatcher (E. hammondii), California thrasher (Toxostoma 

redivivum), rufous-crowned sparrow (Aimophila ruficeps), Bell’s sage sparrow (Amphispiza belli 

spp. belli), and black-chinned sparrow (Spizella atrogularis). 

Mammals 

Monitoring of any BLM sensitive bat species populations discovered in the SBMRNA and the 

CCMA may be conducted following inventory. 

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1.5 Natural Resource Research 

Science supports sustainable resource management of the SBMRNA and CCMA, and provides 

the objective information upon which BLM managers make choices for the benefit of the public. 

The BLM does not presume to have sufficient funding to support research of all natural resource 

types within the SBMRNA. Researchers interested in studying natural resources of the 

SBMRNA come from diverse disciplines and interest groups and from diverse government 

agencies, research institutions, universities in California and other states, and in several 

instances, internationally. The following research topics of interest may be undertaken within 

the SBMRNA: 

1.5.1 Air 

	 Effects of chrysotile asbestos on the health of BLM employees and recreation visitors 

	 Modeling air quality impacts under alternate management scenarios, with special 

reference to the transport of air-borne asbestos, mercury, nitrogen- and sulfur-based 

gases, and ozone 

1.5.2 Water 

	 Influence of the extremely sheared (pulverized) New Idria serpentine mass on local 

hydrology. Curiously, Clear Creek maintains high flow rates year-round, even during 

drought years 

	 Heavy metal and chrysotile asbestos transport and cycling in local streams and rivers 

1.5.3 Geology and Soils 

	 Mineralogy (rare/unique minerals), geology (ultramafic), and tectonics (New Idria thrust 

fault) 

	 Why are the serpentine barrens so barren? Explore factors including geology (pulverized, 

unstable geology), adverse soil characteristics, and interaction with vegetation and human 

land use 

	 Rate of soil formation and soil erosion under different vegetation types and subject to 

different types and levels of human activities 

	 Model soil erosion under alternate management scenarios, with reference to the frequency 

and severity of naturally occurring and human-facilitated erosion 

	 Organic matter accumulation and nutrient cycling 

1.5.4 Lichen Species 

	 Lichen adaptations to adverse physical and chemical conditions imposed by serpentine 

substrates 

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1.5.5 Plant Species and Habitats 

	 Plant adaptations to adverse physical and chemical conditions imposed by serpentine soils 

including macronutrient deficiency (nitrogen, phosphorus, potassium, calcium); 

macronutrient toxicity (magnesium); micronutrient deficiency (molybdenum); 

micronutrient toxicity (nickel), and other heavy metal toxicity (cobalt, chromium, mercury) 

	 Recovery of rare and federally-listed plant species. Research topic focus including optimal 

habitat parameters (soil, vegetation), soil seed bank, seed germination, seedling survival, 

fecundity, breeding system and pollination, demography, animal interactions, competitive 

interactions, population introductions, human impacts, population viability analysis 

	 Invasion by non-native plant species - Ecosystem resistance and management response 

for control on serpentine and nonserpentine soils 

1.5.6 Vegetation 

	 Comparison of vegetation type on serpentine and adjacent nonserpentine soils across the 

geologic boundary. Influence of soil characteristics 

	 Conifer seed collection and ex situ tree breeding 

	 Dendrochronology – demography, historic climate and fire history interpretation 

	 Packrat nest (midden; rock outcrops) and pollen core (Spanish Lake) sampling – historic 

climate interpretation 

	 Model the development of forest vegetation on San Benito Mountain and changes under 

different scenarios of climate change and local human impacts 

	 Reforestation practices to restore logged and burned forests on serpentine soils 

	 Revegetation of serpentine barrens and other drastically disturbed serpentine substrates 

such as asbestos mine tailings 

	 Human history and land use (pre- and post-European settlement) 

1.5.7 Invertebrate Species 

	 Invertebrate adaptations to adverse physical and chemical conditions imposed by 

serpentine substrates 

	 Influence of heavy metals in streams on aquatic invertebrate species 

	 Influence of insects (bark beetles) on the Sam Benito Mountain mixed conifer forest 

1.5.8 Vertebrate Species 

	 Influence of heavy metals in streams on aquatic vertebrate species 

	 Invasion by non-native animal species - Ecosystem resistance and management response 

for control on serpentine and nonserpentine soils 

1.5.9 Partnerships 

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Funding for science at BLM to improve land management has not been a fiscal priority in the 

recent past. BLM cannot depend on internal funding to initiate or support many of the research 

topics. Without investment, tasks for inventories, monitoring protocols, and field research in the 

SBMRNA would proceed slowly. 

The BLM Hollister Field Office staff, and especially its natural resource and recreation 

specialists, can contribute their time and other in-kind services to scientists and researchers who 

wish to conduct research. The Field Office staff can continue to foster a setting of engaged 

inquiry with scientists and researchers at the many government agencies and universities located 

in the counties that surround CCMA. 

One important step to facilitating environmental studies in the CCMA has been assistance 

agreements and memoranda of understanding between the BLM California State Office and the 

University of California and California State University systems, established in 2003. At 

present, the BLM works with the California state natural resource agencies and other federal 

agencies to collaborate on joint watershed planning. The BLM also currently works with 

researchers from the University of California and California State University systems on studies 

of federally-listed plant species recovery, serpentine plant tolerance and evolution and serpentine 

barrens revegetation. Such efforts improve lines of communications between BLM employees 

and interested scientists from regulatory and research agencies and universities. 

The following institutions listed below are active in research that is occurring directly in the 

CCMA or bearing directly on the management issues of the CCMA. The BLM commits itself to 

working to promote the research work of these institutions in the CCMA and to expanding the 

roster of institutions involved. By promoting science in the CCMA, BLM promotes 

improvement of its own management to remain responsive to social and environmental needs for 

sustainable and robust ecosystems. 

Educational Institutions 

University of California System: Berkeley, Davis, Santa Cruz, Merced 

California State University System: San Francisco, San Jose, Stanislaus 

Stanford University 

University of Utah 

California State Agencies 

Department of Fish and Game 

Department of Forestry and Fire Prevention 

Department of Parks and Recreation, Off-Highway Vehicle Recreation Division 

Department of Water Resources (Water Resources Board) 

US Federal Agencies 

Environmental Protection Agency 

National Science Foundation 

US Department of Agriculture, Forest Service, Pacific Northwest Research Station, 

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Forestry Inventory and Analysis Program 

US Department of Agriculture, Forest Service, Pacific Southwest Research Station, 

Institute of Forest Genetics 

US Department of Agriculture, Natural Resource Conservation Service 

US Department of Energy 

US Department of the Interior, Geological Survey, Western Ecological Studies Center 

Governmental Organizations Outside of the United States 

Canadian Geological Survey 

Non-Governmental Non-Profit Agencies 

California Native Plant Society 

California Federation of Mineralogical Societies 

PRBO Conservation Science 

1.6 Fire Management 

Fire objectives will closely approximate the historical and natural fire regime. Any fire that 

occurs in the SBMRNA will be followed by monitoring until the area once again approximates 

its former condition. 

1.6.1 Characteristics 

This Fire Management Unit (FMU) ranges in elevation from 2000 to over 5000 feet. The highest 

peak in the FMU is San Benito Mountain at 5,241 feet. The FMU contains nonserpentine 

chaparral, serpentine barrens, serpentine chaparral, and mixed conifer forest. The FMU contains 

several rare plant species including San Benito evening primrose, rayless layia, talus fritillary, 

and San Benito fritillary. 

1.6.2 Fire History 

Fire history for the SBMRNA may be characterized as one of minimal to infrequent fires, as a 

result of low fuel loads on the low-productivity serpentine soils and barren landscape. Fire 

ignition is primarily caused by lightning, but the potential for fires caused by humans also exists. 

Serpentine and nonserpentine chaparral poses potential for extreme fire behavior. Fire use and 

prescribed fire have been used in the past to maintain and promote uneven-aged brush fields to 

natural conditions. 

1.6.3 Fire Management Objectives 

1)	 Manage the habitat for threatened and endangered plant and animal species to maintain 

viable populations in their natural ecosystems. 

2)	 Promote natural conditions within SBMRNA plant communities. 

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3)	 Restore and maintain structure, species composition, and processes of native ecological 

communities and existing ecosystems. 

4)	 Maintain air quality to meet or exceed applicable federal and state standards and regulations. 

5)	 Use fire to restore and/or sustain ecosystem health based on sound scientific principles and 

information, balanced with other societal goals, including public health and safety, and air 

quality. 

Management Emphasis – T&E Plants and BLM Sensitive Plants: 

1)	 Protect and improve potential habitat for special status plant species and the San Benito 

Mountain mixed conifer forest. 

2)	 Provide a mosaic of plant community seral stages. 

3)	 Improve native plant community diversity and structure. 

Suppression Objectives: 

1)	 Natural fires should be allowed to burn if they meet fire objectives. Fire retardants and 

scarification for fire lines or breaks should be avoided. A resource advisor from the 

Hollister Field Office must be notified before any retardant drops are planned from 

aircraft. 

2)	 Fire will be managed for the protection of sensitive resource values, including the San 

Benito Mountain mixed conifer forest. 

3)	 Use existing roads and natural barriers as the preferred method for containment and 

control of wildfire in the FMU. 

4)	 The Monterey Air Board must be notified when any earth disturbance activities occur to 

conform to the Air Toxic Control Measures (ATCM). 

5)	 The potential for the BLM to inherit the wildfire after the first 24 hours of suppression 

may be possible if objectives are not being met in accordance with the RMP and FMP. 

Fire Use and Prescribed Fire Objectives: 

1)	 Prescribed fire may be used to sustain desired characteristics. Specific seasonal timing, 

patch size, yearly total and rotational time for chaparral type fuel is to be coordinated 

with resource personnel. 

2)	 Fuels treatment may be considered as needed by a site-specific plan. Allow the use of 

prescribed fire to promote natural conditions. 

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3)	 Use prescribed fire, wildland fires, and mechanical and chemical treatments to protect 

and maintain rare, threatened, and endangered plants and habitat, prevent the spread of 

invasive plants, and benefit chaparral components important to wildlife. 

4)	 Construct hand line and natural fuel breaks and control lines for firing only when 

necessary, to preserve natural fire regimes. 

5)	 Protect and enhance the San Benito Mountain mixed conifer forest within the SBMRNA. 

6)	 All local and state air quality objectives will be met prior to ignition of prescribed fires. 

Post Fire Rehabilitation and/or Restoration Objectives: 

1)	 Immediately initiate post-fire rehabilitation and restoration to stabilize rare, threatened, 

and/or endangered plant habitat. 

2)	 Prevent soil erosion and flooding by constructing water bars and installing erosion 

control (straw bales, straw rolls) on fire lines and fuel breaks. 

3)	 Reseed with a diversity of locally-collected native plant seed in appropriate sites for 

species, if needed. 

4)	 Monitor for and control invasive plant species. 

Fire Management Strategies: 

1)	 Use of Appropriate Management Response (AMR) to manage all fires for management 

objectives and based on current conditions and fire location. 

2)	 Prevent wildland fires from spreading to private land and the communication site on San 

Benito Mountain. 

3)	 Use natural barriers for containment. 

4)	 Restore and Rehabilitate fire suppression lines created during fire suppression efforts in a 

timely manner to prevent erosion and stabilize sensitive habitat. 

Implement the full range of wildland fire fuels management practices, provided they will 

contribute to historical and natural fire patterns. BLM’s appropriate management response will 

address areas where plant communities are at high risk due to current conditions or other 

ecological constraints. Appropriate management response strategies will address critical habitat 

for wildlife, T&E species, areas of soil instability, and preservation of cultural resources. Use 

appropriate management response to prevent wildland fires from spreading to private and other 

agency lands outside the SBMRNA. Once the decadal burn target of 300 acres has been reached 

from either planned or unplanned ignitions, a review of objectives and strategies will lead to new 

suppression criteria on all wildland fires. 

The appropriate management response is to prevent wildland fires from spreading to private land 

and to the repeater tower on San Benito Mountain. Suppression is coordinated between BLM 

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and CDF. The FMU is within Local Responsibility Area where the State provides direct 

protection under contract with the agency. Due to the presence of naturally-occurring asbestos in 

the FMU, however, CDF will not enter the SBMRNA. Instead, CDF will assume a support 

function outside of the FMU, to prevent further spread of wildfire. If resources are needed for 

suppression within the FMU, local red carded firefighters with hazardous asbestos health and 

safety training and other required training can enter the asbestos area. Additional resources will 

also need the proper training if extended fire suppression is required. Aerial application and the 

use of natural barriers is the choice for containment within the FMU. This FMU has very limited 

accessibility by land. 

Wildfire for Resource Benefits 

Management of wildfire for resource benefit is a fire management option within this FMU. 

Allow wildlfire to burn to promote natural conditions is identified as a component of research 

conducted within the SBMRNA. Established natural barriers may be able to hold fire within 

certain areas, depending on time of year, fuel loading, weather, location, and firefighting 

resources on hand, and if safety concerns have been addressed and mitigated. 

1.7 Allowable Uses 

Uses inconsistent with the preservation of the values for which the SBMRNA was designated 

will be discouraged. Recreation and access must conform to management actions identified in 

the Proposed RMP (i.e. Proposed Action) and be consistent with SBMRNA management 

objectives. Activities involving organized events or commercial activities will need written 

authorization. 

All uses will be in accordance with 43 CFR 8223.1 

1) No person shall use, occupy, construct, or maintain facilities in a research natural area except 

as permitted by law, other Federal regulations, or authorized under provisions of 43 CFR 

8223. 

2) No person shall use, occupy, construct, or maintain facilities in a manner inconsistent with 

the purpose of the research natural area. 

3) Scientists and educators shall use the area in a manner that is non-destructive and consistent 

with the purpose of the research natural area. 

1.8 References 

Alexander EB, Coleman RG, Keeler-Wolf T, and SP Harrison. 2007. Serpentine geoecology of 

western North America. Oxford University Press, New York, New York. 512 pp. 

Arroues KD. 2006. Soil survey of Fresno county, California, western part. United States 

Department of Agriculture, Natural Resource Conservation Service, Washington, DC, USA. 

1144 pp. 

Boyd RS. 2009 High-nickel insects and nickel hyperaccumulator plants: A review. Insect 

Science 16:19-31. 

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Bradley WM. 1909. On the analysis of the mineral neptunite from San Benito county, 

California. American Journal of Science 28:15-16. 

Brooks RR. 1987. Serpentine and its vegetation. Dioscorides Press, Portland, Oregon. 454 pp. 

Bureau of Land Management (BLM). 1999. Clear Creek Management Area Plan Amendment 

and Final Environmental Impact Statement (FEIS). Hollister Field Office. Hollister, 

California, USA. 

Bureau of Land Management (BLM). 2006. Clear Creek Management Area Resource 

Management Plan Amendment and Route Designation. Hollister Field Office. Hollister, 

California, USA. 

Coleman RG. 1957. Mineralogy and petrology of the New Idria District, California. PhD 

thesis. Stanford University, Palo Alto, California, USA. 160 pp. 

Coleman RG. 1961. Jadeite deposits of the Clear Creek area, New Idria District, San Benito 

County, California. Journal of Petrology 2:209-247. 

Coleman RG. 1986. Field trip guide book to New Idria Area, California. 14th General Meeting 

of the International Mineralogical Association, July 1986. 36 pp. 

Coleman RG. 1996. New Idria serpentinite: A land management dilemma. Environmental and 

Engineering Geoscience 2:9-22. 

Dynamac Corporation Environmental Services. 1998. Geomorphic field evaluation of 

serpentinite soil barrens, Clear Creek Management Area. Dynamac Corporation 

Environmental Services, Rockville, Maryland, USA. 81 pp. 

Eckel EB and WB Myers. 1946. Quicksilver deposits of the New Idria district, San Benito and 

Fresno Counties, California. California Journal of Mines and Geology 42:81-124. 

Evans J, Klein A, Taylor J, Keeler-Wolf T, and D Hickson. 2006. Vegetation classification, 

descriptions, and mapping of the Clear Creek Management Area, Joaquin Ridge, and the 

environs in San Benito and western Fresno counties, California. California Native Plant 

Society and California Department of Fish and Game, Sacramento, California. 273 pp. 

Gervais BR and AM Shapiro. 1999. Distribution of edaphic-endemic butterflies in the Sierra 

Nevada of California. Global Ecology and Biogeography 8:151-162. 

Griffin JR. 1974. A strange pine and cedar forest in San Benito county. Fremontia 2:11-15. 

Harris TB, Olday FC, and N Rajakaruna. 2007. Lichens of Pine Hill, a peridotite outcrop in 

eastern North America. Rhodora 109:430-447. 

Harrison S and AM Shapiro. 1988. Butterflies of northern California serpentines. Fremontia 

15:17-20. 

Isgrig D. 1969. Soil survey, San Benito county, California. United States Department of 

Agriculture, Soil Conservation Service. 200 pp. 

Johnson NK and C Cicero. 1985. The breeding avifauna of San Benito Mountain, California: 

Evidence for change over one-half century. Western Birds 16:1-23. 

Kruckeberg AR. 1984. California serpentines: Flora, vegetation, geology, soils, and 

management problems. University of California Press, Berkeley, California, USA. 180 pp. 

Laird J and AL Albee. 1972. Chemical composition and physical, optical, and structural 

properties of benitoite, neptunite, and joaquinite. American Mineralogist 57:85-102. 

Ledig FT. 2000. Founder effects and the genetic structure of Coulter pine. Journal of Heredity 

91:307-315. 

Libby WJ. 1958. The backcross hybrid Jeffrey x (Jeffrey x Coulter) pine. Journal of Forestry 

56:840-842. 

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Louderback GD 1907 Benitoite, a new California gem mineral. University of California 

Publication, Bulletin of the Department of Geology 5:149-153. 

Louderback GD 1909 Benitoite, its paragenesis and mode of occurrence. University of 

California Publication, Bulletin of the Department of Geology 5:331-380. 

Matthews RA. 1961. Geology of the Butler Estate Chromite Mine. California Division of 

Mines and Geology. Special Report 71. 20 pp. 

Merritt PC. 1962. California asbestos goes to market. Mining Engineering 14:57-60. 

Mumpton FA and CS Thompson. 1975. Mineralogy and origin of the Coalinga asbestos 

deposit. Clays and Clay Minerals 23:131-143. 

Pabst A. 1951. Minerals of the serpentine area in San Benito county. California Rocks & 

Minerals 26:478-485. 

PTI Environmental Services. 1992. Human health risk assessment for the Clear Creek 

Watershed, San Benito River Basin, Central California, prepared for the U.S. Department of 

the Interior, Bureau of Land Management under contract C871-08. 

Rajakaruna N, Knudsen K, Fryday AM, O’Dell RE, Pope N, Olday FC, and S Woolhouse (in 

press) Influence of rock type on saxicolous lichen communities of the New Idria 

serpentinite mass, San Benito County, California, USA. The Lichenologist. 

Reinsch T and K Arroues. 2010. Chemical characteristics of serpentinitic soils of Clear Creek 

Management Area, California. Poster. ASA, CSSA, and SSSA 2010 International Annual 

Meetings. Oct. 31 – Nov. 4. Long Beach, California, USA. 

Robichaud PR and RE Brown. 2002. Silt fences: An economical technique for measuring 

hillslope erosion. General Technical Report RMRS-GTR-94. USDA Forest Service, Rock 

Mountain Research Station, Ft. Collins, Colorado, USA. 24 pp. 

Schwartz MD and MA Wall. 2001. Melanotrichus boydi, a new species of plant bug 

(Heteroptera: Miridae: Orthotylini) monophagic on the nickel hyperaccumulator 

Streptanthus polygaloides (Brassicaceae). Pan-Pacific Entomologist 77:39-44. 

Sirois L, Lutzoni F, and MM Grandtner. 1988. The lichens of the Mount Albert serpentine and 

amphibolite plateau, Gaspé peninsula, Quebec. Canadian Journal of Botany 66:851-862. 

Sloane NH. 1914. Resources and plan of operation of Monterey National Forest. United States 

Department of Agriculture. 381 pp. 

United States Environmental Protection Agency (EPA). 2008. Clear Creek Management Area 

asbestos exposure and human health risk assessment. San Francisco, California, USA. 

http://www.epa.gov/region09/toxic/noa/clearcreek/index.html 

United States Environmental Protection Agency (EPA). 1991. Record of decision for the Atlas 

Mine Area Operable Unit of the Atlas Asbestos Mine Superfund Site. San Francisco, 

California, USA. 

United States Fish and Wildlife Service (FWS). 2005. Biological opinion for the Clear Creek 

Management Area Resource Management Plan Amendment and Final Environmental 

Impact Statement, San Benito and Fresno Counties, California (1-8-05-F-20). September 2, 

2005. 

Van Baalen MR. 1995. The New Idria serpentinite. PhD dissertation. Harvard University, 

Cambridge, Massachusetts, USA. 482 pp. 

Zobel BJ. 1951a. The natural hybrid between Coulter and Jeffrey pines. PhD. Dissertation. 

University of California, Berkeley, California, USA. 114 pp. 

Zobel BJ. 1951b. The natural hybrid between Coulter and Jeffrey pines. Evolution 5:405-413. 

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Appendix IV - Camissonia benitensis Compliance 

Monitoring & Adaptive Management Plan 

1.0 Introduction 

San Benito evening primrose (Camissonia benitensis) is a federally-listed Threatened 

plant species which occurs on Bureau of Land Management (BLM) public lands in the 

Clear Creek Management Area (CCMA). The Endangered Species Act requires that all 

Federal agencies ensure that management actions do not jeopardize the continued 

existence of any threatened or endangered species. 

San Benito evening primrose is a strict serpentine (ultramafic rock) endemic found on 

serpentine alluvial stream terraces and on the margins of tectonic serpentine masses and 

serpentine landslides (serpentine geologic transition zone) in southern San Benito county, 

western Fresno county, and eastern Monterey county, California (BLM 2010). Only 10 

suboccurrences of San Benito evening primrose were known at the time of federal listing 

in 1985 (USFWS 1985; Figure IV-1). The primary threat to the species identified at 

listing was Off-Highway Vehicle (OHV) impacts. Additional identified threats included 

other recreational activities (camping and rockhounding/mineral prospecting), road 

construction and maintenance, and gravel mining. Most of the suboccurrences known at 

the time of listing were located in the vicinity of heavily-impacted OHV areas (staging 

areas) on serpentine alluvial stream terraces in Clear Creek Canyon within Clear Creek 

Management Area (CCMA; Kiguchi 1985). Serpentine alluvial stream terraces were 

believed to be the only habitat type for the species. By 2009, all serpentine alluvial 

stream terrace habitat in the Clear Creek Management Area had been exhaustively 

surveyed for San Benito evening primrose, resulting in a total of 64 known natural 

suboccurrences (BLM 2009; Figure IV-1). Five of the 64 suboccurrences were 

(re)introductions made in 1990 and 1991 (Taylor 1993). Additionally, another six 

suboccurrences were introduced (new introductions) in 2008 for a total of 70 

suboccurrences (BLM 2009). Many miles of fence and pipe barriers had been 

constructed to prevent OHV impacts to San Benito evening primrose and an OHV route 

designation (BLM 2006) further reduced OHV impacts. 

The discovery that San Benito evening primrose also grows on serpentine geologic 

transition zone habitat (edges of tectonic serpentine masses and serpentine landslides; 

uplands) in 2010, followed by intensive survey of that habitat type on both BLM and 

private land resulted in the discovery of another 295 natural suboccurrences for a total of 

361 suboccurrences known by 2011 (5x increase from 2009; BLM 2010; Figure IV-1). 

New suboccurrence finds on private lands doubled the known species range (Figure IV2). Of the 361 total suboccurrences known, 196 suboccurrences are located within 

CCMA and 165 suboccurrences are located outside of CCMA (Table IV-1). Most of the 

newly discovered suboccurrences do not appear to have experienced any significant 

historic or recent human impacts, as a result of their location (largely outside of most 

areas intensively used by OHVs) and landscape position (often steep and brushy areas). 

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Figure IV-1 Suboccurrences of San Benito evening primrose within and in the vicinity of Clear Creek Management Area. 

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Figure IV-2 Previously known ranges, current known range, and estimated actual range of San Benito evening 

primrose. Estimated actual range is based upon field surveys of potential habitat. 

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Table IV-1 Number of currently known San Benito evening primrose suboccurrences, habitat type, 

location, and land ownership. 

The San Benito evening primrose Compliance Monitoring and Adaptive Management Plan will 

improve the BLM’s ability to manage CCMA in a manner that promotes the long-term 

conservation of San Benito evening primrose and makes efficient use of staffing and funding. 

This document outlines specific actions and refines the protocol to be used in monitoring San 

Benito evening primrose occupied and potential habitat areas within CCMA. This monitoring 

program documents disturbance to San Benito evening primrose habitat by tracking the type and 

intensity of threats to the species and its habitat to assess the status of the species over time and 

determine if adaptive management is needed. 

This monitoring program builds upon existing BLM documents and strategies that have 

established protocol for compliance monitoring and FWS Biological Opinions for San Benito 

evening primrose within CCMA (BLM 1997a, 1997b, 2003, 2005, 2006; USFWS 1997, 2005). 

2.0 Definitions 

2.1 Population Terminology 

Population: Traditionally, a plant population has been defined as a group of individuals of the 

same species occupying an area of habitat small enough to permit interbreeding among all 

members of the group (Barbour et al. 1998; Silvertown and Charlesworth 2001). This can be 

referred to as the biological population definition. Due to the difficulty in circumscribing a 

biological population, biologists have more recently departed from the traditional biological 

population definition and now define a population without the criteria of interbreeding. This 

definition of a population is particularly applicable to San Benito evening primrose since the 

species is almost exclusively self-pollinating (Taylor 1990). California Natural Diversity 

Database dispensed of the term “population” and now uses the term “occurrence” instead (as 

defined below). The terms “occurrence” and “suboccurrence”, therefore, are used to describe 

groups of populations and a single population, respectively, of San Benito evening primrose. 

Occurrence: Equivalent to a group of populations. An occurrence is comprised of more than 

one suboccurrence of San Benito evening primrose that are all located within 1⁄4 mile of each 

other. 

Suboccurrence: Equivalent to a single population. A suboccurrence is a group of San Benito 

evening primrose plants that occur within a specific localized area differing noticeably in habitat 

characteristics (slope, aspect) from any other group of San Benito evening primrose plants within 

the same occurrence. There are currently 361 known suboccurrences of San Benito evening 

primrose of which, 196 are located within CCMA. 186 of the 196 known suboccurrences within 

CCMA were monitored in 2011. Only 92 of the 196 suboccurrences within CCMA are assigned 

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a number designating occurrence-suboccurrence relationship to other suboccurrences. The other 

104 suboccurrences discovered in CCMA in 2010 and 2011 are known only by global 

positioning satellite (GPS) coordinates of their locations. 

2.2 Habitat Terminology 

Serpentine alluvial stream terrace: Alluvial terrace created by the deposition of primarily 

serpentine sediment, adjacent to a stream or river channel (Figure IV-3). Serpentine alluvial 

stream terraces are topographically limited to low points (valleys) as a result of their depositional 

setting. San Benito evening primrose typically grows on older serpentine alluvial stream terraces 

where there is no longer active sediment deposition or significant erosion (stable). 

Figure IV-3. Serpentine alluvial stream terrace. Serpentine alluvium eroded from the New Idria 

serpentine mass (visible in upper right corner) was carried by White Creek (visible at far right) and 

deposited on the stream bank as a terrace. San Benito evening primrose grows on the serpentine alluvial 

stream terrace. 

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Serpentine geologic transition zone: Geologic boundary between serpentine and non-serpentine 

rocks (sedimentary or non-ultramafic, metamorphic). The boundary may exist 1) between 

tectonic serpentine masses and non-serpentine rocks (Figure IV-4), 2) between serpentine 

landslides originating from tectonic serpentine masses and non-serpentine rocks, or 3) between 

ancient (>10,000 year old) serpentine alluvial deposits (elevated on hillslopes) and nonserpentine rocks. There is no topographic position limit for serpentine geologic transiton zone. 

It can occur in valleys, on hillslopes, or high on ridges. Vegetation type often dramatically 

changes at the geologic transition zone from dense chaparral to sparse chaparral or blue oak 

woodland. San Benito evening primrose grows on serpentine soils in open gaps of woody 

vegetation at the edges of tectonic serpentine masses and serpentine landslides in the serpentine 

geologic transition zone. 

Figure IV-4. Serpentine geologic transition zone. Serpentine (blue, barren substrate) interfaces with 

non-serpentine rocks (supporting dense annual grassland and blue oak woodland). San Benito evening 

primrose grows on the barren serpentine substrate. 

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Occupied habitat: The area occupied by a suboccurrence. 92 suboccurrences of San Benito 

evening primrose are assigned a suboccurrence number with the extent of occupied habitat 

digitally mapped in geographic information systems (GIS). The other 104 suboccurrences have 

not been assigned a number and are only known only by GPS coordinates of their locations with 

the extent of occupied habitat mapped in GIS. 

Potential habitat: Localized areas of serpentine alluvial stream terraces and serpentine geologic 

transition zone judged to have habitat conditions conducive to supporting San Benito evening 

primrose. Most potential habitat of San Benito evening primrose within CCMA and other areas 

within its known range has been mapped in GIS. Areas of potential habitat are generally, but not 

always, adjacent to occupied habitat. Conditions conducive to supporting San Benito evening 

primrose have been determined from observations of habitat conditions present where the species 

has been found. Conducive habitat conditions include: 1) serpentine soil on stream terraces 

(serpentine alluvial stream terrace habitat) or at the edges of tectonic serpentine masses and 

serpentine landslides (serpentine geologic transition zone habitat), 2) woody vegetation with 

open gaps, 3) presence of other common indicator companion herbaceous species to San Benito 

evening primrose, and 4) low density of invasive annual herbaceous plant species (Taylor 1990; 

USFWS 2006; BLM 2010). San Benito evening primrose has been found on two other distinct 

habitat types including serpentine rock outcrops (2 suboccurrences) and shale outcrops/barrens 

(5 suboccurrences) within- or close proximity to the New Idria serpentine mass (BLM 2010). 

The rock outcrops have habitat conditions similar to geologic transition zone habitat, but it is 

unclear what additional specific habitat conditions on rock outcrops dictate whether they are 

conducive to supporting San Benito evening primrose. Due to this uncertainty, no potential 

habitat has been mapped for serpentine rock outcrops or shale rock outcrops/barrens. 

2.3 Noncompliance Terminology 

Baseline: Baseline conditions noted the previous monitoring visit. The habitat conditions 

documented during the previous monitoring visit are the baseline for the following monitoring 

visit. 

Non-compliance: Motorized and non-motorized trespass and unauthorized use in occupied 

and/or potential habitat. 

Incident: A non-compliant incident is unauthorized human disturbance (impact) to habitat that is 

observed and is a change from the previous monitoring visit. Each visit is relative to the baseline 

condition from the previous monitoring visit. 

Disturbance: Disturbance (impacts) to San Benito evening primrose occupied and/or potential 

habitat resulting from human activities. Disturbances can directly impact San Benito evening 

primrose by damaging plants or degrading their habitat. Motorized disturbance sources (Table 

IV-2) include, but are not limited to: automobiles (full-sized vehicle), all-terrain vehicles 

(ATVs; quads; four wheelers), utility vehicles (UTVs; side by sides), motorcycles (primarily dirt 

bikes), and tractors (tracked vehicles; caterpillars). OHV disturbances are the most common 

human disturbance to San Benito evening primrose at CCMA and the primary threat for which 

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the species was listed (USFWS 1985). Non-motorized disturbance sources (Table IV-3) 

include, but are not limited to: bicycles (primarily mountain bikes) and other non-motorized 

vehicles, camping, rockhounding/mineral prospecting, logging/wood cutting, concentrated 

human foot traffic (trailing), concentrated livestock traffic (trailing), and waste (garbage) 

dumping. The primary habitat disturbances (immediate impacts) from single incidents of 

motorized and non-motorized activities are soil surface disturbance (tracks), soil subsurface 

disturbance (in the case of activities involving digging), and vegetation damage and/or removal. 

Multiple incidents of these disturbances (depending on type, intensity, and degree of 

localization), can result in greater chronic (long-term) habitat impacts including soil compaction, 

soil erosion, and areas denuded of vegetation. 

Table IV-2. Motorized disturbance sources and primary habitat impacts. 

Impact↓ Disturbance source→ Automobile ATV/UTV Motorcycle Tractor

Soil surface (tracks) X X X X

Soil subsurface (digging) X

Vegetation (damage/removal) X X X X

Table IV-3. Non-motorized disturbance sources and primary habitat impacts. 

Disturbance source→ Bicycles &

other non- Rock hounding/ Concentrated Concentrated

motorized mineral Logging/wood human foot livestock Waste

Impact↓ vehicles Camping prospecting cutting traffic (trail) traffic (trail) dumping

Soil surface (tracks) X X X X X X X*

Soil subsurface (digging) X

Vegetation (damage/removal) X X X X X X

*material surface occupancy

and/or chemical contamination

It should be noted that not all human disturbances are regarded as adverse to San Benito evening 

primrose. There is strong evidence that some light to moderate level of human disturbance is 

beneficial to San Benito evening primrose (BLM 2009). Several San Benito evening primrose 

suboccurrences coincide with several prehistoric (Native American) and historic (European 

settler) human habitation sites on serpentine alluvial stream terraces (BLM 2009). Human 

habitation at those sites has been judged to have been beneficial to San Benito evening primrose 

through the removal of woody vegetation (reduction of plant competition) and increase in soil 

fertility (increased organic matter content). In addition to modifying vegetation and soils to 

promote San Benito evening primrose, humans may have also played a role in the dispersal of 

the species. The seeds of San Benito evening primrose are as small as grains of sand and may be 

dispersed in mud stuck to humans, livestock, and vehicles. Livestock grazing may be beneficial 

to San Benito evening primrose by removing competing vegetation. Wildfire is beneficial to San 

Benito evening primrose by removing competing vegetation (BLM 2009). Prescribed fire used 

by the BLM to control invasive yellow starthistle (Centaurea solstitialis) at the confluence of 

Clear Creek and San Benito River has resulted in the (re)colonization of San Benito evening 

primrose in that area. 

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3.0 Habitat and Compliance Monitoring Program 

The monitoring year for San Benito evening primrose begins June 1 and ends June 1 the 

following year. Minimum habitat and compliance monitoring frequency will occur annually 

(coincident with plant counts). Monitoring frequency may be increased in response to increased 

visitor use and/or increased incidence of non-compliance. 

3.1 Plant Counts 

Plant counts will be conducted annually April – May (peak flowering). San Benito evening 

primrose can have large variation (up to four orders of magnitude) in the number of plants from 

year to year. San Benito evening primrose plants will be directly counted for each suboccurrence 

monitored where suboccurrences are 1000 plants in size or less. For suboccurrences 1000 plants 

in size or greater, if plant density is fairly even, the count for a small area can be extrapolated to 

the entire suboccurrence. If the distribution and density are uneven, estimates can be made based 

upon random plots. 

3.2 Habitat Condition and Compliance Monitoring 

San Benito evening primrose occupied and potential habitat monitoring will include 

documentation of significant human disturbances (impacts) as listed in Table IV-2 and IV-3. 

Documentation of disturbances will include the following: 

 Suboccurrence impacted (identify by suboccurrence number or GPS coordinate) and 

whether the disturbance occurred within occupied and/or potential habitat. 

 Type (source) of disturbance. 

 Intensity of disturbance. Description of the extent of the disturbance (number of 

tracks/trails; estimated area of disturbed soil and/or vegetation). 

 Photodocumentation of the disturbance. 

The BLM will respond to incidents of non-compliance with a hierarchical approach. Signs and 

barriers will be used in situations of low to moderate levels of noncompliance. Area closures 

may be enacted in situations of high levels of non-compliance (heavy, repeated impacts to 

numerous suboccurrences). Area closures will be determined in consultation with Ventura FWS. 

Any enacted closures within CCMA will be conducted in accordance with The Endangered 

Species Act of 1973, 43 CFR 8341.2, and 43 CFR 8341.1. 

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Endangered Species Act of 1973 

(d) Protective Regulations.- Whenever any species is listed as a threatened species pursuant to 

subsection (c) of this section, the Secretary shall issue such regulations as he deems necessary 

and advisable to provide for the conservation of such species. The Secretary may by regulation 

prohibit with respect to any threatened species any act prohibited under section 9(a)(1), in the 

case of fish or wildlife, or section 9(a)(2) in the case of plants, with respect to endangered 

species; except that with respect to the taking of resident species of fish or wildlife, such, 

regulations shall apply in any State which has entered into a cooperative agreement pursuant to 

section 6(c) of this Act only to the extent that such regulations have also been adopted by such 

State. 

43 CFR 8341.2 Special Rules 

(a) Notwithstanding the consultation provisions in Sec. 8342.2(a), where the authorized officer 

determines that off-road vehicles are causing or will cause considerable adverse effects upon 

soil, vegetation, wildlife, wildlife habitat, cultural resources, historical resources, threatened or 

endangered species, wilderness suitability, other authorized uses, or other resources, the 

authorized officer shall immediately close the areas affected to the type(s) of vehicle causing the 

adverse effect until the adverse effects are eliminated and measures implemented to prevent 

recurrence. Such closures will not prevent designation in accordance with procedures in subpart 

8342 of this part, but these lands shall not be opened to the type(s) of off-road vehicle to which it 

was closed unless the authorized officer determines that the adverse effects have been eliminated 

and measures implemented to prevent recurrence. 

(b) Each State director is authorized to close portions of the public lands to use by off-road 

vehicles, except those areas or trails which are suitable and specifically designated as open to 

such use pursuant to subpart 8342 of this part. 

43 CFR 8364.1 Closure and Restrictions 

(a) To protect persons, property, and public lands and resources, the authorized 

officer may issue an order to close or restrict use of designated public lands. 

(b) Each order shall: 

(1) Identify the public lands, roads, trails or waterways that are closed to entry or restricted as 

to use; 

(2) Specify the uses that are restricted; 

(3) Specify the period of time during which the closure or restriction shall apply; 

(4) Identify those persons who are exempt from the closure or restrictions; 

(5) Be posted in the local Bureau of Land Management Office having jurisdiction over the 

lands to which the order applies; 

(6) Be posted at places near and/or within the area to which the closure or restriction applies, 

in such manner and location as is reasonable to bring prohibitions to the attention of users; 

(7) Include a statement on the reasons for the closure; and 

(c) In issuing orders pursuant to this section, the authorized officer shall publish them in the 

Federal Register. 

(d) Any person who fails to comply with a closure or restriction order issued under this subpart 

may be subject to the penalties provided in Sec. 8360.0–7 of this title. 

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3.3 Reporting 

Monitoring reports will be generated annually and submitted to the Ventura FWS. The report 

will summarize ongoing management to protect San Benito evening primrose suboccurrences 

and potential habitat on BLM land within CCMA. 

Reports will include the following: 

	 Suboccurrence monitoring data including plant counts 

	 Inventory results of surveyed habitat 

	 Habitat restoration summary 

	 Recovery research summary 

	 Compliance monitoring record 

	 Description and photos of non-compliance incidents 

	 Recommendations for changes in management to reduce non-compliance and promote 

recovery of the species 

4.0 Adaptive Management 

The following measures can be implemented to increase protection of San Benito evening 

primrose habitat from unauthorized activities if compliance monitoring indicates that existing 

protection is insufficient to control impacts to habitat. The protection measures should be 

applied with respect to the specific unauthorized activity and the location where the unauthorized 

activity is occurring. The measures should be applied in a stepwise process. 

1.	 Site Monitoring - Increase frequency of monitoring at specific suboccurrences 

experiencing chronic non-compliance. 

2.	 Signing - Increase signing. Sign for educational and law enforcement purposes (i.e. 

Vegetation Study Area and Closed Area) unless vandalism is a risk. 

3.	 Fencing - Continued non-compliance will determine if barrier installation (fence or pipe) 

is necessary. Wire fencing provides an effective, lower cost option to exclude 

unauthorized human activities from protected areas. This type of barrier, however, is 

often more susceptible to vandalism (fence cutting and damage from OHVs) than robust, 

steel pipe barriers. 

4.	 Pipe barrier – Pipe barrier is constructed from welded segments of 2.5” diameter steel 

pipe. Pipe barrier installation is substantially more expensive to install than wire fencing, 

but its robust construction provides greater protection of sensitive areas, particularly from 

motorized vehicles which are capable of damaging wire fences. 

5.	 Closures - Close trails, sub-watersheds, entire watersheds and larger areas, or the entire 

CCMA when monitoring shows continued non-compliance in San Benito evening 

primrose occupied and potential habitat on BLM managed lands. Closures at the subwatershed and larger areas will be determined in consultation with the FWS to determine 

appropriate adaptive management actions. 

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5.0 Annual review with the U.S. Fish and Wildlife Service 

The BLM will confer with the Ventura FWS on an annual basis to review monitoring data and 

what measures the BLM has taken to remedy any problems that were identified. The conference 

can initially be via e-mail and phone, though either party reserves the right to request an inperson meeting. If substantial disagreement arises between the agencies regarding appropriate 

management response to issues related to protection and conservation of San Benito evening 

primrose, the FWS may request that formal consultation be reinitiated. 

6.0 References 

Barbour MG, Burk JH, Pitts WD, Gilliam FS and MW Schwartz. 1998. Terrestrial plant 

ecology. 3nd edition. Benjamin-Cummings Publishing Company, Menlo Park, California, USA. 

688 pp. 

Bureau of Land Management. 1997a. Baseline 1996 annual report for the San Benito evening 

primrose (Camissonia benitensis) - inventory and compliance monitoring program. Prepared for 

the U.S. Fish and Wildlife Service, Ventura, California. 

Bureau of Land Management. 1997b. Draft compliance monitoring on potential habitat 

polygons for San Benito evening primrose. 

Bureau of Land Management. 2003. Interim Protection Strategy. The Interim Protection 

Strategy (IPS) was developed by the BLM and FWS as an adaptive management response to 

increased OHV non-compliance at CCMA. This revised Compliance Monitoring Plan (CMP) 

included with the Services' Biological Opinion on the Clear Creek Management Area Plan 

Amendment (2005) replaced the IPS and served as a component of the long-term protection plan 

for San Benito evening primrose. 

Bureau of Land Management. 2005. OHV Compliance Monitoring for Camissonia benitensis 

within the Clear Creek Management Area - October 2005. This document was developed to 

update guidance on how to carry out the compliance monitoring program. 

Bureau of Land Management. 2006. Clear Creek Management Area Resource Management 

Plan Amendment and Route Designation. Bureau of Land Management, Hollister, California, 

USA. 

Bureau of Land Management. 2009. Annual Summary Report for the 2008 – 2009 Season 

Monitoring and Status of Camissonia benitensis and Implementation of the 2006 Record of 

Decision. Bureau of Land Management, Hollister, California, USA. 50 pp. 

Bureau of Land Management. 2010. Annual Summary Report for the 2009 – 2010 Season 

Monitoring and Status of Camissonia benitensis and Implementation of the 2006 Record of 

Decision. Bureau of Land Management, Hollister, California, USA. 32 pp. 

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Kiguchi LM. 1985. Sensitive plant survey: Clear Creek Recreation Area. San Benito Mountain 

Natural Area. 8 pp. 

Silvertown JW and D Charlesworth. 2001. Introduction to plant population biology. WileyBlackwell, Oxford, England, UK. 360 pp. 

Taylor DW. 1990. Ecology and life history of the San Benito evening primrose. Biosystems 

Analysis, Inc., Santa Cruz, California, USA. 80 pp. + Appendix. 

Taylor DW. 1993. Ecology and life history of the San Benito evening primrose (Camissonia 

benitensis). 1992 Final supplemental report. Biosystems Analysis, Inc., Santa Cruz, California, 

USA. 20 pp. 

U.S. Fish and Wildlife Service. 1985. Endangered and threatened wildlife and plants; final rule. 

Federal Register 50:5755-5759, February 12, 1985. 

U.S. Fish and Wildlife Service. 1997. Biological Opinion of the Clear Creek Management 

Area/Resource Management Plan Amendment and Final Environmental Impact Statement and 

the Proposed Administrative Site Development Plan, San Benito and Fresno Counties, 

California (1-8-96-F-20) (USDI SERVICE, 1997) and management of Camissonia benitensis. 

U.S. Fish and Wildlife Service. 2005. Biological Opinion of the Clear Creek Management 

Area/Resource Management Plan Amendment and Final Environmental Impact Statement, San 

Benito and Fresno Counties (1-8-05-F-20). 

U.S. Fish and Wildlife Service. 2006. Recovery Plan for Camissonia benitensis (San Benito 

Evening-Primrose). U.S. Fish and Wildlife Service, Sacramento, California, USA. ix + 97 pp. 

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Appendix V - Best Management Practices 

The following management practices were compiled from various sources listed in the reference section. 

These practices are listed as methods for correcting problems related to CCMA travel management and 

watershed issues associated with dust suppression, hazardous materials releases, and soil loss and erosion. 

Many of these management practices are specific measures which will need additional study to determine 

how or if they effectively apply to the specific conditions in the Clear Creek Management Area. 

All of these management practices would need to be monitored and evaluated to determine their overall 

effectiveness and protection of human health and the environment. These management practices have 

been grouped into the following, broad categories: watershed restoration/management, barrens 

restoration/management, transportation and roads, abandoned mine lands (AML) and mining activities, 

and recreation facilities. 

A. Watershed Management & Restoration 

BLM’S watershed management goals related to soil loss are based on limiting sediment production from 

roads, trails, and disturbed areas (hill climbs, mining areas), avoiding vegetation and stream channel 

disturbance, and minimizing mass movement of soil into stream channels (from steep slopes and mining 

areas). 

The following is a list of Management Practices (MP) that have been implemented and will continue to be 

implemented, practices that will be further developed, and management practices that will need further 

evaluation and planning prior to implementation. Continued implementation of management actions 

related to controlling erosion and sediment yield to minimize impacts to watershed resources are 

generally within the capability and budget constraints of the BLM. In all cases, BMPs will be identified 

that best address resource condition objectives and will be phased in over a period of time. 

MP –1:	 Protection of Unstable Areas 

Objective:	 To provide for protection of unstable areas and thereby avoid triggering mass movements 

of the soil mantle and resultant erosion and sedimentation. 

Explanation:	 This management practice will help protect unstable areas by reducing or stabilizing their 

high erosion rates. Unstable slopes will be protected by use of fences and barriers to 

eliminate or channel vehicle use away from these areas, and by use of gully plugs, water 

diversions, etc. as needed. 

MP- 2:	 Streamside Management Zone Designation 

Objective:	 To designate a zone along streams where prescriptions are made that will minimize the 

adverse effects of nearby land disturbance activities including roads, by: (1) acting as an 

effective filter for sediment generated by erosion from road fills and dust drift; (2) 

maintaining shade riparian habitat (aquatic and terrestrial), and channel stabilizing 

effects; (3) keeping the floodplain surface in a resistant, undisturbed condition to limit 

erosion by flood flows. 

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Explanation:	 Activities near streams need to be carefully designed and managed. At designated roads 

and stream crossings, fill and side cast material must be kept at a distance from nearby 

streams to minimize their impact on the critical riparian zone and on the stream itself. 

Factors such as stream class channel aspect, channel stability, side-slope steepness, and 

slope stability are considered in determining the constraints of activities and width of 

stream side management zones. It is vital to stabilize till slopes before the stream side 

management zone is saturated with sediment. The streamside management zone is not a 

zone of exclusion, but a zone of closely managed activity. It is a zone which acts as an 

effective filter and absorptive zone for sediment, maintains shade, protects aquatic and 

terrestrial riparian habitats, protects channel and stream banks, and promotes flood plain 

stability. 

MP – 3:	 Restrict Development within the Floodplain 

Objective:	 To avoid, where possible, the long and short-term adverse impacts to water quality 

associated with the occupancy and modification of floodplains. 

Explanation:	 A floodplain analysis and evaluation will be made when sites within floodplains are 

being considered for structures or developments. Environmental quality, ecological 

effects, and individual safety and health are considered. Flood frequencies, watershed 

conditions, climatic and environmental factors associated with past flood events, flood 

flow quantities and specific flood boundaries are all evaluated. 

MP – 4	 Specifying Riprap Composition 

Objective:	 To minimize sediment production associated with the installation and utilization of riprap 

materials. 

Explanation:	 Riprap is commonly used to armor stream banks, stream crossings, and drainage ways 

from the erosive forces of flowing water. Riprap must be sized and installed in such a 

way that it effectively resists erosive water velocities. Stone used for riprap should be 

free from weakly structured rock, organic material and materials of insufficient size, all 

of which are not resistant to stream flow and would only serve as sediment sources. 

Outlets of drainage facilities in erodible soils commonly require riprap for energy 

dissipation. The Corps of Engineers and Federal Highway Administration procedures are 

commonly used for designing riprap structures. 

MP – 5	 Re-vegetation of Surface Disturbed Areas 

Objective:	 To protect water quality by minimizing soil erosion through the stabilizing influence of 

vegetation. 

Explanation:	 This is a corrective practice to stabilize the soil surface of a disturbed area. The 

vegetation selected will be a mix of species best suited to meet the management 

objectives of the area, be it wildlife, recreation, watershed, or fuels management. 

Endemic species (grass or browse shrubs) may be used between recently planted trees 

where appropriate for aesthetics, erosion prevention or wildlife needs. The factors 

evaluated are soil fertility, slope, aspect, soil water holding capacity, climatic variables, 

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and suitable species selection. Re-vegetation of some disturbed areas in serpentine soils 

may not be feasible. 

MP – 6:	 Watershed Restoration 

Objective:	 To improve water quality and soil stability. 

Explanation:	 Watershed restoration is a corrective measure to: (1) repair degraded watershed 

conditions and restore the hydrologic balance with a vegetative cover that will maintain 

or improve soil stability, reduce surface runoff, increase infiltration, and reduce flood 

occurrence and flood damages; (2) conserve the basic soil resource; (3) maintain and 

improve water availability; and (4) enhance economic, social, and scenic benefits of the 

watershed. Factors considered are: predicted change in water quality, downstream 

values, on-site productivity, threat to life and property, direct and indirect economic 

returns, and social and scenic benefits. Examples of watershed restoration measures are 

gabion structures, back filling gullies with rock, and constructing water diversions. 

MP – 7:	 Erosion Control Structure Maintenance 

Objective:	 To ensure that constructed erosion control structures are stabilized and working. 

Explanation:	 Erosion control structures are only effective when they are in good repair and stable 

condition. Once the erosion control structures are constructed and seeded where 

practicable, there is a possibility that they may not become adequately vegetated or 

stabilized or they may become damaged from subsequent activities. It is necessary to 

provide follow-up inspections and structural maintenance in order to avoid these 

problems and insure adequate erosion control. 

MP – 8:	 Abandoned Road and Trail Restoration and Reclamation 

Objective:	 To improve water quality and soil stability. 

Explanation:	 Route restoration is a corrective measure to: (1) repair degraded route conditions and 

restore the hydrologic balance with a vegetative cover that will maintain or improve soil 

stability, reduce surface runoff, increase infiltration, and reduce flood occurrence and 

flood damages; (2) conserve the basic soil resource; (3) maintain and improve water 

availability; and (4) enhance economic, social, and scenic benefits of the watershed. 

Factors considered are: predicted change in water quality, downstream values, on-site 

productivity, threat to life and property, direct and indirect economic returns, and social 

and scenic benefits. Examples of route restoration measures are soil de-compaction, 

vertical and horizontal mulching, transplanting and re-seeding vegetation, re-establishing 

natural drainage features and utilization of temporary water management features. 

B. Barren Areas Management & Restoration 

The purpose of this section is to present sediment and erosion control BMPs that are potentially 

applicable for active OHV play areas. Due to the unique conditions at the Clear Creek Management Area 

(i.e., topography, climate, soil types, vegetation, and recreational OHV use), the effectiveness of the 

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proposed BMPs is difficult to predict. There is very limited practical experience with BMPs for 

conditions similar to those found at Clear Creek. 

In order to directly evaluate the efficiency of the proposed BMPs at Clear Creek, it is recommended that a 

BMP pilot program be implemented. Under the pilot program, the BMPs considered by BLM to be most 

feasible based on the available budget will be implemented on a limited scale. Each selected BMP is 

implemented at one or two sites that meet its applicability criteria and using different designs where 

possible. The effectiveness of each BMP is then evaluated over the course of one year. At the end of the 

evaluation, BLM will identify the most effective BMPs and designs and will expand their use at other 

sites with similar features within the Clear Creek Management Area. 

MP – 9	 Silt Fences 

Objective:	 A silt fence consists of a geotextile fabric attached to supporting poles, which is used to 

intercept, reduce velocity, and filter surface runoff. 

Explanation:	 Silt fences are effective in areas where sheet flow occurs for example, at lower end of 

active play areas, particularly at the interface between a play area and a vegetation buffer; 

base of slopes; and along streams. Silt fences provide retention of runoff sediments, 

decrease runoff flow velocity and energy, protect downslope vegetation from 

sedimentation and wash-out, and provide visual indication of play area lower boundary. 

Installation does not require construction equipment or skilled labor and is low cost. 

MP –10	 Erosion Control Blankets 

Objective:	 Erosion control blankets are mats made of synthetic or natural material, or a combination 

of the two, which are stapled to the soil on steep slopes to control erosion and promote 

the establishment of vegetation. 

Explanation:	 The use of erosion control blankets is limited to narrow strips adjacent to the lateral 

boundaries of vegetated areas located downgradient of active OHV use areas. In order for 

the blankets to be effective, the soil over which they are installed should be of sufficient 

quality to support vegetation growth. The soil surface must be relatively smooth, without 

rock, deep depressions, or debris. The blankets may be seeded to improve the vegetation 

establishment process. This BMP may be combined with the use of silt fences, which are 

described earlier in this section. A silt fence may be installed upgradient of a vegetated 

area and extended laterally to protect the erosion protection blanket strips. Benefits and 

advantages of erosion control blankets include: effective protection of soils on highly 

erodible slopes: they absorb and hold moisture near the soil surface; promote vegetation 

establishment; may be installed on steep slopes; and they do not require construction 

equipment or skilled labor. 

MP – 11	 Rock Backfilling of Gullies 

Objective:	 Filling gullies with loose angular rock prevents further deterioration from water erosion. 

Explanation:	 This practice is used primarily in naturally incised drainage channels that concentrate 

flow and significantly contribute to sediment generation and transport. This method may 

be combined with the check dam application where lower, more accessible sections of a 

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gully may be backfilled with rock and the check dams would be constructed at higher 

sections of the gully. Benefits of rock backfilling include: a decrease in runoff flow 

velocity and energy; retention of runoff sediment which, over time, may clog the void 

spaces and “heal” the gully; and maintenance can be minimal with proper construction. 

MP – 12	 Check Dams 

Objective:	 Check dams decrease runoff flow velocity and energy and provide retention and settling 

of runoff sediments. 

Explanation:	 Check dams are small structures made of logs, stone, or silt fence that are constructed 

across a gully or ephemeral stream in order to lower the speed, retain sediments, and 

diminish the erosion potential of concentrated flows. Installation does not require 

construction equipment or skilled labor and is low cost. 

MP – 13	 Interceptor Dyke and Swale 

Objective:	 Interceptor dykes and swales are used to decrease runoff flow energy, protect downslope 

vegetation from sedimentation and wash-out, and provide visual indication of play area 

lower boundary. 

Explanation:	 Dykes are ridges of compacted soil and swales are excavated depressions. A dyke is 

constructed adjacent and downslope of the swale from materials excavated for the 

construction of the swale. In most cases the swale is stabilized with riprap. Dyke and 

swale systems intercept overland flow and convert it into concentrated flow with lower, 

non-erosive velocity. The diverted flow is discharged to a suitable outlet. Dykes differ 

from silt fences in that it intercepts and diverts all runoff from upload areas, whereas, silt 

fences allow runoff to filter though the fence and reach lower areas. 

MP – 14	 Sediment Basins 

Objective:	 Sediment basins provide retention of runoff sediments up to 60 to 70%, decrease runoff 

flow velocity and energy, and protect downslope vegetation from sedimentation and 

wash-out. 

Explanation:	 A sediment basin is a pond created by constructing a dam across a drainage way, and is 

designed to detain runoff in order to allow suspended sediments to settle. The pond is 

provided with a riser connected to a discharge pipe, which ends downgradient of the dam. 

The pipe is placed perpendicular to and at the base of the water flow. In the pond, water 

accumulated until its level exceeds the height of the riser and the excess water discharges 

though the pipe to the downgradient outlet. The basin volume below the top of the riser is 

the sediment storage zone. The dam should be constructed of materials less permeable 

than gravel and clean sand. Local materials such as silty sand, clayey sand, and silt, are 

acceptable if they are free of debris. The storage volume may be increased by evacuation 

the area in from of the dam, and excavated materials may be used for the construction of 

the dam. The structure is provided with an emergency spillway to prevent water from 

flowing over the dam in flood conditions. The ratio between the basin length and width 

should be between 2:1 and 9:1. 

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MP – 15	 Rock Filter 

Objective:	 Rock filters provide retention of runoff sediments, decrease runoff flow velocity and 

energy, and create physical boundaries for OHV’s. 

Explanation:	 A rock filter consists of a berm of crushed rock (size 1.5 to 3 inches), wrapped in poultry 

wire (one inch diameter hexagonal mesh, galvanized 20 gauge), and placed parallel to 

topographic contour lines on a horizontal surface at the toe of a slope. The purpose of the 

rock filter is to intercept sediment laden runoff from disturbed areas of the site, reduce 

flow velocity, promote sedimentation, and release the water as sheet flow. Rock filters 

are low cost and require low maintenance. 

MP – 16	 Gabion Mattresses 

Objective:	 To provide retention of runoff sediments, decrease runoff flow velocity and energy, and 

create a physical boundary for OHV’s. 

Explanation:	 A gabion mattress is a wire-mesh box filled with crushed rock. Typical mattress 

dimensions are: Height – six to nine inches; length – nine to twelve feet; and width – six 

feet. The purpose of gabion mattresses similar to that of the filter rock in which sediment 

laden runoff is intercepted from disturbed areas of the site, flow velocity is reduced 

sedimentation is promoted, and water is released as sheet flow. The main differences 

between mattresses and filter rock are: gabion mattresses may be placed on the slope 

before and after the slope break at the toe; gabion mattresses are more resilient; and 

mattresses are wider, resulting in better sediment trapping efficiency. 

C. Transportation & Roads 

MP – 17:	 Dust Mitigation Measures 

Objective:	 Reduction of Chrysotile Emissions on Unpaved Roads and Trails 

Explanation:	 Airborne chrysotile dust would attempt to be controlled through various mitigating 

treatments. Treatments would potentially range from base rock, frequent application of 

water, Lignosulfonate, Calcium chloride, petroleum products, liquid copolymers and 

synthetic organic soil binding fluid. A variety of suppliers are available. Efficacy would 

need to be established through field testing. Reapplication and maintenance schedules 

would be established through testing using manufacturers’ recommendation as baseline. 

Fugitive airborne dust and sloughing may increase application to subjective intervals. 

MP – 18:	 Stream course Protection 

Objective:	 (1) To protect the natural flow of streams, (2) to provide unobstructed passage of storm 

flows, (3) to reduce sediment and other pollutants from entering streams, and (4) to 

restore the natural course of any stream as soon as practicable if the stream is diverted as 

a result of management activities. 

Explanation:	 The following points are fundamental to protecting streams and stream courses: 

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a.	 Vehicles should not operate within stream side management zones except where trails 

and roads cross the stream channel. 

b.	 Water bars and other erosion control structures will be located so as to prevent water and 

sediment from being channeled into stream courses and to dissipate concentrated flows. 

c.	 Material resulting from temporary road and ORV trail stream course crossing should be 

removed and stream banks restored and protected to the extent practicable. 

MP – 19:	 Road Stream crossings 

Objective:	 To ensure that roads do not unduly damage streams or disturb channels. 

Explanation:	 Culverts or other means are necessary on roads (temporary, semi-permanent, or 

permanent) at all locations where it is necessary to cross designated streams. Alternate 

means of crossing stream courses may include: rock fills, hardened fords (using such 

features as rocked approaches) and low water crossings. Most (if not all) crossings of 

perennial streams should be approved by an inter-disciplinary team. Such facilities 

should be designed to provide for unobstructed flows and to minimize damages to stream 

courses. The number of crossings should be kept to the minimum needs for access. 

Channel crossings should be as perpendicular to stream courses as possible. Stream bank 

excavation should be kept to the minimum needed for use of the crossings, and entry and 

exit ramps may need to be rocked. Fords and turnpike crossings hardened with washed 

rock or landing mats are sometimes an acceptable alternative depending upon 

hydrological considerations. 

MP – 20:	 Road Slope Design 

Objective:	 To reduce sedimentation by: (1) minimizing erosion from road slopes, and (2) 

minimizing the chances for slope failures along roads. 

Explanation:	 No stabilization project can entirely prevent erosion from cut and fill slopes, but no road 

construction should be planned without considering stabilization needs. The first 

planning requirement is for an adequate soil and geologic investigation, to provide data 

necessary for proper cut and fill design consideration such as: 

(1) The proper cut and full slopes for the material; 

(2) The handling of surface and subsurface drainage; 

(3) Necessary compaction standards and surfacing needs. 

A prerequisite for stabilization is to provide basic mechanical stability of the soils, using 

data from soils and geologic investigations to develop requirements for proper slope 

angles, compaction, and adequate drainage. 

MP – 21:	 Road Slope Stabilization 

Objective:	 To improve road cut and fill slope stabilization by applying mechanical and vegetative 

measures. 

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Explanation:	 Few slopes are sufficiently rocky to be naturally stable without needing additional 

measures. In most cases mechanical, and/or vegetative measures are required. 

Mechanical measures include but are not limited to: erosion nets, terraces, wattling, side 

drains, sub-surface dewater devices, blankets, fute mats, riprap, mulch, tackifier 

pavement, soil seals, and gunnite. Vegetative measures include the seeding of endemic 

herbaceous species (grass, legumes, or browse species) or the planting of endemic brush 

or trees. Vegetative measures may include: fertilization, mulching (or even watering) to 

insure success. A combination of endemic vegetative species often produces a better 

result than a more simplistic treatment, e.g., grass seeding alone. (See also MP – 5). 

MP – 22:	 Dispersion of Subsurface Drainage from Cut and Fill Slopes. 

Objective:	 To minimize the possibilities of cut or fill slope failure and the subsequent production of 

sediment. 

Explanation:	 Roadways may drastically change the surface drainage characteristics of a slope. Since 

the angle and height of cut and fill slopes increase the risk of instability, it is often 

necessary to provide subsurface drainage to avoid moisture saturation necessary because 

of slopes, soil, aspect, and precipitation. Methods that should be used: 

(1) Pipe under drains 

(2) Horizontal drains 

(3) Stabilization trenches 

Dispersion of collected water should be accomplished in an area capable of withstanding 

increased flows. On erosive soils, energy dissipaters need to be placed below pipe 

carrying large volumes of runoff water. 

MP – 23	 Control of Road Drainage 

Objective:	 (1) To minimize the erosive effects of water concentrated by road drainage features; (2) 

to disperse runoff from disturbances within the road clearing limits; (3) to lessen the 

sediment load from road areas; (4) to minimize erosion of the road prism by runoff from 

road surfaces and from uphill areas. 

Explanation:	 A number of measures can be used (alone or in combination) to control the detrimental 

effects of road drainage. Methods used to reduce erosion may include such things as 

properly spaced cross drains or water bars, dips, drop basins, energy dissipaters, aprons, 

downspouts, gabions, debris racks, and armoring of ditches and drain inlets and outlets. 

Disposal of runoff can be accomplished by such means as rolling the grade; out sloping; 

installation of water spreading ditches; contour trenching; or adequate sized over side 

drains, etc. Disposal of runoff also reduces peak down stream flows and associated high 

water erosion and sediment transport. Sediment loads can be reduced by installing such 

things as sediment filters, settling ponds, and contour trenches. Soil stabilization can help 

reduce sedimentation by lessening erosion on borrow and waste areas, on cut and fill 

slopes and on road shoulders. 

MP – 24:	 Erosion Control on ORV Trails and Temporary Roads. 

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Objective:	 To protect water quality by minimizing erosion and sedimentation derived from ORV 

trails and roads. 

Explanation:	 Installation of erosion control measures may be required on OHV trails and temporary 

roads. This work may involve cross ditches and water spreading ditches. Other methods 

such as back-blading may be used in lieu of cross drains. Volunteer groups may also be 

used for constructing erosion control structure projects. 

MP – 25:	 Minimization of Sidecast Material. 

Objective:	 To minimize sediment production originating from material sidecast during road 

construction or maintenance. 

Explanation:	 Unconsolidated side-cast material is very difficult to stabilize and often such material is 

susceptible to erosion and / or mass instability. Sidecasting of un-compacted material 

should be permitted only at locations designated through interdisciplinary input, and 

shown in the plans. In some areas especially those slopes over 60 percent, end hauling 

may be the only acceptable alternative to sidecasting even though the costs are high and 

end-haul equipment may need certain minimum widths in which to work. Waste areas 

should be located where excess materials can be deposited and stabilized. During road 

maintenance operations, care should be taken to eliminate the deposition of sidecast 

material onto stabilized slopes. Disposal of slide debris should be done only at 

designated water areas. Personnel performing road maintenance should confine 

excavated or embankment material within the roadway limits and the roadway should be 

constructed in reasonably close conformity with the lines, grades, and dimensions 

designated on the ground. They should also remove materials deposited outside the 

roadway. All materials should be incorporated in the planned work. Disposal of excess 

excavation which develops due to miscalculation or a specific design change should be 

disposed of in a specified manner and at a specified location. 

MP – 26:	 Maintenance of Roads 

Objective:	 To maintain roads in a manner which provides for water quality protection by minimizing 

rutting, failures, sidecasting, and blockage of drainage facilities – all of which can cause 

sedimentation and erosion. 

Explanation:	 Roads normally deteriorate because of use and weather impacts. This deterioration can 

be minimized through adequate maintenance and /or restriction of use. All system roads 

should be maintained to provide the basic custodial care required to protect the road 

investment and to see that damage to adjacent land and resources is held to a minimum. 

This level of maintenance often requires an annual inspection to determine what work, if 

any is needed to keep drainage functional and the road stable. This level is the normal 

prescription for roads that are closed or seasonally closed to traffic. As a minimum 

measure, maintenance must protect drainage facilities and runoff patterns. Higher levels 

of maintenance may be chosen to reflect greater use or resource administrative needs. 

Additional maintenance measures could include resurfacing, out sloping, clearing debris 

from dips and cross drains, armoring of ditches and spot rocking. 

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MP – 27:	 Control of Road Use During Wet Periods 

Objective:	 (1) To reduce road surface disturbance and rutting of roads; and (2) to lessen sediment 

washing from disturbed road surfaces. 

Explanation:	 The unrestricted and official use of many unimproved and semi-improved roads during 

wet weather often results in rutting and churning of the road surfaces. Run off from such 

disturbed road surfaces often carries a high sediment load. The damage/maintenance 

cycle for roads that are frequently used in winter can create a disturbed road surface that 

is a continuing sediment source. Roads that are used during wet periods should have a 

stable surface and/or sufficient drainage to allow such use with a minimum of resource 

impact. Rocking, oil, paving, and armoring are measures that may be necessary to 

protect the road surface and reduce material loss. Drainage should be maintained to 

prevent water from standing on the road surface or running down the road creating rills 

and gullies in the road surface. 

D. Abandoned Mine Lands & Mining Related Activities 

MP – 28:	 Regulation of Streamside Gravel Borrow Areas 

Objective:	 To limit channel disturbances and sediment production associated with gravel source 

development. 

Explanation:	 Materials deposited along channel sections during storm runoff often provide an 

inexpensive source of gravel. Because of easy access this gravel is often in demand; with 

adequate planning, it can often be removed with minimal impact on water resources. 

Under some circumstances, gravel removal may alter stream flow characteristics and 

consequently affect stream channel stability and create a new sediment source. 

Borrowing should be limited to gravel bars above the water line which is normal for the 

period of excavation. If the borrow area is subject to periodic flooding, some leveling, 

shaping, or other special drainage features should be provided. Excavation should not 

take place below the water table unless sediment basins are built to contain or catch the 

resulting sediment. Sediment basins should not be subject to washouts. If excess 

sediment accumulates in basins, excavators should be required to clean the basin and 

deposit removed sediment in approved sites. Serpentine areas should not be used as a 

gravel source for use outside of the serpentine area. 

MP – 29:	 Restoration of Borrow Pits, Quarries, and Mining Operations 

Objectives:	 To minimize sediment production from borrow pits, quarry sites and mining operations. 

Explanation:	 Borrow pits, quarries, and mining operations are often susceptible to erosion due to steel 

side slopes, lack of vegetation, and/or their proximity to water courses. Whenever 

necessary, prior excavation of the site, top soil should be removed and stockpiled for 

surface dressing in the post operation rehabilitation period. Once excavation has been 

completed on all or part of the area, the sides will be sloped and graded and the general 

pit area smoothed and stabilized. Oversize material, if left in the pit or quarry, should be 

evenly distributed. Finer materials should be spread over the bottom of the pit prior to 

spreading stockpiled or imported top soil. Seeding and mulching may be required and 

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sediment basins should also be considered. Access roads to the site should be ripped, 

drained, blocked to traffic, and seeded unless other treatment is required by the design. 

MP – 30:	 Environmental Health and Safety Hazard Awareness 

Objective:	 Improve the level of visitor awareness of environment health and safety hazards, e.g., 

asbestos hazard in dust and water. 

Explanation:	 The public will be encouraged through signs, pamphlets, media exposure and public 

contact to conduct their activities in ways that will not unnecessarily expose themselves 

to environmental hazards. 

E. Recreation Facilities 

MP – 31:	 Surface erosion Control at Facility Sites 

Objective:	 Limit the amount of surface erosion taking place on developed sites and the amount of 

soil entering streams. 

Explanation:	 On lands developed for campgrounds, parking areas or waste disposal sites much ground 

is cleared of vegetation. Erosion control methods need to be implemented to keep as 

much of the oils in place as possible and to reduce the amount of soil entering streams 

Some examples of erosion control methods that can be applied at a site for keeping the 

soil in place would be applying endemic species seed, jute matting, tackifiers, hydro 

mulch, paving or rocking of roads, water bars, cross drains, or retaining walls. To control 

the amount of soil entering streams, the natural drainage pattern of the area should not be 

changed. Sediment basins and sediment filters should be established to filter surface 

runoff. Diversion ditches and berms should be built to divert surface runoff around bare 

areas. Construction activities should be scheduled to avoid periods of the year when 

heavy runoff will occur. 

MP – 32:	 Control of Sanitation Facilities. 

Objective:	 To protect surface and subsurface water quality from bacteria, nutrients, and chemical 

pollutants resulting from collection, transmission, and disposal of sewage from Bureau of 

Land Management facilities. 

Explanation:	 Toilet facilities are provided at semi-developed and developed recreation sites. 

Sanitation facilities will be planned, located, designed, constructed, operated, inspected 

and maintained to minimize the possibility of water contamination. Toilet facilities 

should be located outside of the flood plain. 

MP – 33	 Control of Refuse Disposal 

Objective:	 To protect water quality from nutrients, bacteria, and chemicals associated with solid 

waste disposal. 

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Explanation:	 Users of public land recreation facilities are encouraged cooperate in the proper disposal 

of garbage and trash. Receptacles are provided at most semi-developed sites. Garbage 

and trash must be packed out by those who use dispersed areas. The final disposal of 

collected garbage will be at a proper designated and operated sanitary landfill. The land 

fill site will be located where groundwater and surface waters are at safe distances as 

prescribed by State or local Health Board regulations. 

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Appendix VI - Wild & Scenic River Inventory 

i. Wild and Scenic River System 

The Wild and Scenic Rivers Act of 1968 (Public Law 90-542) was passed by Congress to preserve 

riverine systems that contain outstanding features. The law was enacted during an era when many rivers 

were being dammed or diverted, and is intended to balance this development by ensuring that certain 

rivers and streams remain in their free-flowing condition. The BLM is mandated to evaluate stream 

segments on public lands as potential additions to the National Wild and Scenic Rivers System (NWSRS) 

during the Resource Management Plan (RMP) process under Section 5(d) of the Act. The NWSRS study 

guidelines are found in BLM Manual 8351, U.S. Departments of Agriculture and Interior Guidelines 

published in Federal Register Vol. 7, No.173, September 7, 1982 and in various BLM memoranda and 

policy statements. Formal designation as a Wild and Scenic River requires Congressional Legislation, or 

designation can be approved by the Secretary of Interior if nominated by the Governor of the state 

containing the river segment. The following discussion provides information on how BLM considered 

waterways for potential inclusion in the NWSRS. 

The NWSRS study process has three distinct steps: 

1.	 Determine what rivers or river segments are eligible for NWSRS designation; 

2.	 Determine the potential classification of eligible river segments as wild, scenic, recreational or 

any combination thereof; and 

3.	 Conduct a suitability study to determine if the river segments are suitable for designation as 

components of the NWSRS. 

This report documents all three steps of the process for the streams in the planning area. 

ii. Eligibility of Planning Area Rivers & Streams 

Identification 

A variety of sources were reviewed to identify waterways which could have potential for wild and scenic 

river designation. They include the Nationwide Rivers Inventory List, the Outstanding Rivers List 

compiled by American Rivers, Inc., river segments identified by state or local government, river segments 

identified by the public during formulation of the CCMA RMP/EIS, and river segments identified by the 

planning team as having potential to meet Wild and Scenic River eligibility requirements. 

The Wild and Scenic Rivers Act defines a river as a “flowing body of water or estuary or a section, 

portion, or tributary thereof, including rivers, streams, creeks, runs, kills, rills, and small lakes.” 

Eleven stream segments totaling 21 miles located on or crossing BLM public lands were identified for 

review. These streams segments are identified on Map 7 in Appendix I and are listed in Table 1 below. 

Eligibility Determination 

Each identified river segment was evaluated to determine whether it is eligible for inclusion in the 

NWSRS. To be eligible, a river segment must be “free flowing” and must possess at least one 

“outstandingly remarkable value” (ORV). These ORV’s include: 

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(1) Scenic,	 (7) Cultural, 

(2) Recreational,	 (8) Ecological, 

(3) Geological,	 (9) Riparian, 

(4) Fish,	 (10) Botanical, 

(5) Wildlife,	 (11) Hydrological, and 

(6) Historical,	 (12) Scientific values 

To be considered as “outstandingly remarkable”, a river related value must be a unique, rare, or 

exemplary feature that is significant at a comparative regional or national scale. Only one such value is 

needed for eligibility. All values should be directly river related, meaning they should: 

1.	 Be located in the river or on its immediate shorelands (generally within 1⁄4 mile on either side of 

the river); 

2.	 Contribute substantially to the functioning of the river ecosystem; and/or 

3.	 Owe their location or existence to the presence of the river. 

These are the only factors considered in determining the eligibility of a river segment. All other relevant 

factors are considered in determining suitability. A river need not be navigable by watercraft to be 

eligible. For purposes of eligibility determination, the volume of flow is sufficient if it is enough to 

maintain the outstandingly remarkable value(s) identified within the segment. 

Table 1 summarizes the eligibility evaluation of all identified river segments. The table includes 

information on the length of stream segments managed by BLM, free-flowing status, and outstandingly 

remarkable value(s) of each eligible segment, if applicable. Table 1 also gives a description of each 

eligible river segment’s location on BLM Surface Management (SM) maps. 

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171 


Table 1: Wild & Scenic River htventory 

Riwr Name.~,$egm,ent R.ea~n C~9ide~' t 1}, SCM Length (mLI Segmentl.Reaoh Identiftea~ on Fr~ Flowll:a,g ORV(~} ~ligibility 

COALINGA S M. T1SS., R12E .. SEC 19 . . 

Picaohc-Cle!Sk c: 20 T1SS , R11E .. SEC 25 y C,H E ljgibl: 

WhitS: C1'e:.<:k c: 28 COALIIVGA S M, T19S .. R13E ., SEC ..q, .S, 9, 17 Y F.G E ljgibl: 

Luicus Ct~ c: 25 COALIIVGA S M, T17S .. R11E ., SEC 26, 35, 36 Y F.G E ljgibl: 

COALINGA S M, T1SS., R12E ., SEC 2. 

E 3S t Fe« cf S3r. C3rlcs e: ~ c: 1.4 T17S , R12E .. SEC 22, 26, 36 y D E ljgibl: 

San C3tlos ...:~ c 1.0 CCALIN'GA S M. T18S., R1.2E., SEC :4. 5 y D.F E l;oib" 

San Se:i"itoRiv:n o c 0,8 CCALIN'GA S M. T18S .. R12E .. SEC S2. 5 y B,D,H E lioiblo: 

San Se:i"itoRiv:;- i 2} c 0,5 CCALIN'GA S M. T18S .. R12E . SEC 25,26 y B,D,H E lioiblo: 

San Se:i"itoRiv:H3) c 0,3 CCALIN'GA S M. , T17S .. R1CE. SEC ·16, 17 y B,D,H E lioiblo: 

Ca'"!e:Ca.nvon c 1.3 CCALIN'GA S M. T17S .. R11E .. SEC .30. 3·l y A NaH~~ibl: 

COALINGA S M, T1SS.R12E, S:c 1, 12. 13., 24 

Cantua Ctes:i: D 3.8 T1SS . R1 :?.E. Sec 5.6 y B, C E ls:cibk: 

COALINGA S M, T1SS., R12E., SEC .8. 9. 17 

Cl:arCc.;:.:)< 3t'ld Tributa.:ies c 7.0 T1SS .. R1 1E .. SEC 1. 11. 12. 15. 16 y B- H E lioiblo: 

COALINGA S M, T1SS., R12E., SEC 1, 

S~NMill Cu..;!( c 1.5 4. . · 22 v E,F,H Elioibl• 

SM= BLMSurl'ace Management Mop 

(I) A -N•tion.!Riv.rs Jw.n1oty 

B -1988 Outstardirc Rivers List, An-ericanRivers, Ire. 

C -Seg:n-el11: inHollistn Field Office ripari.mdatabase 

(2) A-Non-existe,. 

B -Soel1ic 

C -Recreational 

D -Oth.r D -GeoJocical 

E-Fish&WIIdlife 

F -Histotical 

G-Culrural 

H -Oih>r(in:ludmg Ecological) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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iii. Suitability of Hollister Field Office Stream Segments 

All river segments identified on Map 7 in Appendix I and displayed in Table 1 (above) were found to be 

eligible for inclusion into the NWSRS. 

Section 4(a) of the Wild and Scenic River Act mandates that all rivers found eligible as potential 

additions to the NWSRS be studied as to their suitability for such a designation. The purpose of the 

suitability study is to provide information upon which the President of the United States can base his 

recommendation and Congress can make a decision. The study report describes the characteristics that do 

or do not make the stream segment a worthy addition to the system, the current status of land ownership 

and use in the area, the reasonably foreseeable potential uses of the land and water which would be 

enhanced, foreclosed, or curtailed if the area were included in the system, and several other factors. The 

suitability study is designed to answer these questions: 

 Should the river’s free–flowing character, water quality, and outstandingly remarkable values 

(ORVs) be protected, or are one or more other uses important enough to warrant doing otherwise? 

 Will the river’s free-flowing character, water quality, and ORVs be protected through 

designation? Is it the best method for protecting the river corridor? 

 Is there a demonstrated commitment to protect the river by any nonfederal entities that may be 

partially responsible for implementing protective management? 

Pursuant to Sections 4(a) and 5(c) of the Wild and Scenic Rivers Act, the following factors would be 

considered and evaluated as a basis for the suitability determination for each river (as described further, 

below); 

(a) Characteristics that do or do not make the area a worthy addition to the NWSRS; 

(b) The current status of land ownership, minerals (surface and subsurface), and use in the area, 

including the amount of private land involved and associated or incompatible uses. 

(c) The	 reasonably foreseeable potential uses of the land and water that would be enhanced, 

foreclosed, or curtailed if the area were included in the NWSRS. Historical or existing rights 

which could be adversely affected. 

(d) The federal agency that will administer the area should it be added to the NWSRS. 

(e) The estimated cost to the United States of acquiring necessary lands and interests in lands and of 

administering the area should it be added to the NWSRS. 

(f)	 A determination of the degree to which the state or its political subdivisions might participate in 

the preservation and administration of the river should it be proposed for inclusion in the 

NWSRS. 

(g) An evaluation of the adequacy of local zoning and other land use controls in protecting the river’s 

ORVs by preventing incompatible development; 

(h) Federal, public, state, local, or other interests in designation or non-designation of the river, 

including the extent to which the administration of the river, including the cost thereof, may be 

shared by state, local, or other agencies and individuals. Support or opposition to the designation. 

(i)	 The consistency of designation with other agency plans, programs or policies and in meeting 

regional objectives. 

(j)	 The contribution to river system or basin integrity. 

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(k) The ability of BLM to manage the river segments under designation, or ability to protect the river 

area other than Wild and Scenic designation. 

1. Characteristics that Do or Do Not Make the River Segments Worthy Additions to 

the NWSRS 

Stream segments in the Planning Area are located within the California Coast Ranges of the Pacific 

Border Physiographic Province. This province was used as a basis to determine if the study segments 

possess characteristics of at least regional significance that would make them worthy additions to the 

NWSRS. The Pacific Border province contains the highest rainfall and density of streams in California. 

Also, many of these streams provide habitat for anadromous fisheries. 

The San Francisco Bay and Central Coast portion of the Coast Ranges are considered a distinct 

hydrological area because precipitation in this region is generally about 50% of that in the northern part of 

the province and snowmelt influences are insignificant. The tectonics associated with the San Andreas 

Fault system have influenced the orientation and location of the major river valleys. Sediment yields are 

high because of high-intensity rainfall, high rates of uplift, and unstable rocks. These small steep 

watersheds have short lag times and high peak runoffs, and rivers often flood during winter storms. 

There are currently 15 designated National Wild & Scenic Rivers in California, which include portions of 

the North Fork and Lower American River, Big Sur River, Black Butte River, Eel River, Feather River, 

King River, Kern River. Klamath River, Merced River, Sespe Creek, Sisquoc River, Smith River, Trinity 

River, and Tuolumne River. This amounts to more than 1,800 miles of rivers and streams that are 

designated as part of the NWSRS in California. 

Many of the eligible river segments within the CCMA have outstandingly remarkable values when 

considered in the context of other streams in the region. However, the BLM planning team found that all 

river segments provided below-average to low quality values in the statewide and national context. 

Therefore, they are not considered to be worthy additions to the system. 

In summary, although these values meet the minimum eligibility criteria, when viewed in the context of 

the California Coast Ranges of the Pacific Border Physiographic Province, the study team determined that 

these river segments were not of a level of quality to make them worthy additions to the NWSRS. 

2. Status of Land Ownership and Current Use 

BLM Manual 8351.33A(2), “Wild and Scenic Rivers – Policy and Program Direction for Identification, 

Evaluation and Management”, states “In situations where there is limited public land (shoreline and 

adjacent land) administered by the BLM within an identified river study area, it may be difficult to ensure 

those identified outstandingly remarkable values could be properly maintained and afforded adequate 

management protection over time. Accordingly, for those situations where the BLM is unable to protect 

or maintain any identified outstandingly remarkable values, or through other mechanisms (existing or 

potential), river segments may be determined suitable only if the entity with land use planning 

responsibility supports the finding and commits to assisting the BLM in protecting the identified river 

values. An alternative method to consider these segments is for state, local governments or private 

citizens to initiate efforts under section 2(a)(ii), or a joint study under section 5C of the Wild and Scenic 

Rivers Act.” Typically, the local county governments have land use planning responsibility for the private 

lands on these segments. However, BLM has not approached the counties in the Planning Area regarding 

their support for wild and scenic designation of these segments, because the study team determined that 

they are not worthy additions to the system and BLM ownership of shoreline and adjacent lands is 

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sufficient to ensure that ORVs could be properly maintained and afforded adequate management 

protection over time regardless of designation. 

3. Potential Uses of the Land to be Enhanced or Curtailed by Designation/ 

Historical or Existing Rights That Could Be Adversely Affected, including Water 

Resources Projects. 

Diversion of additional water from any of the streams during the summer low-flow period could impact 

outstandingly remarkable values if they are present. Wild and Scenic River designation would not impact 

current water rights, but could affect future diversions from the streams. 

4. Federal Agency that will Administer Wild & Scenic River Segments 

BLM’s Hollister Field Office would administer all river segments under evaluation should they be 

included in the NWSRS. 

5. Estimated Cost of Acquisition and Administration 

There would be a minor need to acquire additional lands for Hollister Field Office river segments to be 

included in the National Wild & Scenic River System. A small number of private in-holdings and CCMA 

adjacent lands would need to be acquired (or placed under conservation easements) in stream corridors to 

maintain or restore their character. There would also be a modest cost associated with developing 

management plan(s) for all designated streams, and coordination with mining claim holders and private 

landowners to ensure that their activities would not cause offsite (downstream or downslope) impacts that 

could potentially affect river values. 

6. State or local political subdivision participation in river preservation and 

management. 

During the initial scoping period no government agencies commented or expressed interest specifically in 

wild and scenic river designation. However, numerous state and Federal agencies are committed to 

protecting river related values on the study segments. For example, the BLM and California State Parks 

OHV Division have funded grants to reduce sediment transport that result from watershed management 

activities in the CCMA. Plus, BLM is working with Regional Water Quality Control Districts and EPA to implement total 

maximum daily loads (TMDLs) for pollutants in San Benito River (mercury, sediment) and Clear Creek (sediment). In 

summary, there is already a strong established level of cooperation among Federal, state and local 

agencies to restore and protect the beneficial uses of streams in the region. 

7. Local Zoning and Land Use Planning Adequacy in protecting the river values. 

All of the stream segments included in this study are on Federal Lands administered by the BLM and 

local zoning would not apply. Where the segments cross private lands, most stretches are zoned for 

livestock, agriculture, or residential use. Livestock and agricultural uses at the scales foreseen within the 

study segments would not be compatible with Wild and Scenic River designation. Although the private 

land base in these watersheds could be developed for residences, it is likely to be low density and retain 

its rural character, which would be compatible with Wild and Scenic River designation. 

8. Federal, public, state, local or other interests in designation/non-designation of 

the river. Support or Opposition to the Designation. 

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A description of other Federal, state and local agency involvement and interest in river management is 

contained under item 6 above. Residents of the San Joaquin Valley and Hernandez Valley have a long 

history of active interest in water conservation for flood control and agriculture or livestock use. Although 

no comments specific to wild and scenic river designation were received during the scoping period, many 

comments were received regarding protection of river related values including water quality/quantity, 

riparian habitat, recreation opportunities, and scenic values. 

9. The consistency of designation with other agency plans, programs or policies 

and in meeting regional objectives. 

Wild and Scenic River designation for most of the study segments would be consistent with BLM’s goals 

for natural and cultural resources and other agency plans and programs for the region. However, wild and 

scenic river management and promoting recreational activities on the CCMA river segments in the 

Serpentine ACEC would not be consistent with BLM and EPA goals to provide adequate protection of 

human health and the environment. 

10. Contribution to River System or Basin Integrity 

The contribution of wild and scenic river designation to river system or basin integrity in the planning 

area would be minimal due to the current regulations and existing efforts to conserve water resources for 

beneficial uses. 

11. Management or Protection other than Wild and Scenic River Designation 

In the case of river segments that are found not suitable for designation, the Hollister Field Office will 

continue to manage these streams as integral ecosystem components on BLM public lands. Management 

objectives in this RMP/EIS call for continued emphasis on restoration of riparian ecosystems, and other 

components of healthy watersheds. The preferred alternative for this plan also calls for the BLM to 

submit applications to the State of California for federal water reserves to protect the aquatic habitat of 

streams on public lands. 

Recommendation and Rationale 

It is recommended that none of the eligible river segments identified in this study, as defined in Table 1, 

be designated as components of the NWSRS. 

Many of the river segments under evaluation have similar land tenure status, historical uses, and potential 

or existing uses. The primary factor for the non-suitable determination of all river study segments in the 

planning area was the conclusion that they would not make worthy additions to the system. Many of these 

watersheds have been substantially modified through past mining and logging activities and the 

associated construction of roads and trails. The resulting landscapes would not broaden the representation 

of key ecosystems within the Wild and Scenic River system. A second factor contributed to the nonsuitable recommendation for river segments in the Tucker Zone. Although these watersheds are currently 

somewhat undeveloped, local and regional planning may consider development in these areas to address 

California’s growing population. The anticipated level of development is not likely to change the 

character of the watersheds or be incompatible with Wild and Scenic River designation. Biological 

resources and other watershed values for all streams will be afforded protection through state and local 

land use plans, the Clean Water Act, and the Endangered Species Act. 

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iv. Protective Management 

All river segments found to be eligible for inclusion in the NWSRS are placed under protective 

management by the BLM. Subject to valid existing rights, the BLM is required to protect the free-flowing 

characteristics and outstandingly remarkable values in the stream corridors. The BLM must also protect 

the corridor from modifications that would impact the tentative river classification (i.e. change the 

classification potential from Wild to Scenic, or from Scenic to Recreational). These management 

restrictions apply only to public lands. Once suitability is determined and the Record of Decision (ROD) 

for the RMP signed, protective management continues only for those segments found suitable for 

designation. This protective management remains in effect until Congress makes a final decision 

regarding designation, or the CCMA RMP is amended. 

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Appendix VII - Best Management Practices for Wind Energy
 

Development on Public Lands
 

The BLM proposes that the following Best Management Practices (BMPs) be applied to all wind energy 

development projects to establish environmentally sound and economically feasible mechanisms to 

protect and enhance natural and cultural resources. These proposed BMPs were derived from the 

mitigation measures discussed in Chapter 5 of the Programmatic Environmental Impact Statement (PEIS) 

but are limited to those measures that are applicable to all wind energy development projects (PEIS 

Section 5.15). These BMPs would be adopted as required elements of project-specific PODs and/or as 

ROW authorization stipulations. They are categorized by development activity: site monitoring and 

testing, development of the POD, construction, operation, and decommissioning. The proposed BMPs for 

development of the POD identify required elements of the POD needed to address potential impacts 

associated with subsequent phases of development. 

Some of the proposed BMPs address issues that are not unique to wind energy development but that are 

more universal in nature, such as road construction and maintenance, wildlife management, hazardous 

materials and waste management, cultural resource management, and pesticide use and integrated pest 

management. For the most part, however, the level of detail provided by the BMPs is less specific than 

that provided in other, existing BLM program-specific mitigation guidance documents (PEIS Section 

3.6.2). As required by proposed policy (PEIS Section 2.2.3.1), mitigation measures identified in or 

required by these existing program-specific guidance documents would be applied, as appropriate, to 

wind energy development projects; however, they are not discussed in detail in the programmatic BMPs 

proposed here. 

In summary, stipulations governing specific wind energy projects would be derived from a number of 

sources: (1) the proposed BMPs discussed in this section; (2) other, existing and relevant programspecific mitigation guidance (PEIS Section 3.6); and (3) the mitigation measures discussed in PEIS 

Chapter 5. Guidelines for applying and selecting project-specific requirements include determining 

whether the measure would (1) ensure compliance with relevant statutory or administrative requirements, 

(2) minimize local impacts associated with siting and design decisions, (3) promote postconstruction 

stabilization of impacts, (4) maximize restoration of previous habitat conditions, (5) minimize cumulative 

impacts, or (6) promote economically feasible development of wind energy on BLM-administered land. 

Site Monitoring and Testing 

 The area disturbed by installation of meteorological towers (i.e., footprint) shall be kept to a 

minimum. 

 Existing roads shall be used to the maximum extent feasible. If new roads are necessary, they shall 

be designed and constructed to the appropriate standard. 

 Meteorological towers shall not be located in sensitive habitats or in areas where ecological 

resources known to be sensitive to human activities (e.g., prairie grouse) are present. Installation of 

towers shall be scheduled to avoid disruption of wildlife reproductive activities or other important 

behaviors. 

 Meteorological towers installed for site monitoring and testing shall be inspected periodically for 

structural integrity. 

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Plan of Development Preparation 

General 

1.	 The BLM and operators shall contact appropriate agencies, property owners, and other 

stakeholders early in the planning process to identify potentially sensitive land uses and issues, 

rules that govern wind energy development locally, and land use concerns specific to the region. 

2.	 Available information describing the environmental and sociocultural conditions in the vicinity of 

the proposed project shall be collected and reviewed as needed to predict potential impacts of the 

project. 

3.	 The Federal Aviation Administration (FAA)-required notice of proposed construction shall be 

made as early as possible to identify any air safety measures that would be required. 

4.	 To plan for efficient use of the land, necessary infrastructure requirements shall be consolidated 

wherever possible, and current transmission and market access shall be evaluated carefully. 

5.	 The project shall be planned to utilize existing roads and utility corridors to the maximum extent 

feasible, and to minimize the number and length/size of new roads, lay-down areas, and borrow 

areas. 

6.	 A monitoring program shall be developed to ensure that environmental conditions are monitored 

during the construction, operation, and decommissioning phases. The monitoring program 

requirements, including adaptive management strategies, shall be established at the project level 

to ensure that potential adverse impacts of wind energy development are mitigated. The 

monitoring program shall identify the monitoring requirements for each environmental resource 

present at the site, establish metrics against which monitoring observations can be measured, 

identify potential mitigation measures, and establish protocols for incorporating monitoring 

observations and additional mitigation measures into standard operating procedures and BMPs. 

7.	 “Good housekeeping” procedures shall be developed to ensure that during operation the site will 

be kept clean of debris, garbage, fugitive trash or waste, and graffiti; to prohibit scrap heaps and 

dumps; and to minimize storage yards. 

Wildlife and Other Ecological Resources 

 Operators shall review existing information on species and habitats in the vicinity of the project 

area to identify potential concerns. 

 Operators shall conduct surveys for federal- and/or state-protected species and other species of 

concern (including special status plant and animal species) within the project area and design the 

project to avoid (if possible), minimize, or mitigate impacts to these resources. 

 Operators shall identify important, sensitive, or unique habitats in the vicinity of the project and 

design the project to avoid (if possible), minimize, or mitigate impacts to these habitats (e.g., 

locate the turbines, roads, and ancillary facilities in the least environmentally sensitive areas; i.e., 

away from riparian habitats, streams, wetlands, drainages, or critical wildlife habitats). 

 The BLM will prohibit the disturbance of any population of federal listed plant species. 

 Operators shall evaluate avian and bat use of the project area and design the project to minimize 

or mitigate the potential for bird and bat strikes (e.g., development shall not occur in riparian 

habitats and wetlands). Scientifically rigorous avian and bat use surveys shall be conducted; the 

amount and extent of ecological baseline data required shall be determined on a project basis. 

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 Turbines shall be configured to avoid landscape features known to attract raptors, if site studies 

show that placing turbines there would pose a significant risk to raptors. 

 Operators shall determine the presence of bat colonies and avoid placing turbines near known bat 

hibernation, breeding, and maternity/nursery colonies; in known migration corridors; or in known 

flight paths between colonies and feeding areas. 

 Operators shall determine the presence of active raptor nests (i.e., raptor nests used during the 

breeding season). Measures to reduce raptor use at a project site (e.g., minimize road cuts, 

maintain either no vegetation or nonattractive plant species around the turbines) shall be 

considered. 

 A habitat restoration plan shall be developed to avoid (if possible), minimize, or mitigate negative 

impacts on vulnerable wildlife while maintaining or enhancing habitat values for other species. 

The plan shall identify revegetation, soil stabilization, and erosion reduction measures that shall 

be implemented to ensure that all temporary use areas are restored. The plan shall require that 

restoration occur as soon as possible after completion of activities to reduce the amount of habitat 

converted at any one time and to speed up the recovery to natural habitats. 

 Procedures shall be developed to mitigate potential impacts to special status species. Such 

measures could include avoidance, relocation of project facilities or lay-down areas, and/or 

relocation of biota. 

 Facilities shall be designed to discourage their use as perching or nesting substrates by birds. For 

example, power lines and poles shall be configured to minimize raptor electrocutions and 

discourage raptor and raven nesting and perching. 

Visual Resources 

1.	 The public shall be involved and informed about the visual site design elements of the proposed 

wind energy facilities. Possible approaches include conducting public forums for disseminating 

information, offering organized tours of operating wind developments, and using computer 

simulation and visualization techniques in public presentations. 

2.	 Turbine arrays and turbine design shall be integrated with the surrounding landscape. Design 

elements to be addressed include visual uniformity, use of tubular towers, proportion and color of 

turbines, nonreflective paints, and prohibition of commercial messages on turbines. 

3.	 Other site design elements shall be integrated with the surrounding landscape. Elements to 

address include minimizing the profile of the ancillary structures, burial of cables, prohibition of 

commercial symbols, and lighting. Regarding lighting, efforts shall be made to minimize the need 

for and amount of lighting on ancillary structures. 

Roads 

1.	 An access road siting and management plan shall be prepared incorporating existing BLM 

standards regarding road design, construction, and maintenance such as those described in the 

BLM 9113 Manual (BLM 1985) and the Surface Operating Standards for Oil and Gas 

Exploration and Development (RMRCC 1989) (i.e., the Gold Book). 

Ground Transportation 

2.	 A transportation plan shall be developed, particularly for the transport of turbine components, 

main assembly cranes, and other large pieces of equipment. The plan shall consider specific 

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object sizes, weights, origin, destination, and unique handling requirements and shall evaluate 

alternative transportation approaches. In addition, the process to be used to comply with unique 

state requirements and to obtain all necessary permits shall be clearly identified. 

3.	 A traffic management plan shall be prepared for the site access roads to ensure that no hazards 

would result from the increased truck traffic and that traffic flow would not be adversely 

impacted. This plan shall incorporate measures such as informational signs, flaggers when 

equipment may result in blocked throughways, and traffic cones to identify any necessary 

changes in temporary lane configuration. 

Noise 

	 Proponents of a wind energy development project shall take measurements to assess the 

existing background noise levels at a given site and compare them with the anticipated 

noise levels associated with the proposed project. 

Noxious Weeds and Pesticides 

	 Operators shall develop a plan for control of noxious weeds and invasive species, which 

could occur as a result of new surface disturbance activities at the site. The plan shall 

address monitoring, education of personnel on weed identification, the manner in which 

weeds spread, and methods for treating infestations. The use of certified weed-free 

mulching shall be required. If trucks and construction equipment are arriving from 

locations with known invasive vegetation problems, a controlled inspection and cleaning 

area shall be established to visually inspect construction equipment arriving at the project 

area and to remove and collect seeds that may be adhering to tires and other equipment 

surfaces. 

	 If pesticides are used on the site, an integrated pest management plan shall be developed 

to ensure that applications would be conducted within the framework of BLM and DOI 

policies and entail only the use of EPA-registered pesticides. Pesticide use shall be 

limited to nonpersistent, immobile pesticides and shall only be applied in accordance 

with label and application permit directions and stipulations for terrestrial and aquatic 

applications. 

Cultural/Historic Resources 

	 The BLM will consult with Indian Tribal governments early in the planning process to identify 

issues regarding the proposed wind energy development, including issues related to the presence 

of cultural properties, access rights, disruption to traditional cultural practices, and impacts to 

visual resources important to the Tribe(s). 

	 The presence of archaeological sites and historic properties in the area of potential effect shall be 

determined on the basis of a records search of recorded sites and properties in the area and/or, 

depending on the extent and reliability of existing information, an archaeological survey. 

Archaeological sites and historic properties present in the area of potential effect shall be 

reviewed to determine whether they meet the criteria of eligibility for listing on the National 

Register of Historic Places (NRHP). 

	 When any ROW application includes remnants of a National Historic Trail, is located within the 

viewshed of a National Historic Trail’s designated centerline, or includes or is within the 

viewshed of a trail eligible for listing on the NRHP, the operator shall evaluate the potential 

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visual impacts to the trail associated with the proposed project and identify appropriate mitigation 

measures for inclusion as stipulations in the POD. 

	 If cultural resources are present at the site, or if areas with a high potential to contain cultural 

material have been identified, a cultural resources management plan (CRMP) shall be developed. 

This plan shall address mitigation activities to be taken for cultural resources found at the site. 

Avoidance of the area is always the preferred mitigation option. Other mitigation options include 

archaeological survey and excavation (as warranted) and monitoring. If an area exhibits a high 

potential, but no artifacts were observed during an archaeological survey, monitoring by a 

qualified archaeologist could be required during all excavation and earthmoving in the highpotential area. A report shall be prepared documenting these activities. The CRMP also shall (1) 

establish a monitoring program, (2) identify measures to prevent potential looting/vandalism or 

erosion impacts, and (3) address the education of workers and the public to make them aware of 

the consequences of unauthorized collection of artifacts and destruction of property on public 

land. 

Paleontological Resources 

	 Operators shall determine whether paleontological resources exist in a project area on the basis of 

the sedimentary context of the area, a records search for past paleontological finds in the area, 

and/or, depending on the extent of existing information, a paleontological survey. 

	 If paleontological resources are present at the site, or if areas with a high potential to contain 

paleontological material have been identified, a paleontological resources management plan shall 

be developed. This plan shall include a mitigation plan for collection of the fossils; mitigation 

could include avoidance, removal of fossils, or monitoring. If an area exhibits a high potential but 

no fossils were observed during survey, monitoring by a qualified paleontologist could be 

required during all excavation and earthmoving in the sensitive area. A report shall be prepared 

documenting these activities. The paleontological resources management plan also shall (1) 

establish a monitoring program, (2) identify measures to prevent potential looting/vandalism or 

erosion impacts, and (3) address the education of workers and the public to make them aware of 

the consequences of unauthorized collection of fossils on public land. 

Hazardous Materials and Waste Management 

	 Operators shall develop a hazardous materials management plan addressing storage, use, 

transportation, and disposal of each hazardous material anticipated to be used at the site. The plan 

shall identify all hazardous materials that would be used, stored, or transported at the site. It shall 

establish inspection procedures, storage requirements, storage quantity limits, inventory control, 

nonhazardous product substitutes, and disposition of excess materials. The plan shall also identify 

requirements for notices to federal and local emergency response authorities and include 

emergency response plans. 

	 Operators shall develop a waste management plan identifying the waste streams that are expected 

to be generated at the site and addressing hazardous waste determination procedures, waste 

storage locations, waste-specific management and disposal requirements, inspection procedures, 

and waste minimization procedures. This plan shall address all solid and liquid wastes that may 

be generated at the site. 

	 Operators shall develop a spill prevention and response plan identifying where hazardous 

materials and wastes are stored on site, spill prevention measures to be implemented, training 

requirements, appropriate spill response actions for each material or waste, the locations of spill 

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response kits on site, a procedure for ensuring that the spill response kits are adequately stocked 

at all times, and procedures for making timely notifications to authorities. 

Storm Water 

	 Operators shall develop a storm water management plan for the site to ensure compliance with 

applicable regulations and prevent off-site migration of contaminated storm water or increased 

soil erosion. 

Human Health and Safety 

	 A safety assessment shall be conducted to describe potential safety issues and the means that 

would be taken to mitigate them, including issues such as site access, construction, safe work 

practices, security, heavy equipment transportation, traffic management, emergency procedures, 

and fire control. 

	 A health and safety program shall be developed to protect both workers and the general public 

during construction, operation, and decommissioning of a wind energy project. Regarding 

occupational health and safety, the program shall identify all applicable federal and state 

occupational safety standards; establish safe work practices for each task (e.g., requirements for 

personal protective equipment and safety harnesses; Occupational Safety and Health 

Administration [OSHA] standard practices for safe use of explosives and blasting agents; and 

measures for reducing occupational electric and magnetic fields [EMF] exposures); establish fire 

safety evacuation procedures; and define safety performance standards (e.g., electrical system 

standards and lightning protection standards). The program shall include a training program to 

identify hazard training requirements for workers for each task and establish procedures for 

providing required training to all workers. Documentation of training and a mechanism for 

reporting serious accidents to appropriate agencies shall be established. 

	 Regarding public health and safety, the health and safety program shall establish a safety zone or 

setback for wind turbine generators from residences and occupied buildings, roads, ROWs, and 

other public access areas that is sufficient to prevent accidents resulting from the operation of 

wind turbine generators. It shall identify requirements for temporary fencing around staging 

areas, storage yards, and excavations during construction or decommissioning activities. It shall 

also identify measures to be taken during the operation phase to limit public access to hazardous 

facilities (e.g., permanent fencing would be installed only around electrical substations, and 

turbine tower access doors would be locked). 

	 Operators shall consult with local planning authorities regarding increased traffic during the 

construction phase, including an assessment of the number of vehicles per day, their size, and 

type. Specific issues of concern (e.g., location of school bus routes and stops) shall be identified 

and addressed in the traffic management plan. 

	 If operation of the wind turbines is expected to cause significant adverse impacts to nearby 

residences and occupied buildings from shadow flicker, low-frequency sound, or EMF, sitespecific recommendations for addressing these concerns shall be incorporated into the project 

design (e.g., establishing a sufficient setback from turbines). 

	 The project shall be planned to minimize electromagnetic interference (EMI) (e.g., impacts to 

radar, microwave, television, and radio transmissions) and comply with Federal Communications 

Commission [FCC] regulations. Signal strength studies shall be conducted when proposed 

locations have the potential to impact transmissions. Potential interference with public safety 

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communication systems (e.g., radio traffic related to emergency activities) shall be avoided. 

	 The project shall be planned to comply with FAA regulations, including lighting regulations, and 

to avoid potential safety issues associated with proximity to airports, military bases or training 

areas, or landing strips. 

	 Operators shall develop a fire management strategy to implement measures to minimize the 

potential for a human-caused fire. 

Construction 

General 

	 All control and mitigation measures established for the project in the POD and the resourcespecific management plans that are part of the POD shall be maintained and implemented 

throughout the construction phase, as appropriate. 

	 The area disturbed by construction and operation of a wind energy development project (i.e., 

footprint) shall be kept to a minimum. 

	 The number and size/length of roads, temporary fences, lay-down areas, and borrow areas shall 

be minimized. 

	 Topsoil from all excavations and construction activities shall be salvaged and reapplied during 

reclamation. 

	 All areas of disturbed soil shall be reclaimed using weed-free native grasses, forbs, and shrubs. 

Reclamation activities shall be undertaken as early as possible on disturbed areas. 

	 All electrical collector lines shall be buried in a manner that minimizes additional surface 

disturbance (e.g., along roads or other paths of surface disturbance). Overhead lines may be used 

in cases where burial of lines would result in further habitat disturbance. 

	 Operators shall identify unstable slopes and local factors that can induce slope instability (such as 

groundwater conditions, precipitation, earthquake activities, slope angles, and the dip angles of 

geologic strata). Operators also shall avoid creating excessive slopes during excavation and 

blasting operations. Special construction techniques shall be used where applicable in areas of 

steep slopes, erodible soil, and stream channel crossings. 

	 Erosion controls that comply with county, state, and federal standards shall be applied. Practices 

such as jute netting, silt fences, and check dams shall be applied near disturbed areas. 

Wildlife 

	 Guy wires on permanent meteorological towers shall be avoided. 

	 In accordance with the habitat restoration plan, restoration shall be undertaken as soon as possible 

after completion of construction activities to reduce the amount of habitat converted at any one 

time and to speed up the recovery to natural habitats. 

	 All construction employees shall be instructed to avoid harassment and disturbance of wildlife, 

especially during reproductive (e.g., courtship and nesting) seasons. In addition, pets shall not be 

permitted on site during construction. 

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Visual Resources 

	 Operators shall reduce visual impacts during construction by minimizing areas of surface 

disturbance, controlling erosion, using dust suppression techniques, and restoring exposed soils as 

closely as possible to their original contour and vegetation. 

Roads 

	 Existing roads shall be used, but only if in safe and environmentally sound locations. If new roads 

are necessary, they shall be designed and constructed to the appropriate standard and be no higher 

than necessary to accommodate their intended functions (e.g., traffic volume and weight of 

vehicles). Excessive grades on roads, road embankments, ditches, and drainages shall be avoided, 

especially in areas with erodible soils. Special construction techniques shall be used, where 

applicable. Abandoned roads and roads that are no longer needed shall be recontoured and 

revegetated. 

	 Access roads and on-site roads shall be surfaced with aggregate materials, wherever appropriate. 

	 Access roads shall be located to follow natural contours and minimize side hill cuts. 

	 Roads shall be located away from drainage bottoms and avoid wetlands, if practicable. 

	 Roads shall be designed so that changes to surface water runoff are avoided and erosion is not 

initiated. 

	 Access roads shall be located to minimize stream crossings. All structures crossing streams shall 

be located and constructed so that they do not decrease channel stability or increase water 

velocity. Operators shall obtain all applicable federal and state permits. 

	 Existing drainage systems shall not be altered, especially in sensitive areas such as erodible soils 

or steep slopes. Potential soil erosion shall be controlled at culvert outlets with appropriate 

structures. Catch basins, roadway ditches, and culverts shall be cleaned and maintained regularly. 

Ground Transportation 

	 Project personnel and contractors shall be instructed and required to adhere to speed limits 

commensurate with road types, traffic volumes, vehicle types, and site-specific conditions, to 

ensure safe and efficient traffic flow and to reduce wildlife collisions and disturbance and 

airborne dust. 

	 Traffic shall be restricted to the roads developed for the project. Use of other unimproved roads 

shall be restricted to emergency situations. 

	 Signs shall be placed along construction roads to identify speed limits, travel restrictions, and 

other standard traffic control information. To minimize impacts on local commuters, 

consideration shall be given to limiting construction vehicles traveling on public roadways during 

the morning and late afternoon commute time. 

Air Emissions 

	 Dust abatement techniques shall be used on unpaved, unvegetated surfaces to minimize airborne 

dust. 

	 Speed limits (e.g., 25 mph [40 km/h]) shall be posted and enforced to reduce airborne fugitive 

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dust. 

 Construction materials and stockpiled soils shall be covered if they are a source of fugitive dust. 

 Dust abatement techniques shall be used before and during surface clearing, excavation, or 

blasting activities. 

Excavation and Blasting Activities 

	 Operators shall gain a clear understanding of the local hydrogeology. Areas of groundwater 

discharge and recharge and their potential relationships with surface water bodies shall be 

identified. 

	 Operators shall avoid creating hydrologic conduits between two aquifers during foundation 

excavation and other activities. 

	 Foundations and trenches shall be backfilled with originally excavated material as much as 

possible. Excess excavation materials shall be disposed of only in approved areas or, if suitable, 

stockpiled for use in reclamation activities. 

	 Borrow material shall be obtained only from authorized and permitted sites. Existing sites shall 

be used in preference to new sites. 

	 Explosives shall be used only within specified times and at specified distances from sensitive 

wildlife or streams and lakes, as established by the BLM or other federal and state agencies. 

Noise 

	 Noisy construction activities (including blasting) shall be limited to the least noise-sensitive times 

of day (i.e., daytime only between 7 a.m. and 10 p.m.) and weekdays. 

	 All equipment shall have sound-control devices no less effective than those provided on the 

original equipment. All construction equipment used shall be adequately muffled and maintained. 

	 All stationary construction equipment (i.e., compressors and generators) shall be located as far as 

practicable from nearby residences. 

	 If blasting or other noisy activities are required during the construction period, nearby residents 

shall be notified in advance. 

Cultural and Paleontological Resources 

	 Unexpected discovery of cultural or paleontological resources during construction shall be 

brought to the attention of the responsible BLM authorized officer immediately. Work shall be 

halted in the vicinity of the find to avoid further disturbance to the resources while they are being 

evaluated and appropriate mitigation measures are being developed. 

Hazardous Materials and Waste Management 

	 Secondary containment shall be provided for all on-site hazardous materials and waste storage, 

including fuel. In particular, fuel storage (for construction vehicles and equipment) shall be a 

temporary activity occurring only for as long as is needed to support construction activities. 

	 Wastes shall be properly containerized and removed periodically for disposal at appropriate offsite permitted disposal facilities. 

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	 In the event of an accidental release to the environment, the operator shall document the event, 

including a root cause analysis, appropriate corrective actions taken, and a characterization of the 

resulting environmental or health and safety impacts. Documentation of the event shall be 

provided to the BLM authorized officer and other federal and state agencies, as required. 

	 Any wastewater generated in association with temporary, portable sanitary facilities shall be 

periodically removed by a licensed hauler and introduced into an existing municipal sewage 

treatment facility. Temporary, portable sanitary facilities provided for construction crews shall be 

adequate to support expected on-site personnel and shall be removed at completion of 

construction activities. 

Public Health and Safety 

	 Temporary fencing shall be installed around staging areas, storage yards, and excavations during 

construction to limit public access. 

Operation 

General 

	 All control and mitigation measures established for the project in the POD and the resourcespecific management plans that are part of the POD shall be maintained and implemented 

throughout the operational phase, as appropriate. These control and mitigation measures shall be 

reviewed and revised, as needed, to address changing conditions or requirements at the site, 

throughout the operational phase. This adaptive management approach would help ensure that 

impacts from operations are kept to a minimum. 

	 Inoperative turbines shall be repaired, replaced, or removed in a timely manner. Requirements to 

do so shall be incorporated into the due diligence provisions of the ROW authorization. Operators 

will be required to demonstrate due diligence in the repair, replacement, or removal of turbines; 

failure to do so could result in termination of the ROW authorization. 

Wildlife 

	 Employees, contractors, and site visitors shall be instructed to avoid harassment and disturbance 

of wildlife, especially during reproductive (e.g., courtship and nesting) seasons. In addition, any 

pets shall be controlled to avoid harassment and disturbance of wildlife. 

	 Observations of potential wildlife problems, including wildlife mortality, shall be reported to the 

BLM authorized officer immediately. 

Ground Transportation 

	 Ongoing ground transportation planning shall be conducted to evaluate road use, minimize traffic 

volume, and ensure that roads are maintained adequately to minimize associated impacts. 

Monitoring Program 

	 Site monitoring protocols defined in the POD shall be implemented. These will incorporate 

monitoring program observations and additional mitigation measures into standard operating 

procedures and BMPs to minimize future environmental impacts. 

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	 Results of monitoring program efforts shall be provided to the BLM authorized officer. 

Public Health and Safety 

	 Permanent fencing shall be installed and maintained around electrical substations, and turbine 

tower access doors shall be locked to limit public access. 

	 In the event an installed wind energy development project results in EMI, the operator shall work 

with the owner of the impacted communications system to resolve the problem. Additional 

warning information may also need to be conveyed to aircraft with onboard radar systems so that 

echoes from wind turbines can be quickly recognized. 

Decommissioning 

General 

	 Prior to the termination of the ROW authorization, a decommissioning plan shall be developed 

and approved by the BLM. The decommissioning plan shall include a site reclamation plan and 

monitoring program. 

	 All management plans, BMPs, and stipulations developed for the construction phase shall be 

applied to similar activities during the decommissioning phase. 

	 All turbines and ancillary structures shall be removed from the site. 

	 Topsoil from all decommissioning activities shall be salvaged and reapplied during final 

reclamation. 

	 All areas of disturbed soil shall be reclaimed using weed-free native shrubs, grasses, and forbs. 

	 The vegetation cover, composition, and diversity shall be restored to values commensurate with 

the ecological setting. 

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Appendix VIII - Hollister Field Office Reasonably Foreseeable
 

Development Scenario for Oil and Gas 

I. Summary 

Based on an analysis of past oil and gas related activities within the boundaries of the Hollister Field 

Office (HFO) and the very small amount of federal mineral estate within areas of high development 

potential, we project that oil and gas activities on federal mineral estate within the Hollister Field Office 

area boundary will continue at a relatively minimal level. Overall, within the next 15-20 years, we project 

total surface disturbance due to all oil and gas activities on federal mineral estate to be no more than 74 

acres. This estimate includes geophysical exploration (seismic), 5 exploration wells, 10 development 

wells and associated facilities, roads, and a transmission pipeline that could be linked to existing 

transmission lines within the area. One third of this disturbance, 26 acres, will be temporary, and would 

be mostly to totally reclaimed within a few months to a couple of years. Over the long term, both new 

and existing oil and gas related activities would eventually be abandoned, the lands would be reclaimed, 

and the sites would be restored to as near a natural condition as practical. 

The total surface disturbance for up to 10 development wells would be 10 acres for well pads, 12 acres for 

roads, and 24 acres for a single transmission line 10 miles long. No more than 1 acre would be required 

for the small facility (meter, separator) on each of two parcels, for a total of 2 acres. The total surface 

disturbance caused by seismic operations, exploration drilling, and development would be 74 acres. 

Description Number Unit Surface 

Disturbance 

(acres) 

Total Surface 

Disturbance 

(acres) 

Exploratory Wells 

Well Pads 

Roads (40’ wide) 

5 wells 

5 x 0.5 miles 

1 acre/well 

4.8 acre/mile 

5 

12 

Development 

Well Pads 

Roads (40’ wide) 

Facilities 

10 

10 x 0.25 mi 

4 

1 acre/well 

4.8 acre/mile 

1 acre/facility 

10 

12 

4 

Seismic (2 track x 18”) 25 miles 0.36 acre/mi 9 

Pipeline (20 ‘ wide) 10 miles 2.4 acres/mi 24 

Total: 40 miles 74 74 

II. Introduction 

This appendix describes the scenario for the Reasonably Foreseeable Development (RFD) of oil and gas. 

The RFD scenario estimates the level and type of future oil and gas activity in the planning area and 

provides a basis for the analysis of cumulative effects. Based on current regulations and the small amount 

of projected activity on federal mineral estate within the planning area, this RFD is applicable regardless 

of which of the alternatives analyzed in the EIS is chosen as the Preferred Alternative. 

The scenario first describes the steps involved in exploring for and developing deposits of oil and gas. 

Trends and assumptions affecting oil and gas activity are discussed in this appendix, followed by 

estimates for future oil and gas exploration and development. 

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The scenario for reasonably foreseeable development is based on known or inferred oil and gas potential, 

and applies the conditions and assumptions discussed below. Changes in available geologic data or 

economic conditions may alter this scenario, and some deviation should be expected over time. The lands 

included are limited to those with BLM-administered minerals, including split estate with federal 

minerals. 

It should be noted that not all mineral estate managed by the BLM may have been identified at this time. 

For purposes of this document, we consider that all mineral estate managed by the BLM is covered by 

this RFD, even if we do not currently show the mineral estate on BLM maps. We also consider that 

mineral estate on lands that may be acquired in the future will also be covered by this RFD so long as the 

values and resources that are contained on the newly acquired lands do not differ significantly from those 

on existing known federal mineral estate. 

III. Petroleum Geology of the Hollister Field Office Area 

Refer to Section V, Oil and gas Occurrence and Development Potential. 

IV. Past and Present Oil and Gas Exploration and Development Activity 

There are 30 active oil fields and gas fields within the HFO management area, with a total administrative 

area of 188,000 acres. Within those administrative areas, the actual productive areas total about 58,000 

acres. During the past 10 years, more than 1000 wells have been drilled within the HFO area, 93% of 

which were within field boundaries, with only 7% being classified as wildcats (outside administrative 

field boundaries). Although there are nearly 5400 acres of federal mineral estate within these productive 

boundaries (9% of the total), there was not a single well on federal mineral estate. This trend is not likely 

to change much, because nearly all of the activity in each of the past 10 years occurred in 3 fields where 

the federal share of mineral estate is only 1%. 

Regarding new field discoveries, there have been fewer than 3 fields discovered within the last 10 years, 

none of which contained federal mineral estate. Because of the low amount of activity on federal mineral 

estate, a more detailed description of past and current activities throughout the entire HFO area is 

unnecessary. 

V. Oil and gas Occurrence and Development Potential 

The Hollister Field Office has areas of high, moderate, and low to none development potential. The size 

of each category is shown in the table below. 

Category Total Acres 

High 1,883,449 

Moderate 2,402,432 

Low to None 2,529,259 

Total 6,815,140 

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High Development Potential 

The areas of high oil/gas development potential occur in five areas. The areas, a total of 1,883,000 acres, 

are depicted in pink on Map 10. They will be described from north to south. 

The first area of high oil/gas development potential is in the extreme northern part of the Hollister Field 

Office area in Contra Costa County. This area is dominated by gas fields that produce from Eocene and 

Paleocene sedimentary rocks. 

The second area of high oil/gas development potential is in the Santa Clara Mountains of southeastern 

San Mateo and northwestern Santa Cruz Counties. There are no presently active oil or gas fields in the 

area. However, several drilling programs have identified potential production (“shows”) from Lower 

Tertiary and Upper Cretaceous formations in this area. 

The third area of high oil/gas development potential is in the central part of the Hollister Field Office area 

in northern San Benito County. The Sargent Oil Field produces from the Miocene Monterey Formation 

and Pliocene Purisima Formation of the San Juan Valley sedimentary basin. 

The fourth area of high oil/gas development potential is in southeastern San Benito County and western 

Fresno County. This area is part of the San Joaquin Basin, and has several oil fields that produce from 

Miocene and Pliocene marine sedimentary rocks. 

The fifth area of high oil/gas development potential is in southwestern San Benito County and 

southeastern Monterey County. The most important oil/gas field in this area is the San Ardo field. It, and 

the other oil fields in the area, produce from the Miocene Monterey formation in the Salinas sedimentary 

basin. 

Moderate Potential 

There are several areas of moderate potential within the Hollister Field Office area. These areas, a total of 

2,402,000 acres, are shown in yellow on Map 10. They are described as areas with Upper Cretaceous or 

Lower Tertiary sedimentary rocks containing many wells with oil and gas “shows” or even production, 

although generally not in economic quantities. Although these areas may contain numerous wells that 

either had production at one time, or had “shows”, they are classified as having only moderate potential 

because the rocks in this area are generally more highly fractured, and do not generally have trapping 

styles or cap rocks that permit sustained development from oil/gas accumulations. 

In the southern part of the Hollister Area Office, these rocks are found in three strips along the western 

central and eastern parts of the Area Office. The eastern strip of Moderate oil/gas potential lies west of 

high-potential areas of the Sacramento-San Joaquin Basin. This strip lies east of a mass of crystalline and 

Franciscan metamorphic rocks in the center of the Field Office Area, including the Clear Creek 

Management Area in the Diablo Mountain Range. 

The central strip of moderate oil/gas potential is bounded on the east by a mass of crystalline and 

Franciscan metamorphic rocks of the Diablo Range and a similar set of igneous and metamorphic rocks in 

the Coast Ranges. 

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The western strip of moderate oil/gas potential occurs between the coast and the western foothills of the 

Coast Ranges. 

Low to None Development Potential 

There areas of low to none (hereafter “low”) oil/gas development potential is defined as areas that are 

underlain dominantly by crystalline igneous rocks and metamorphic rocks of the Franciscan Formation. 

These areas of low oil/gas development potential, a total of 2,529,000 acres, are shown in green on Map 

10. 

There are five low potential zones in the Hollister Field Office. The low potential rocks occur in three 

discontinuous bands that run north-northwest to south-southeast in the eastern, central, and western parts 

of the Area Office. 

The eastern low potential zone is located in the Diablo Mountains and in the Tumey-Panoche Hills. It is 

divided into northern and southern segments by the Vallecitos Trough. 

The central low potential zone is located in the Coast Ranges as the core of a crystalline igneousmetamorphic faulted complex. 

The western low potential zone has two components. The northern component is in the Santa Lucia 

Range, and the southern component in the Santa Lucia Range. 

Occurrence Potential 

Refer to Map 10 in Appendix I to identify areas of oil and gas occurrence potential in CCMA. 

VI. RFD Baseline Scenario Assumptions, Discussion, and Estimated Surface 

Disturbance from Oil and Gas Activity on Federal Mineral Estate in the 

Hollister Field Office Area 

For purposes of this document, we have assumed that all potentially productive areas are open under 

standard lease terms and conditions, except those areas designated as closed to leasing by law, regulation, 

or executive order. Based on current regulations and policy and the small amount of projected activity on 

federal mineral estate within the planning area, this RFD is applicable regardless of which of the 

alternatives analyzed in the EIS is chosen as the Preferred Alternative. 

Future trends and assumptions: Based on the history of minimal activity for oil and gas exploration and 

development on federal lands within the planning area, activity over the next 15 to 20 years is likely to be 

sporadic. Oil and gas activity will probably consist of the issuance of some competitive and over-thecounter leases, a few geophysical surveys, and perhaps the drilling of 3-5 exploratory wells, with no more 

than 10 development wells, and the associated facilities/gas transmission lines. It is very unlikely that 

more than a total of 15 exploratory and development wells will be drilled on new federal oil and gas 

leases. While the large majority or even all of this activity is expected to occur in areas identified in this 

RFD as “High Development Potential,” there is always a possibility that federal minerals in other areas 

may see geophysical exploration, leasing, and even actual exploration and development drilling. It is 

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highly unlikely that any wells in such an area would be productive, so any associated surface disturbance 

would likely be short term. 

Geophysical exploration: Geophysical exploration is conducted to determine the subsurface structure of 

an area and the potential for mineral resources. There are three geophysical survey techniques that are 

generally used to define subsurface characteristics through measurements of the gravitational field, 

magnetic field, and seismic reflections. 

Gravity and magnetic field surveys—involve small, portable measuring units that are easily transported 

by light off-highway vehicles, such as 4-wheel drive pickup trucks and jeeps, or aircraft. Both off and onhighway travel may be necessary. Although these two survey methods can take measurements along 

defined lines, it is more common to have a grid of distinct measurement stations. Surface disturbance 

resulting from these surveys is negligible, consisting almost exclusively of soil or vegetation compaction 

that persists no more than a few months. 

Seismic reflection surveys—are the most common of the geophysical methods, and they produce the most 

detailed subsurface information. Seismic surveys are conducted by sending shock waves, generated by a 

small explosion or by mechanically beating the ground with a thumping or vibrating platform. 

In the explosive method, small charges are detonated on the surface or in a shallow drill hole. The 

surface charge method uses 1 to 5-pound charges attached to wooden laths 3 to 8 feet above the ground. 

Placing charges lower than 6 feet usually results in destruction of vegetation, whereas placing the charges 

higher, or on the surface of deep snow, results in little visible surface disturbance. In the drill hole 

method, holes for the charges are drilled using truck-mounted or portable air drills. In general, this 

method uses 4 to 12 holes per mile of line, and a 5 to 50-pound explosive charge is placed in each hole, 

covered, and detonated. The shock wave created is recorded by geophones placed in a line on the surface. 

In rugged terrain, a portable drill carried by helicopter can sometimes be used. The vehicles used for a 

drilling program may include heavy truck-mounted drill rigs, track-mounted drill rigs, water trucks, a 

computer recording truck, and a light pickup. 

In the mechanical method, four large trucks are usually used, each equipped with pads about 4-feet 

square. The pads are lowered to the ground, and the vibrations are electronically triggered from the 

recording truck. Once information is recorded, the trucks move forward a short distance and the process is 

repeated. Surface disturbance includes flattening of vegetation and compaction of soils. 

In either type of seismic reflection surveys, existing roads and trails are used where possible. However, 

off-road travel is necessary in some cases. Several trips per day are made along a seismograph line, 

usually resulting in a well defined two-track trail. 

It is expected that no more than three Notices of Intent, involving seismic reflection and gravity/magnetic 

field surveys across federal surface, would be filed under all Alternatives and the Proposed RMP during 

the life of this plan. Although it is unlikely, it is possible that one or two of the parcels with federal 

surface could be involved in a 3-D seismic proposal. If that occurs, the total expected surface disturbance 

could be up to 9 acres, based on up to 25 miles of seismic lines and a two track road with each track being 

18” wide. It is possible that much of the travel could be located on existing roads or other previously 

disturbed lands, and there could be some hand laying of lines, and that would result in less new 

disturbance. 

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Drilling phase: After a parcel is leased, there may or may not be any actual disturbance. In fact, 

historically, a large majority of leases are relinquished without ever having any actual surface disturbance. 

In the event that an Application for Permit to Drill (APD) is submitted, a site specific evaluation will be 

made by the BLM to ensure compliance with NEPA requirements. Based on the results of that 

evaluation, additional Conditions of Approval may be added, and the operator may only begin 

construction after complying with lease stipulations and Conditions of Approval of the drilling permit. 

When a site requires construction of an access road, the shortest feasible route is usually selected to 

reduce the haul distance and construction costs. Environmental factors or a landowner’s wishes may 

dictate a longer route in some cases. Drilling in the planning area is expected to be done using existing 

roads and construction of only short (approximately 0.5 mile) roads to access drill site locations. 

Even though there are 30 active oil fields and gas fields that are partly or totally within the Hollister FO 

area, only 9% land within the productive boundaries of those fields contains federal minerals (5400 

federal acres out of a total of more than 58,000 acres). In the past ten years, 1030 wells have been drilled 

in the entire FO area, but no wells have been drilled on federal minerals within the entire FO area. 

Consequently, based on the history of oil and gas exploration in the planning area, it is projected that no 

more than three to five exploratory wildcat wells (wells outside of the administrative boundary of existing 

oil and gas fields) would be drilled on BLM-administered land in the planning area during the life of this 

plan. Although the success rate for wildcat wells has improved markedly during the past decade, largely 

due to improved seismic data, it is still unlikely that any new fields would be discovered by drilling on 

federal minerals because there is so little activity in areas with significant amount of federal mineral 

estate. 

Most drilling is expected to occur in areas of land designated as high development potential (shown on 

Map 10). Although there is a low probability that a field will be discovered on federal land during the life 

of this plan, if a field containing federal land were to be discovered in the northern portion of HFO area, it 

is likely that the discovery would be gas because all of the occurrences in that area are gas. Conversely, if 

a field containing federal land were to be discovered in the southern portion of HFO area, it is likely that 

the discovery would be oil because all of the occurrences in that area are oil. 

During the first phase of drilling, the operator would move construction equipment over existing 

maintained roads to the point where the access road begins. Less than 0.5 mile of moderate duty access 

road per well with a gravel surface 20 feet wide is expected for construction. With ditches, cuts, and fill, 

the total width of surface disturbance would average 40 feet. The second part of the drilling phase is the 

construction of a drill pad up to 1 acre in size. The likely duration of well drilling, testing, and 

abandonment is 3 or 4 months per site. The total disturbance for each exploratory well and any new road 

is estimated to be 3.4 acres. The total surface disturbance caused by exploratory drilling of 3-5 wells over 

the life of this plan is expected to be no more than 10-17 acres. 

Field development and production: Exploratory drilling is not expected to lead to the development of a 

producing field in the planning area. Nonetheless, the following scenario describes the operations and 

effects associated with field development. 

The minimum size considered economically feasible would depend mainly on its proximity to existing 

infrastructure. There are many fields within the boundaries of the HFO area, mostly in the extreme 

southern and extreme northern portions of the area, and it is likely that any pipelines from a new field 

would be relatively short. The wells within the actual productive boundaries (smaller than the 

administrative boundaries) of gas fields are spaced on average at 80-160 acres. For oil fields in the HFO 

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area, spacing is much closer. In the larger oilfields, usual development spacing is typically at 5-7 acres 

per well. However, spacing can be as close as one well per acre in areas with heavy oil. Although it is 

unlikely that a new field will be discovered on federal minerals, for planning purposes we will assume a 

fairly small to mid size oil field may be discovered somewhere within the planning area. The average 

field size in the FO area is over 1900 acres, but that is significantly skewed by the presence of a few very 

large fields. The bottom 80% of the active fields in the FO area average 650 acres, about one square mile. 

If a single oilfield of that size was discovered, on average it would contain 9.1% federal mineral estate, 

about 60 acres. At 5-7 acres per well, it would take approximately 10 wells to fully develop the parcel. 

Each development well would require an estimated 0.25 mile of road, which would have a surface of 

crushed aggregate or gravel approximately 20 feet wide (total disturbed width of 40 feet). Well pads 

would be no more than 1 acre in size. Oil/gas produced would be carried by pipelines that could be 

linked to existing and proposed transmission lines in the planning area. Average infield pipeline length is 

estimated to be 0.25 mile per well, which could probably be largely contained within the road right of 

way and little new surface disturbance would be required. The total distance from a new field to an 

existing transmission pipeline is likely to be less than 10 miles. The width of the surface disturbance for 

pipelines would average 20 feet. 

The total surface disturbance for up to 10 development wells would be 10 acres for well pads, 12 acres for 

roads, and 24 acres for a single transmission line 10 miles long. No more than 1 acre would be required 

for the small facility (meter, separator) on each parcel. For planning purposes, we will assume that the 

wells may be on two separate parcels, so there would be a total of 2 acres for facilities. The total surface 

disturbance caused by seismic operations, exploration drilling, and development would be 74 acres. 

Description Number Unit Surface 

Disturbance 

(acres) 

Total Surface 

Disturbance 

(acres) 

Exploratory Wells 

Well Pads 

Roads (40’ wide) 

5 wells 

5 x 0.5 miles 

1 acre/well 

4.8 acre/mile 

5 

12 

Development 

Well Pads 

Roads (40’ wide) 

Facilities 

10 

10 x 0.25 mi 

2 

1 acre/well 

4.8 acre/mile 

1 acre/facility 

10 

12 

2 

Seismic (2 track x 18”) 25 miles 0.36 acre/mi 9 

Pipeline (20 ‘ wide) 10 miles 2.4 acres/mi 24 

Total: 40 miles 74 74 

Plugging and abandonment: Wells that are drilled and determined to be dry holes are plugged according 

to a plan designed for the condition of each well. Plugging involves placing cement plugs at strategic 

locations in the hole. Drilling mud is used as a spacer between the plugs to prevent communication 

between fluid-bearing zones. The drill casing is cut off at least 5 feet below ground level and capped by 

welding a steel plate on the casing stub. After plugging, all equipment and debris would be removed and 

the site restored as near as reasonably possible to its original condition. It is projected that much of the 

surface disturbance from exploratory activities and all of the seismic activities would be of short duration 

(between a few months and a couple of years). The impacts from the successful development wells 

would last longer, but it would still be completely reclaimed eventually 

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Military Bases – Fort Hunter Liggett military base is within the planning area. Leasing these lands 

requires consent from the local Base Commander. It has been shown in numerous cases across the 

country and within California that oil and gas exploration and development can often be conducted in a 

manner that is fully compatible with ongoing military operations. It is quite possible that negotiations 

between BLM and military personnel may result in agreement to lease lands within the boundaries of 

bases or other military lands. In the event that happens, appropriate leasing stipulations that would fully 

protect the military’s mission will be added prior to any land being leased. 

Authors: BLM Bakersfield Field Office 

Lead - Jeff Prude – Petroleum Engineer – Field Office Oil and Gas Program Lead 

Gregg Wilkerson - Geologist 

W/ Assistance from Larry Vredenburgh – GIS Specialist 

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Clear Creek Management Area Appendix IX 

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APPENDIX IX - CONFORMITY ANALYSIS CERTIFICATION 

PROJECT NAME:	 Clear Creek Management Area Resource Management Plan 

PROJECT LOCATION:	 Southern Portion of San Benito County and Western Fresno County, CA, 

(Case File - ) 

Fresno County, CA – PM-2.5 nonattainment 

Fresno County, CA – Serious PM-10 nonattainment 

Fresno County, CA – Serious 8-hr Ozone (NOx/VOC) nonattainment 

PROJECT DESCRIPTION:	 Establish or revise designations of vehicle use areas and routes. 

POTENTIAL TOTAL (DIRECT AND INDIRECT) EMISSIONS (tons/year): 

Carbon monoxide (CO): [Not applicable-attainment] n/a 

Lead (Pb): [Not applicable-attainment] n/a 

Nitrogen oxides (NOx): [Not applicable-de minimis] 0.6 tons/year 

Particulate Matter (PM10): [Not applicable-de minimis] 66.5 tons/year 

Particulate Matter (PM2.5): [Not applicable-de minimis] 10.0 tons/year 

Sulfur dioxide (SO2): [Not applicable-attainment] n/a 

Volatile Organic Compounds 

re: Ozone (O3): [Not applicable-de minimis] 0.6 tons/year 

MAXIMUM MODELED IMPACT (μg/m3

): 

Carbon monoxide (CO): [Not applicable-attainment] 

Lead (Pb): [Not applicable-attainment] 

Nitrogen dioxide (NO2): [Not applicable-attainment] 

Particulate Matter (PM10): [Not applicable-de minimis] 

Particulate Matter (PM2.5): [Not applicable-de minimis] 

Ozone (O3): [Not applicable-de minimis] 

Sulfur dioxide (SO2): [Not applicable-attainment] 

THIS PROJECT HAS BEEN DETERMINED TO CONFORM WITH ALL APPLICABLE LOCAL, 

STATE AND FEDERAL AIR QUALITY LAWS, REGULATIONS AND STATUTES, AS DEFINED 

IN THE San Joaquin Valley, CA (Fresno County) Planning Area IMPLEMENTATION PLAN(s), FOR 

THE FOLLOWING REASON(s): 

[ ] Action is covered within the approved Implementation Plan. 

[ ] Action is excluded by the Regulatory Authority per: 

[ ] Action is categorically excluded per (citation): 

[X]	 Potential total emissions are below de minimis levels: Per 40 CFR 93.153(b)(1) <50 T/Y NOx ; 

<50 T/Y VOC (Serious Ozone NAA); <70 T/Y PM-10 (Serious PM-10 NAA); and <70 T/Y PM2.5 (PM-2.5 NAA) 

[ ] Potential total emissions are fully offset by: 

[ ] Maximum modeled impacts are below applicable standards: 

[X]	 Other (specify): Subject to implementation per December 6, 2005 Fresno County, California,
 

Clear Creek Management Area Emission Spreadsheet and Assumptions. 

SIGNED: 

TITLE: Hollister Field Office Manager 

DATE: 

197
 
Clear Creek M allagement Area Appendix IX 

ProposedRMP alld Final EJS- Volume II 

Fresno County, Califurnia, Clear Creek Management Area Emission Spreadsheet and Assumptions (December 6, 2005) 

Citation: Archer, S.F. 2005. Microsoft Excel© Spreadsheet Estimate ofTotal and Fresno County Emissions by Alternative- Clear Creek 

Management Area EIS. ELM-National Science and Technology Center. Denver, Colorado. (See file: 051206_CCMA_Emissions) 

Summary Table: 

Total ALTA 


Annual TPY 


NOx 1.7 


PM-2.5 28A 


PM-10 190.0 


TSP 488.9 


voc 1.7 


Fresno Co. ALTA 


1'\nuual 

NOx 

TPY 


0.6 


PM-2.5 10.0 


PM-10 66.5 


TSP 17 l.J 

voc 0.6 


Note: Assmnes 35 per cent ofTotal Elnission would occur witJ1in Fresno County 


(CA) nonattairunem areas. 


Note: Alternative A = No Action A lternative. 


198 

Su 

Wint mm 

111 678 433 

ATV 180 20 60 

su 965 588 376 

v 11 72 39 

864 527 337 

MC 738 490 248 

Clear Creek Management Area 

Proposed RMP antl Final EIS- Volume II 

Appendix IX 

VOC and NOx Emission Estimates: 

AJV'HC+NOx Ef (gmlkin) = 1.5 

Sourc'e;_4JLCEEU051107 

SUV NMHC Ef (g·mfmi) = 0.31 

SUV NOx Ef(gmlmi) = 0.6 

So ...Ef8_ 2000 

MC HG+NOxEf (gmlkm}=2 0 

Source: 40 CFR 1051.105 

Note: VMT estimates for No Ad ion Alternative are based on 2005 visitor use trends. 

Total ALTA 

Annual TPY 

NOx 1.746 

voc 1.715 

Note: A TV and MC emission were assumed to be equally distributed between NMHC and NOx 

Note: VOC emission were assumed to be equivalent to NMHC an ell or HC 

Reference: 

EPA 2000. "California Certification Exhaust Emission Standards for Light-Duty Vehicles (Passenger Cars) and Light-Duty Trucks: 

Federal Test Procedure (FTP)- LDT110 Years/100,000 Miles" EPA420-B-00-001. February 2000. Researclh Triangle Park, NC. 

Available online at: http:/M\wt. epa. gov/otaqlcertlveh-cert/b00001f. pdf 

199 
Clear Creek Management Area Appendix IX 

ProposedRJJP andFinalEIS- Volume II 

Unpaved Road Emission Factors: 

Ef (lbs/VMT) =((k)x {sf1 2}•x (Sf30)"1(M/0,5)0] - C 

Source: EPA 2003 

Constants PM-2.5 PM-10 TSP 
 Assumptions ATV suv MC 

k= 0.27 1.8 6,0 
 10 10 15 

a= 1 
 W = 0.3 2.5 0.2 

d= 0.5 0.5 0.3 
 w = 4 4 2 

c= 0.2 0.2 0.3 


C= 0,00036 0.00047 0.00047 


Vv'here: 
 Where: 

s =silt (%) 


S =vehicle speed (mpi;l) 
 S = vehicle spee·d (mph) 

M =soil Moisture (%) 
 W = vehicle weight (tons) 

C=excess ex haust/brake/tire PM (lbs/VI'..rr) 
 w = number ofwheels 

Soilll]o.istpre. data source: N\IVS 2003 

Vehicle weight correction 

Precipitation correction factor factor 

Pcf =(d,- doo.p,.,) I ~ Wcf= ryYI3F 

Where: ,ATV suv MC 

d1=total number ofday s in season Wcf= 0.35 0.92 0.30 

d.a.o11n =days in season with :<: 0.01 in 

precipitation 

Winter Summer 

d,= 181 184 

d -401fn = 42 6 

Pcf= 0.77 0.9.7 

Precipitation data s.ource: WRCC 2003 

200 
Clear CreekManogementArea Appendix IX 

ProposedRMP andFinalEIS- Volume II 

Unpaved Road Emission Factors (continued): 

PM-25 Winter Wiptey- Winter Winter ·summer Summer Summer Summer 

Soil ATV suv MC Soil ATV suv MC 

Soil Unit Silt % Moist % lbs/VMT lbs/VMT lbs/VMT Moist % lbs/VMT lbs/VMT lbs/VMT 

742 30,7 40.0 0.04514 0.11719 0.04608 28.0 0.06107 0.15857 0.06235 

744 36.1 40.0 0.05309 0.13785 0.05420 28.0 0.07184 0.18652 0.07333 

757 25.8 40.0 0.03792 0.09845 0.03871 28.0 0.05131 0.13321 0.05238 

758 17.8 40.0 0.02613 0.06784 0.02668 28.0 0.03536 0.09180 0.03611 

761 18.0 40.0 0.02642 0.06861 0.02698 28.0 0.03576 0.09284 0.03651 

765 28.0 40.0 0.04116 0.10686 0.04202 28.0 :0.05569 0.14459 0.05685 

767 31.9 40.0 0.04691 0.12178 0.04788 28.0 0.06346 0.16418 0.06479 

768 8.1 40.0 0.01184 0.03073 0 01210 28 0 ·0.01602 0.04160 oP1637 

769 7.·6 40.0 0.01110 0.02882 0 01135 28 0 ·o01503 0.03901 oP1536 

770 38.6 40.0 0.0567.8 0.14742 0.05796 28.0 0.07682 0.19945 0.07842 

773 17.4 40.0 0.02554 0.06631 0.02608 28.0 0.03456 0.08973 0.03529 

774 16.6 40.0 0.02436 0.06325 0.02488 28.0 0.03297 0.08559 0.03366 

PM-~0 Winter Winter Winter Winter Summer Summer Summe'r Summer 

Soil ATV suv MC. Soil ATV suv Me 

Soil Uni~ Silt%. MOist% lbs'IVMT lbsNMT lbsjVMT Moist% lbs/VMT lbs/VMT lbs/VMT 

742 30.7 40.0 0.30144 0.78266 0.30764 28.0 0.40781 1 0.5884 0.41620 

744 36.1 40.0 0.35449 0.92038 0.36177 28.0 ·0.47957 1.24516 0.48943 

757 25.8 40.0 0.25331 0.65768 0.25852 28.0 0.34270 0.88977 0.34975 

758 17.8 40.0 0.17472 0.45365 0.17833 28.0 0.23638 0.61374 0.24126 

761 18.0 40.0 0.17669 0.45.875 0.18033 28.0 0.23904 0.62064 0.24397 

765 28.0 40.0 0.27492 0. 71379 0.28057 28.0 0.37193 0.96568 0.37958 

767 31. 9 40.0 0.31323 0.81326 0.31967 28.0 0.42376 1.10024 0.43247 

768 8.1 40.0 0.07944 0.20625 0.08109 28.0 0.10746 0.27906 0.10971 

769 7.6 40.0 U.Uf4:J:J U.1~:J:JU tiU~ ~~.U . 1UU~4 u.~o~~ ~ U.1U~9:J 

770 38.6 40.0 0.37904 0.98414 0.38683 28.0 0.51280 1.33142 0.52333 

773 17.4 40.0 0.17079 0.44345 0.17432 28.0 0.23107 0.59994 0.23583 

774 16.6 40.0 0.16294 0.42304 0.16630 28.0 '0.22044 0.57234 0.22498 

201 

Clear Creek MtuUJgementArea Appendix IX 

ProposedRMPandFinalEIS- Volwne II 

Unpaved Road Emission Factors (continued): 

S'oil AlV 

TSP Summer 

suv Me Soil ATV suv MG 

lbs/VMT lh>s/VMT lbs/VMT 

742 30J 40.0 0.80782 2 09740 0. 76016 2~ 0 1.13255 2.94052 1.06574 

744 36.1 40.0 0 94993 2.46638 0.89389 28.0 1.33178 3.45782 t25322 

757 25.8 40.0 0.67886. 1..76258 0.63882 28.0 0.95176' 2.47112 0.89561 

758 17.8 40.0 0.46832 1215.94 0.44070 2~ 0 0.65659 1.70475 0.61786 

761 18.0 40.0 0.47358 122961 0.44565 28.0 0.66397 1.72391 0.62481 

765 28.0 40.0 0.73676 19:1291 0.69330 28.0 1 03293 2.68187 0.97199 

767 319 40.0 0.83940 2 17.939 0. 78988 28.0 1.17682 3 05548 1.10740 

768 8,1 40.0 0.21304 0.55314 0.20049 28.0 0.29870 0.77553 0.28109 

769 7.6 40.0 0.j9988 0.51898 0.18810 2~ 0 0 28025 0.72763 0.26373 

770 38,6 40.0 t01372 2.63720 0.95580 28.0 1'12402 .3.69731 1,34001 

773 17.4 40.0 OA5779 r. 18861 043080 28.0 0.641,83 1.66643 0.60397 

774 16.6 40.0 0.43674 1.13395 0.41098 28.0 0.61231 158980 0.57620 

References: 

EPA 2003. c.ompilation ofAir Poll:utant Emission Factors,AP-42, FiftlfEdition, Volume 1: Stati-onary Pointand Area. Sources; 

Chapter 13, Misce'llaneousSources; 13.2.2 Unpaved Roads. Deceml;>er, 2003, Research Triangle Park, NC 

Available online at:. http:/Awvw.epa. govlttn/chief/ap42/ch 13/final/c13s0202.pdf 

National ~at her Service (NWS). 2003. Monthly Soil MoiSture Climatology- Soil ~tness: Calculated Soil Wetness Climatolog)t 

(1971-2000) Maps. Climate Prediction Genter. C.amp Springs, MD, 

Available online,at: h)tp /Awvw ~. ncep.noaa.gov soilmst,Wdim:_we ness frame.html 

Western Regional Climate Cent.er (WRCC). 2093. Historical Climate Information: Piiest Valley, California (047150}; 1948 to 2003. 

Rerio, NV. Available online·at http //Ww'W.wrcc.dri.edu/cgi,bin/diMAIN,pl?caprie+sca. 

202 
Clear Creek 1lfanagement Area Appendix IX 

Proposed RMP and Final EIS- Volume II 

VMT by Soil Unit for Alternative A: No Action Alternative 

Total Winter Summer 

VMT VMT VMT 

ATV 111180 67820 43360 


suv 96511 58872 37639 


MC 864738 527490 337248 


Note: VMT estimates were assumed t o remain constant regardless of management Alternative 

FractioRal ALTA ALTA ALTA 

Use By ATV suv MC 

VMT VMT VMT 

742 0.000 0.008 0.009 

744 0.073 0.063 0.044 

757 0.000 0.006 0.007 

758 0.001 0.001 0.001 

761 0.036 0.034 0.037 

765 0.209 0246 0.276 

767 0589 0.414 0494 

768 0.028 0.060 0.028 

769 0.077 0.088 0.081 

770 0.000 0.030 0.000 

773 0.000 0.020 0.006 

774 0.007 0.030 0.017 

TOTAL 1.000 1.000 1.000 

203 

Clear CreekManagementArea Appendix IX 

ProposedRMPand FinalEIS- Volume II 

VMT by Soil Unit for Altemative A: No Action AItemative (continued): 

ALTA Full Year Winter Wi~ter Winter Winter Summer Summer Summer Summer 

Total Total ATV suv MC Total ATV suv MC 

SoilUnit VMT VMT VMT VMT VMT VMT VMT VMT VMT 

742 0.0 471 .0 4747.4 0.0 301.1 3035.2 

744 4950.9 3708.9 23209.6 3165.3. 2371 .3 14838.9 

757 0.0 353.2 3692.4 0.0 225.8 2360.7 

758 67.8 58.9 527.5 43.4 37.6 337.2 

761 2441.5 2001.6 19517.1 1561 .0 1279.7 12478.2 

765 14174.4 14482.5 145587.2 9062.2· 9259.2 93080.4 

767 38589.6 24373.0 260580.1 24671.8 15582.5 166600.5 

768 1899.0 3532.3 14769.7 1214.1 2258.3 9442.9 

769 5222.1 5180.7 42726.7 3338.7 3312.2 27317.1 

770 0.0 1766.2 0.0 0.0 1129.2 0.0 

773 0.0 1177.4 3164.9 0.0 752.8 2023.5 

774 474.7 1766.2 89673 303.5 1129.2 5733.2 

TOTAL 67820 58872 527490 43360 37639 337248 

204 
Clear Creek ManagementArea Appendix IX 


ProposedRMP and FiJuJJ EIS- Vobune II 


Total PM Emissions for Alternative A No Action Alternative 

TetE~I ALTA 

Annual TPY 

PM-2.5 28 


PM-10 190 


TSP 489 


Emissions ALTA ALTA ALTA 

By PM-2.5 PM-tO TSP 

;S,UifUnil TPY TPY TPY 

742 0 2 4 

744 2 13 33 

757 0 3 

758 0 0 0 

761 1 5 12 

765 8 51 132 

767 16 107 276 

768 0 2 5 

769 1 4 11 

770 0 2 4 

773 0 3 

774 0 2 6 

TOTAL 28 190 489 

205 

Clear CreekManagementArea Appendix IX 


Proposed D1P andFinal EIS- Volume II 


Total PM Emissions for Alternative A: No Action Alternative (continued): 

ALTA Full Year Full Year Full Year Winter Winter 
 Winter Summer 
 Summer 
 Summer 

PM-2.5 PM-10 TSP PM-2.5 PM-10 
 TSP PM-2.5 
 PM-10 
 TSP 

Soil Unit TPY TPY TPY TPY TPY 
 TPY TPY 
 TPY 
 TPY 

2.1 742 
 0.1 0.9 2.3 0.1 0.8 

744 1.0 6.8 
 17.3 0.9 5.9 15.5 

757 
 0.1 0.6 
 1.5 0.1 0.5 1.3 

758 
 0.0 0.1 
 0.2 0.0 0.1 0.2 

761 0.4 2.4 
 6.2 0..3 
 2.1 5.5 

765 
 4.1 27.5 
 69.5 3.6 23.8 62.3 

767 
 8.6 57.6 
 145.7 7.5 49.8 130.6 

768 
 0.2 1.0 
 2.7 0.1 0.9 
 2A 

769 
 0.3 2.3 
 5.9 0.3 2.0 
 5.3 

770 
 0.1 0.9 
 2.3 0.1 0.8 
 2.1 

773 
 0.1 0.5 
 1.4 0.1 0.5 
 1.2 

774 
 0.2 1.2 
 2.9 
 0.1 
 1.0 
 2.6 


TOTAL 28 190 489 15 102 
 258 
 13 
 88 
 231 


206 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

Appendix X - Public Comments on the CCMA Draft RMP/EIS 

& BLM Responses 

This appendix contains a summary of the public comment letters received by the Hollister Field Office 

from agencies, organizations, and individuals on the Clear Creek Management Area Draft RMP and EIS, 

and responses to these comments prepared by BLM in accordance with 40 CFR 1504.3. 

During the public comment period, which extended from December 4, 2009 to April 19, 2010, 5,657 

comment submissions were received from individuals, agencies, and organizations. Many of these were 

form letters and/or emails containing identical text that had been suggested by environmental interest 

groups (2,885), private landowners (132), off-highway vehicle organizations (2,177), and rockhounding 

clubs (12). Each comment letter typically contained multiple individual comments on one or more of the 

topics addressed in the Draft RMP EIS. 

The commenters include federal and state officials; public interest groups; and private citizens. In 

compliance with the provisions of NEPA and CEQ regulations, public comments on the Draft RMP EIS 

were assessed both individually and collectively by BLM. Some comments resulted in changes or 

modifications to the PRMP/FEIS. A summary of major changes made in the Proposed RMP / Final EIS, 

in response to public comment, is provided in Chapter 1.9. 

Pursuant to NEPA, the BLM is only required to provide responses to comments that raise substantive 

environmental issues under NEPA in this appendix. However, the following sections include a summary 

of all the comments received during the public comment period for the CCMA Draft RMP and EIS in 

order to provide an overview of the concerns expressed during the comment period and to demonstrate 

the BLM decision-makers are aware of these concerns. All the comments received during the public 

comment period for the CCMA Draft RMP and EIS are included in the administrative record for the 

CCMA RMP/EIS and are available for review at BLM’s Hollister Field Office. 

Comments that were not associated with modifications to the PRMP/FEIS may have generated responses 

to correct readers’ misinterpretations, to explain or communicate government policy, to clarify the scope 

of the PRMP/FEIS, to explain the relationship of the PRMP/FEIS to other documents, to refer 

commenters to other information in the PRMP/FEIS to answer technical questions, or to further explain 

technical issues. 

Comment summaries and responses to comments are provided in Chapters I, II, & III of this appendix. 

The comment summaries provide a brief overview of the comments for the reader’s convenience in 

reviewing the responses, and are not intended to provide a complete representation or interpretation of the 

comment’s meaning. BLM’s responses are based on the comments in the letters themselves. 

Frequently, more than one commenter submitted identical (or form letter) comments; in those cases, 

comments were grouped together, summarized, and given a single response. Common Responses to 

Public Comments in Chapter I provide an example of the comment to summarize the issues, followed by 

a “Common Response” prepared by BLM in accordance with 40 CFR 1504.3. 

An alpha-numeric identifier was used to develop the “Comment Code” for each comment letter and/or 

email received by the Hollister Field Office. 

Table X-1 lists the agencies and organizations that submitted comments on the CCMA Draft RMP and 

EIS. Table X-2 provides a summary of agency and organization comments on the CCMA Draft RMP and 

EIS. and BLM’s responses to these comments. 

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Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

Table X-3 and Table X-5 list the names (or emails) of people that submitted individual comments or form 

letters on the CCMA Draft RMP/EIS, respectively. Table X-4 and Table X-6 provide a summary of these 

comments (or form letters) on the CCMA Draft RMP/EIS and BLM’s responses to these comments, 

respectively. 

A legend of “Comment Codes” used to track comments on the CCMA Draft RMP and EIS is provided 

below. 

Comment Code Legend 

AG-*NAME*: Agency Comment 

ORG-*NAME*: Organization (or Club) Comment 

IND-COM: Individual Commenter 

BRC-FORM: BlueRibbon Coalition Form Letter 

CBD-FORM: Center For Biological Diversity Form Letter 

EXT-COM: Request to Extend Public Comment Period 

STT-FORM: Save the Trails Form Letter 

HVPO-FORM: Hernandez Valley Propoerty Owners Form Letter 

HGMC Form Letter: Hobby Gem and Mineral Collectors Form Letter 

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Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

I. BLM’S COMMON RESPONSES TO PUBLIC COMMENTS 

This appendix provides a listing of all the agencies, organizations, and individuals that submitted 

comments on the CCMA Draft RMP/EIS and a summary of their comments. Each comment summary is 

followed by a brief response to the substantive issues or concerns regarding the CCMA Draft RMP/EIS. 

Note: Public comments reviewed by the Hollister Field Office demonstrate significant effort by several 

reviewers to understand and evaluate the uncertainties inherent in human health risk asssessments and the 

time dedicated by these individuals to quantitatively estimate the effects are appreciated and the following 

responses are given to his detailed comments. 

Many of the public comments received on the CCMA Draft RMP/EIS discussed the same issues or 

environmental concerns. Rather than repeat responses over and over again, “Common Responses” were 

prepared to address those issues or concerns. Accordingly, the responses to those comments refer the 

reader to the applicable “Common Response” by identifying the section number and letter for the 

“Common Response” below to which the comments apply. For example, “Section 1A” provides a 

response to comments regarding the “definition of asbestos and chrysotile toxicity”. 

The “Common Responses” are listed briefly below and are provided in full in the following sections: 

 ̈ Section 1: Non-NEPA/BLM Issues 

A. Definition of Asbestos and Chrysotile Toxicity 

B. Amphiboles Detected in EPA Air Samples 

C. EPA Risk Assessment Methodology 

D. EPA Risk Assessment Results 

E. R.S. 2477 

F. Issues Considered, but Not Analyzed 

G. General Comments, Non-Substantive 

 ̈ Section 2: Purpose and Need 

A. EPA Risk Assessment 

B. Endangered Species Act 

C. Social and Economic Conditions 

 ̈ Section 3: Project Alternatives 

A. Range of Alternatives 

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Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

B. No Action Alternative 

C. Alternative D 

D. Preferred Alternative 

 ̈ Section 4: Impact Analysis 

A. Risk Assessments and Uncertainty 

B. Impacts to OHV Recreation 

C. Impacts to Other Resources 

D. Social and Economic Effects 

E. Cumulative Effects 

Section 1: Non-NEPA/BLM Issues 

Many comments raised concerns that are not environmental issues within the context of the National 

Environmental Policy Act (NEPA) or are outside the scope of the CCMA RMP/EIS because they are not 

under the authority or within the jurisdiction of the BLM. 

Pursuant to NEPA, the BLM is only required to provide responses to comments that raise substantive 

environmental issues under NEPA in this appendix. Responses to public comments that are nonsubstantive, excessive, or outside the scope of BLM’s land use decisions for the CCMA are limited to a 

brief explanation of how the BLM’s Draft RMP/EIS and Proposed RMP and Final EIS addressed the 

comments or the rationale for the proposed action. 

The following comments do not raise issues under the National Environmental Policy Act (NEPA) or that 

are outside the authority of the United States Bureau of Land Management (BLM). 

A. Definition of Asbestos and Chrysotile Toxicity 

Many public comments suggested the word “asbestos” is being used improperly and questioned whether 

the reference to a specific mineral is more appropriate. 

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Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

Example: 

ORG-3ROCKS: 

According to the United States Geological Survey, “Asbestos is a generic name given to six fibrous 

minerals that have been used in commercial products.” The definition is expanded further in the USGS 

Open-File Report 02-149 as, “These fibers belong to two mineral groups: serpentines and amphiboles. 

The serpentine group contains a single asbestiform variety: chrysotile. There are five asbestiform 

varieties of amphiboles: anthophyllite asbestos, grunerite asbestos (amosite), riebeckite asbestos 

(crocidolite), tremolite asbestos, and actinolite asbestos.” (Virta 2002:5). The EPA asbestos risk 

assessment is based on 1986 data (EPA 1986) and fails to consider the current EPA opinion which admits 

that chrysotile is much less potent (EPA 2008), and may, in fact, not be a human health risk. 

Response: 

Section 4.2.3.1 of the CCMA Draft RMP/EIS and Proposed RMP/FEIS include the definition of asbestos 

provided by the U.S. Department of Health and Human Services’ Agency for Toxic Substances and 

Disease Registry, and explains that “The two general types of asbestos are amphibole and chrysotile 

(fibrous serpentine). Chrysotile asbestos has long, flexible fibers. This type of asbestos is most commonly 

used in commercial products. Amphibole fibers are brittle, have a rod or needle shape, and are less 

common in commercial products. Although exposure to both types of asbestos increases the likelihood of 

developing asbestos-related diseases, amphibole fibers tend to stay in the lungs longer. They also are 

thought to increase the likelihood of illness, especially mesothelioma, to a greater extent than chrysotile 

asbestos.” 

While there is some debate within the scientific community regarding the varying potencies of the 

different types of asbestos relative to certain cancers, there is no debate that all types of asbestos cause 

cancer and debilitating and fatal non-cancer disease. 

B. Amphiboles Detected in EPA Air Samples 

Many public comments repeated claims that no amphibole asbestos fibers were previously detected in 

New Idria Basin and that the amphiboles detected by EPA were a result of mining and other industrial 

uses in the area. 

Example: 

ORG-3ROCKS: 

The subject Serpentine ACEC is known for its naturally occurring chrysotile deposit, and is known to be 

free of natural amphibole asbestos fiber. 

Response: 

By using activity-based sampling, EPA collected air samples which represented exposures over a large 

geographic area, in comparison to soil samples collected from discrete locations. The air samples were 

analyzed by Transmission Electron Microscopy, which permitted the identification of fiber mineralogy. 

Amphiboles were identified in 8% percent of the samples. It is not uncommon for both chrysotile and 

amphibole asbestos to be found in the same general locations. “...Chrysotile occurs most commonly in 

serpentinites and serpentinized ultramafic rocks but may also occur in altered or metamorphosed mafic 

rocks or in metamorphosed carbonate rocks. The amphibole asbestos minerals (tremolite, actinolite, 

anthophyllite, riebeckite, and cummingtonite-grunerite) also occur in and immediately adjacent to 

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Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

serpentinites and serpentinized ultramafic rocks and in a variety of other metamorphosed rocks...” John 

P. Clinkenbeard and Ronald K. Churchill. Geology of naturally occurring asbestos in California; 

Geological Society of America, Cordilleran Section, 101st annual meeting; American Association of 

Petroleum Geologists, Pacific Section, 80th annual meeting Abstracts with Programs – Geological 

Society of America, Vol. 37, No. 4, Apr 2005, pp. 37. 

C. EPA Risk Assessment Methodology 

Comments from Friends of CCMA and many others reflect concerns that the samples used by EPA for 

the Risk Assessment are skewed toward the dry season, and/or the Risk Assessment does not represent 

“typical” CCMA user situations. 

Examples: 

ORG-SCC: 

The exposure durations and visits per year do not represent typical CCMA use patterns. The most 

frequent users of CCMA ride solo or in the lead position. If this was taken into account in the risk 

calculations, the Assessment would be more accurate and the numbers would be significantly lower. 

The air samplers ran continuously and collected samples when the rider was encountering a dust cloud. 

In actual practice, a rider would avoid or hold his/her breath when traversing a dust cloud. Therefore, 

the sampling method caused overestimation of actual asbestos exposure. 

The exposure measurement did not take into account the precautions BLM publishes for riding at CCMA, 

i.e. “If riding an OHV in a group, spread out along the trail, and don’t ride in another rider’s dust.” 

The Risk Assessment overestimates the speed, distance, and time-spent while riding at CCMA. 

ORG-BRC: 

The Risk Assessment is flawed because riders spent too much time on Clear Creek Road. 

ORG-FOCCMA: 

The samples used by EPA for the Risk Assessment are skewed toward the dry season, and the Risk 

Assessment therefore does not represent “typical” CCMA user situations. The samples do not reflect the 

distribution anticipated in the Sampling and Analysis Plan. 

The results are “atypical” of actual use conditions because photographs taken during the EPA sampling 

events show that the BLM graded the road prior to the sampling to increase dust production and asbestos 

exposure levels. 

Response: 

Recreation use scenarios adequately represent typical use in the CCMA for the following reasons. The 

visits per year actually came from the 1992 PTI Health Risk Assessment and are based on national 

recreational survey data and statements of CCMA users. The 30-year exposure duration is standard for 

recreational exposures per the EPA Risk Assessment Guidance for Superfund. Further, many CCMA 

users have stated that they have been riding at CCMA for more than 30 years. The risk numbers were 

expressed in ranges to provide information that users could adjust to their personal exposure experience. 

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Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

Activity-based sampling has been used for decades to measure exposures in occupational environments 

and is currently the standard practice for environmental exposures to asbestos. The sampling methods 

used at CCMA were based on discussions of typical uses that EPA had with BLM rangers and members 

of the OHV community. 

The sample collection was designed to capture typical exposures. Any change in concentration and 

duration of exposure will change the estimated risk. The EPA risk estimations reflect assumptions about 

exposure and duration in the context of standard EPA risk assessment methodology. For example, 

avoiding dust would reduce the exposure to trailing riders and the overall risk of asbestos-related disease. 

Certainly, if someone spends an hour riding, the exposure will be less than someone who rides for 6 

hours. However, the assumptions about vehicle speed provided in the CCMA Draft RMP/EIS were not a 

factor in the overall risk calculations because the results are based on the analysis of the air samples 

collected by EPA riders conducting the Risk Assessment. The estimated speeds were derived by 

approximating the area covered and dividing by the time the sampler was on the trails. The concentration 

of asbestos found in the breathing zone during the rides is the important information. Ultimately, the risk 

factors for an individual may be less or more than those shown in the Risk Assessment, based on 

individual riding practices and exposures. 

The photographs referenced in the EPA risk assessment were taken at the beginning and end of one of the 

sampling events as the riders were returning to the staging station at the Oak Flat campground. With the 

exception of the SUV driving/riding scenario, the road riding was only a portion of the total route and 

therefore only a portion of the exposures measured. It is representative of typical CCMA activity that 

riders start from the Oak Flat campground and travel on the road a short distance to access the trails. 

Sampling on the road was minimized for those riders whose air pumps had timed-out before returning to 

the staging area. All available information indicates that road conditions were typical of usual CCMA 

conditions. Therefore, BLM and EPA determined that the data used in the Risk Assessment were 

indicative of typical use scenarios.The Sampling and Analysis Plan charts for the number of samples to be 

collected at CCMA only included the three days of sampling conducted in November 2004. It was not 

intended to represent the total samples collected or the seasonal distribution. 

To complete the CCMA risk assessment, EPA conducted sampling over 9 days from September 2004 to 

September 2005. Five of the 9 days were during the winter months, representing moist and wet 

conditions. Of the sample results used in the Risk Assessment, approximately 50% were from dry 

sampling days and the remaining 50% were from moist and wet sampling days. As the attached chart 

(CHART-1C) shows, the EPA results for the dry season and the wet or “moist” season are comparable. 

There was no significant difference in the concentrations between dry and wet exposures. 

In response to public comments, the statement below was inserted into Section 4.2.4.1 (Impacts from 

Mitigation Measures for Alternatives A, B, C, and D) of this PRMP/FEIS. 

Under Alternative A, BLM would continue to enforce seasonal use restrictions to limit vehicle use to 

major roads in the Serpentine ACEC from June 1 to October 15. Alternatives B and C would further 

restrict the season of use from December 1 – April 15. Alternative D would allow vehicle use on major 

roads in the Serpentine ACEC all year-round. Human health risks from airborne asbestos exposure would 

be similar under all alternatives. Restricting the season of use would have negligible impacts on asbestos 

exposure and human health risk because EPA’s CCMA AEHHRA (2008) explains that wet weather 

reduces but does not eliminate exposure. For example, the September 2004 and September 2005 sampling 

events were conducted under dry conditions, and the November 2004 sampling event was conducted 

within one week of a two day rainfall event that produced about one inch of precipitation in the CCMA 

area, and the preceding month of October was very rainy. During the November sampling event, lowlying areas contained standing water, while elevated areas were nearly dry. EPA further explains that 

213
 
 

 

 

 

 

 

 

 

 

Clear Creek Management Area 

Proposed RMP & Final EIS – Volume II Appendix X 

many of the concentrations in the samples from the November event were actually higher than those 

measured in the September events, leading to a higher overall mean and 95% UCL for the “moist” event. 

Based on the EPA sampling, it appears that only active rainfall reduces asbestos air concentrations. 

Reasons why include topographic and soil factors affecting soil moisture such as slope, aspect, 

permeability, drainage and surface runoff, but further study would be necessary to define the exact 

conditions necessary to reduce dust generation. Additionally, because precipitation is so variable in the 

project area, it would be difficult to predict when conditions would typically be wet enough to reduce 

risk. As a result, seasonal use restrictions would only provide minor benefits for human health. 

214
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS– Volume II 

CHART-1C (below) shows, the EPA results for the dry season and the wet or “moist” season are comparable. There was no significant difference 

in the concentrations between dry and wet exposures. 

CHART-1C: Comparison of Mean and 95% UCL for All Data1 and Wet Season Data2 – Riding Positions from motorcycling and ATV 

riding only. 

Concentrations are PCME f/ml as defined in EPA’s CCMA Asbestos Exposure and Human Health Risk Assessment (May 2008). 

Position 

No. Valid 

Data -

All/Wet 

No. Detected 

Data - All/Wet 

All 

Mean 

Wet 

Mean Difference 

Ratio Wet 

to All 

Mean 

All 

UCL 

Wet 

UCL Difference Ratio Wet to All UCL 

Adult Lead 41/20 35/17 0.0673 0.0554 0.0119 0.8232 0.1040 0.1010 0.0030 0.9712 

Adult First 

Trailing 37/20 34/17 0.2480 0.2720 -0.024 1.0968 0.3940 0.3300 0.0640 0.8376 

Adult 

Second 

Trailing 

17/10 16/9 0.5630 0.4800 0.083 0.8526 1.0790 1.2720 -0.1930 1.1789 

Child Lead 36/17 33/14 0.0991 0.0971 0.002 0.9798 0.1660 0.1960 -0.0300 1.1807 

Child First 

Trailing 31/14 31/14 0.3830 0.4760 -0.093 1.2428 0.5950 1.27703 -0.682 2.9529 

Child 

Second 

Trailing 

17/10 17/10 0.5410 0.4880 0.053 0.9020 0.6730 0.6770 -0.0040 1.0059 

1. All data includes results from Sept ’04, Nov ’04, Feb ’05 and Sep ’05. 

2. Wet data includes results from only Nov ’04 and Feb ’05. 

3. Maximum result, UCL exceeds max detected. 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

D. EPA Risk Assessment Results 

Example: 

AG-DPR-OHMVRD: 

The significance and accuracy of the information presented in the Health Risk Assessment is 

open to debate 

The Division believes serious questions have been raised about the Health Risk Assessment, such 

as identification and differentiation of chrysotile and amphibole asbestos, asbestos-related 

epidemiology, appropriateness of risk models, and activity based sampling methods. 

ORG-BRC: 

The EPA calculated health risks in the DEIS are inherently flawed because they are based on the 

original calculations in the original risk assessment. 

Response: 

EPA Region 9 used standard and accepted practices for environmental asbestos sample 

collection, sample analysis, and risk assessment. The EPA Risk Assessment for CCMA was 

reviewed by members of the Agency’s Technical Working Group for Asbestos, the California 

Department of Toxic Substances Control (DTSC), and the California Office of Environmental 

Health Hazard Assessment (OEHHA). EPA reviewers and both California agencies agreed with 

and support Region 9’s methods and findings. Domestic and international health and scientific 

organizations, including the State of California, the EPA, the Centers for Disease Control, the 

National Toxicology Program, the National Institute for Occupational Safety and Health 

(NIOSH), the Occupational Safety and Health Administration (OSHA), the World Health 

Organization International Agency for Research on Cancer, and the International Program on 

Chemical Safety, have all classified chrysotile asbestos as a known human carcinogen. 

Both the IRIS and California OEHHA toxicity values were used to demonstrate the range of 

possible quantitative estimates. The toxicity values are based on the same dose response studies 

but EPA’s toxicity value is a mean of the dose and the OEHHA value is based on the more health 

protective upper confidence limit. While there is some debate within the scientific community 

regarding the varying potencies of the different types of asbestos relative to certain cancers, there 

is no debate that all types of asbestos cause cancer and debilitating and fatal non-cancer disease. 

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E. R.S. 2477
 

Examples: 

ORG-3ROCKS: 

All of the main arterial highways passing over the subject public lands were clearly established 

before Congressional passage to the Federal Land Policy Management Act of 1976, which 

repealed Federal Revised Statute 2477. 

[BLM proposes] to decommission or vacate public highways and to otherwise impair public use 

of historically established road and ways within the subject area. 

Decommissioning roads, the county's abandonment of roads, or otherwise vacating roads only 

effect the government's responsibility to the roads, but in no way impairs the public's right to use 

or maintain the public road or way (Chollar-Potosi v. Kennedy 93 Am. Dec. 409; Brown v. Stone 

69 Am. Dec. 303). 

Additionally, the long history of uninterrupted use and enjoyment of the roads and right of way 

conferred titled to the private property assignees in common, and perhaps in common with the 

public, and have also established prescriptive right to continue to enjoy the roads and rights of 

ways (Pierce v. Cloud, 82 Am. Dec. 496; Chollar-Potosi v. Kennedy 93 Am. Dec. 409; Hill v. 

Crosby, 13 Am. Dec 448). 

Historically established public highways within the subject area include, but are not limited to, 

the roads and trails as marked on the maps tabulated in Table 1 and Table 2 on page 5 of Ray 

Iddings Substantive Comments; submitted March 3, 2010. 

MSBT-LAW: 

Per Congressionally enacted Revised Statute 2477, the public has a right of access of roads and 

highways to facilitate their right-of-way. This document presents various scenarios that would 

inhibit the right of the public to travel over previously designated public and county roads and 

highways, in opposition to all rights and privileges granted to members of the public. 

Response: 

BLM's Proposed Plan and Final EIS does not include proposals to decommission or vacate these 

public highways, and the proposed restrictions on public use of designated routes within the 

subject area would allow for continued historical uses except for OHV recreation due to the 

human health risk identified in Chapter 4 and the EPA Asbestos Exposure and Human Health 

Risk Assessment (2008). 

Under the Proposed Action, BLM would provide rights of ways over the public lands to and from 

the private properties within the subject area. Under the Proposed Plan and Final EIS, BLM 

would require private property owners to acquire rights-of-ways (ROWs) for use of routes off the 

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public highways administered by the County of San Benito. The BLM's authority for 

administering rights-of ways across public lands was established in Article V of FLPMA, which 

allows Field Office managers discretion to waive charges and fees for ROWs. These ROWs 

would not dictate terms of use for private property or public highways which supersede their 

jurisdiction and BLM would honor valid existing rights for access to private property. 

The issues related to R.S. 2477 are outside the scope of BLM’s land used decisions for 

transportation and travel management on CCMA public lands because the U.S. Tenth Circuit 

Court of Appeals ruled that the validity of R.S 2477 claims can only be determined through the 

courts. 

The following roads; Clear Creek (R1), Mexican Lake (R11), Wildass (R15), and Sawmill Creek 

(T158) have been informally identified as “County Roads” for a number of years. However, no 

record exists that San Benito County has a right of way or any legal right to these roads. The 

BLM has no record that the County established a right-of-way on the 26.1 miles of roads. The 

County has provided no information to the BLM to assert any rights-of-way and takes no 

responsibility for the roads, so by default these are Federal roads. 

Furthermore, San Benito County abandoned road maintenance on these roads in 1994 and has not 

conducted maintenance on them for 16 years. Lack of maintenance has resulted in impacts to 

natural resources, including water quality, habitat for Federally listed species, and public health 

and safety. Public health and safety are being adversely affected by the lack of appropriate road 

maintenance, and in fact this has resulted in death and injury to the public. Unlimited use of these 

roads exposes the public to airborne asbestos and poses a health hazard. 

Nevertheless, BLM, existing rights-of-way holders, and private property owners with in-holdings 

still need reliable access to the area for resource management and other purposes, but are 

frequently impeded due to the unmanaged condition of the roads. Improper road maintenance 

can also lead to excessive sedimentation and transport of toxic materials from the CCMA into 

various watersheds. This is affecting BLM’s ability to comply with water quality standards for 

mercury and sediment within the CCMA. Stream crossings and riparian areas are being affected 

by the lack of maintenance. A 1995 study by a BLM contractor identified roads within the 

CCMA as the primary contributor of sediment into watersheds within the area. Maintenance 

proposed by BLM in the PRMP/FEIS would reduce sedimentation from these roads. 

The County’s failure to maintain these roads conflicts with resource management goals and the 

overarching laws and regulations governing BLM. Therefore, under the Proposed RMP, the BLM 

would assert its’ authority and jurisdiction over the aforementioned roads; and the Hollister Field 

Office would perform maintenance and repairs on the designated routes on public lands in the 

CCMA from Coalinga-Los Gatos Road to Idria Road. BLM would also continue to provide 

access on other routes in the CCMA for valid existing rights of way, mining claims, leases, and 

private landowners. Refer to section 2.3.3 for other management actions related to travel and 

transportation management. 

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F. Issues Considered, but Not Analyzed 

i. Epidemiological Studies 

Example: 

ORG-TMC: 

No epidermal or forensic evidence to confirm the health risk of naturally occurring chrysotile 

asbestos from the serpentine soil and rocks to produce any type of cancer? The risk assessment 

has been taken as a statement of fact, when it is only an incomplete analysis (1502.22) based on 

some occupational models adjusted to look like they have some sort of meaningful relationship to 

recreational usage at CCMA. The truth is risk assessment is a fancy way of saying a wild guess of 

what the future may be. Many times statistics have been used to circumnavigate the truth or lack 

of it. Statistically it can be shown that there’s a higher probability of dying, when driving to and 

from CCMA than recreating at CCMA. 

ORG-CA4WDC: 

Unless and until epidemiological studies definitely prove a risk that is beyond a supposition, the 

Clear Creek Management Area must be reopened to motorized recreational use. Please strike 

form the document all reference to health risk until such time as the appropriate epidemiological 

studies are conducted and prove any other than the current evidence shows – that there is no risk 

for motorized recreation in the Clear Creek Management Area. 

IND-COM-04: 

BLM is using the 2008 EPA Asbestos Risk Assessment as evidence when the document is only an 

assessment. BLM fails to identify there is lacking information that shows scientifically there is an 

asbestos risk at CCMA. The EPA report fails to show there are any health risks by not providing 

an Epidemiology report which would back up their data. The BLM EIS must indicate there is no 

epidemiological information available from the EPA because the EPA finds it too difficult to 

obtain a valid epidemiological report. 

Response: 

Excess lifetime cancer risk was estimated using both the U.S. EPA Integrated Risk Information 

System (IRIS) and the California EPA Office of Environmental Health Hazard Assessment 

(OEHHA) cancer toxicity values for asbestos. 

The EPA Integrated Risk Information System (IRIS) toxicity value for asbestos is derived from 

epidemiological studies of human fatalities and health effects, not from studies of test animals in 

the laboratory. Of the 14 epidemiological studies used to derive the asbestos toxicity value, 7 

involve 100% chrysotile or predominately chrysotile exposures. While the risk assessment does 

not predict individual outcomes, there is more confidence that adverse health effects in humans is 

associated with increased exposure to asbestos. 

A discussion of the limits and constraints of the analysis, acknowledging the lack of 

epidemiological studies specific to CCMA and the importance of this information relevant to 

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reasonably foreseeable significant adverse impacts is included in Section 4.2.2 of the CCMA 

Draft RMP/EIS and the CCMA Proposed RMP and Final EIS. 

ii. Other Available Information 

Example: 

MSBT-LAW: 

Throughout the NEPA process for the CCMA RMP, HFO has essentially disregarded, or at least 

ignored, credible scientific data indicating that PCME fibers are located in concentrated areas, 

which would allow for a more tailored management approach than is available from the range of 

alternatives presented in the DEIS. It also is apparent that the EPA report fails to sample 

according to actual riding patterns. 

ORG-TMC: 

[In reference to a list of documents regarding chrysotile exposure.] 

“The BLM’s omission of these studies in any of its analysts is evidence by their acknowledgement 

of them in the scoping report but no mention of the studies in the RMP goes to show no balance 

of analyst. These studies need to be included into the RMP to produce a more balanced analyst of 

the risks of Chrysotile type asbestos.” 

The EPA also published in December 2008 that Chrysotile asbestos is significantly less potent 

than amphibole asbestos, a position also held by the World Health Organization. Even though 

this was published prior to the release of the DEIS, this change in stance by the EPA is not 

reflected in their report. 

Response: 

As indicated by the August 2008 Scoping Report for the CCMA RMP/EIS, BLM and EPA are 

aware of the documents referenced in the public comment letters. The EPA toxicity factor for 

asbestos is based on the review of 14 epidemiological studies of asbestos-related disease and 

death and combines risks from both lung cancer and Mesothelioma. While there is debate in the 

scientific community regarding the mode of asbestos toxicity, there is no debate among health 

experts and agencies that chrysotile asbestos exposure causes cancer and non-cancer disease. 

EPA expressed concerns about the technical deficiencies of the 1992 PTI health risk assessment 

during the revision of the Hollister RMP in 2004. Specifically, EPA stated “the [2004] DEIS 

continues to rely on an inadequate 1992 health risk assessment ... EPA’s preliminary data 

indicate a potentially higher risk to OHV users than BLM’s 1992 risk assessment. EPA’s 

complete evaluation will sample a range of conditions and analyze all samples with transmission 

electron microscopy (TEM) analysis. TEM analysis is better able to resolve fiber types and 

dimensions than phase contrast microscopy (PCM), which was used in the 1992 risk assessment.” 

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Furthermore, EPA’s comments on BLM’s 2004 DEIS identified the need for additional 

information regarding the potential health risks to children and smokers, stating that “young 

children exposed to asbestos in the CCMA have a higher risk of developing mesotheliorna during 

their lifetime than older adults because the latency period for developing this cancer can be 30 to 

40 years.”

Therefore, BLM agreed to work with EPA and the public upon completion of the study to 

incorporate the new health risk information into public land use decisions for the area. (DEIS pg. 

1) Accordingly, The purpose and need for the CCMA Draft RMP/EIS states that “EPA’s CCMA 

Asbestos Exposure and Human Health Risk Assessment (2008) provides significant new 

information that must be incorporated into a land use plan to evaluate the public health risk 

associated with BLM land use authorizations.” (DEIS pg. 4) 

In 2008, EPA requested that the external Science Advisory Board (SAB) review an approach to 

address toxicities from various mineral forms of asbestos. The objective of the proposed approach 

was to investigate the influence of asbestos mineral types and fiber dimensions on estimates of 

cancer potency derived from epidemiological data. The Board agreed that mineral type and 

dimension are important determinants of asbestos toxicity, and that an effort to examine the 

relative contributions of these characteristics to asbestos toxicity was worth pursuing. However, 

the Committee found that the available exposure data was not robust enough to support the effort 

EPA proposed. In light of the Board's concerns, the EPA Office of Solid Waste and Emergency 

Response decided not to pursue the effort 

. 

The effort to examine the toxicity of various asbestos mineral forms and dimensions was in no 

way predicated on scientific evidence that chrysotile asbestos is benign. On the contrary, the 

evidence continues to support EPA’s position that chrysotile is a known human carcinogen and 

causes debilitating and fatal non-cancer disease. The serious health impacts of chrysotile 

exposure are recognized by the Centers for Disease Control, the Occupational Safety and Health 

Administration, the National Institute of Occupational Safety and Health, the World Health 

Organization International Agency for Research on Cancer, and others. Recent follow-up studies 

of North Carolina textile workers confirmed the strong relationship between estimated exposure 

to chrysotile and mortality from lung cancer and asbestosis. M. Hein, L. Stayner, E. Lehman, J. 

Dement. Follow-up study of chrysotile textile workers: cohort mortality and exposure-response 

Occup Environ Med 2007; 64:616-625 doi: 10.1136/ oem.2006.031005. Additional studies of the 

textile workers confirmed “that workers exposed to chrysotile are at increased risk of 

mesothelioma, as well as lung cancer.” Loomis D, Dement JM, Wolf SH, Richardson DB. Lung 

Cancer Mortality and Fiber Exposures among North Carolina Asbestos Textile Workers, 

Occupational and Environmental Medicine, published online March 11, 2009 by the BMJ 

Publishing Group Ltd. 

G. General Comments, Non-Substantive 

Comments related to the existence of typos and quotation marks used to place emphasis on 

specific terms used in the CCMA Draft RMP/EIS are non-substantive and do not inhibit 

meaningful analysis because the document provides the purpose and need for the Draft RMP/EIS, 

includes a reasonable range of alternatives, and describes the affected environment and the 

environmental consequences of alternative management actions for the CCMA 

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Similarly, comments regarding the general public’s ability to assimilate and provide germane 

comments due to the format and length of the document do not exclude individuals that would 

otherwise be able to provide comments. 

Response: 

These comments do not raise environmental issues under the National Environmental Policy Act 

(NEPA), provide general comments or statements without raising a specific environmental 

question, and/or represent an opinion of the commenter that does not raise issues under NEPA. In 

compliance with NEPA, the BLM prepared a Final Environmental Impact Statement (FEIS) and 

that FEIS will be available to the public for 30 days. After publication of the FEIS and after 

consideration of the comments received on the DEIS, including comments regarding the EPA 

Risk Assessment, possible BLM actions related to public health and safety or other environmental 

issues, the BLM may select an alternative and set forth its approval in a Record of Decision (23 

Code of Federal Regulations [CFR] 771.127) along with a summary of the adverse impacts of the 

proposed action and avoidance, minimization, and mitigation measures incorporated into the 

Record of Decision (ROD) to complete the environmental process under NEPA. 

Section 2: Purpose and Need 

The purpose and need for the CCMA RMP/EIS, as described in Section 1.0, is consistent with the 

Federal Land Policy and Management Act (FLPMA; 43 United States Code [USC] 1701) and 

satisfies the requirements of the National Environmental Policy Act (NEPA). Therefore, the 

BLM’s purpose and need statement for the CCMA RMP/EIS was not revised in response to 

public comments. Specific responses to public comments related to the project purpose and need 

are provided in the following sections. 

A. EPA Risk Assessment 

Many comments suggest that the purpose and need is flawed based on the significance of the 

results of the EPA risk assessment. 

Example: 

ORG-SRMC: 

The BLM has not provided any facts in the DEIS to support the statement that there is a 

significant health risk of recreating in the CCMA as evidence by incidents of disease. 

While the EPA’s CCMA Asbestos Exposure and Human Health Assessment (2008) provides new 

information, it does not provide information so compelling that it warrants the emergency closure 

or the severe restrictions on OHV use proposed in the preferred alternative. 

Example: 

IND-COM-140: 

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The 2008 EPA Assessment has not provided the “substantial new information” as stated in the 

2009 DEIS/RMP. The assessment has not provided conclusive evidence that there is a real risk to 

users of the area and there are numerous issues with the data collected and used (in common 

scientific terms “garbage in equals garbage out”). It is this author’s opinion that based on the 

above, the BLM has not proved a need for the current “emergency closure” and subsequent 

preparation of the 2009 DEIS/RMP. As such, the 2009 DEIS/RMP needs to be declared null and 

void, the area needs to be reopened immediately, and the BLM shall manage the CCMA under the 

current record of decision and amendments. 

Should the BLM elect to provide additional education outreach to users of the area and/or 

provide mitigation such as armoring of main roadways, I believe this would fall under an 

amendment to the current ROD, but does not warrant the need for a new EIS/RMP. 

Response: 

EPA Region 9 used standard and accepted practices for environmental asbestos sample 

collection, sample analysis, and risk assessment. The EPA Risk Assessment for CCMA was 

reviewed by members of the Agency’s Technical Working Group for Asbestos, the California 

Department of Toxic Substances Control (DTSC), and the California Office of Environmental 

Health Hazard Assessment (OEHHA). EPA reviewers and both California agencies agreed with 

and support Region 9’s methods and findings. Domestic and international health and scientific 

organizations, including the State of California, the EPA, the Centers for Disease Control, the 

National Toxicology Program, the National Institute for Occupational Safety and Health 

(NIOSH), the Occupational Safety and Health Administration (OSHA), the World Health 

Organization International Agency for Research on Cancer, and the International Program on 

Chemical Safety, have all classified chrysotile asbestos as a known human carcinogen. 

The EPA Superfund program defines the acceptable risk range for exposure to a carcinogen, like 

asbestos, as 1 in 10,000 (10-4) to 1 in 1,000,000 (10-6) excess lifetime cancer risk1

. Exposures 

which are calculated to cause more than 1 in 10,000 excess cancers, like those evaluated in the 

EPA study and the CCMA Draft RMP/EIS are considered to be of concern and may require 

action to reduce the exposure and resulting risk. Therefore, the BLM believes that the purpose 

and need for the RMP/EIS, as discussed in Section 1.0 in the FEIS, is consistent with the 

directives described under the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA), also known as the Superfund Act. 

B. Endangered Species Act 

Many comments suggest that the purpose and need statement’s reference to the listing and/or 

additional habitat needs species protected under the federal 1973 Endangered Species Act (ESA) 

is not supported by existing knowledge and information available about listed species occurring 

within the area and the suitability of the habitat on public lands in the CCMA. 

1 40 CFR Part 300, National Oil and Hazardous Substances Pollution Contingency Plan, section 

430(e)(2)(i)(A)(2), “For known or suspected carcinogens, acceptable exposure levels are generally 

concentration levels that represent an excess upper bound lifetime cancer risk to an individual of -4 -6 between 10 and 10 using information on the relationship between dose and response...” 

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Example: 

IND-COM-140: 

The 2008 DEIS/RMP has erroneously listed [needs for species protected under the federal 1973 

Endangered Species Act (ESA),] as a need for the document. As such, the 2009 DEIS/RMP needs 

to be declared null and void, the area needs to be reopened immediately, and the BLM shall 

manage the CCMA under the current record of decision and amendments. 

IND-COM-97: 

The Bureau of Land Management has failed to show a cause for action necessitating inclusion of 

the California Condor in the resource management plan or the environmental impact statement. 

The BLM has also failed to show a significant Purpose and Need for this discussion in the 

management plan or environment impact study, or how CCMA recreation affects the California 

Condor habitat. 

Response: 

The CCMA Draft RMP/EIS (2009) and this CCMA PRMP/FEIS both say that there are no 

known occurrences of the California red-legged frog or the California tiger salamander on public 

lands in the decision area. Nonetheless, the CCMA is well within the range of these species, as 

well as the endangered California condor and other listed plant species (or candidates proposed 

for listing) including the San Benito evening-primrose and Rayless layia, respectively. 

BLM has a responsibility under the Federal Land Management and Policy Act (FLPMA), and the 

Endangered Species Act (ESA), to address species listings and habitat needs for these species 

even if it’s just to confirm that the BLM proposed actions would have no effect on listed species 

because they are not present in the CCMA. Furthermore, consultation with the United States Fish 

and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) is required if 

BLM land use decisions may affect listed species and designated critical habitat, to ensure that 

actions taken are not likely to jeopardize the continued existence of any threatened or endangered 

species or their critical habitat. 

Section 3.6.4 describes the resources conditions for these species and the BLM’s progress in 

identifying areas of ecological importance and the purpose and need for the CCMA RMP/EIS 

reaffirms priority species and habitats, and identifies restoration strategies, opportunities, and 

management decisions to protect or prevent avoidable loss of habitat supporting special status 

species within each of the management areas. 

BLM has expended considerable effort in species-directed inventories throughout the CCMA, 

particularly as part of efforts to delist the San Benito evening-primrose, of which the HFO 

administers the majority of known occupied habitat for the species. Important new information 

regarding the status of this species has been added to the PRMP/FEIS to analyze impacts to San 

Benito evening primrose and its’ associated habitats under the range of alternatives and the 

proposed action. 

In light of the public comments about the relationship of the ESA to the CCMA RMP and lack of 

habitat for California red-legged frogs and tiger salamanders in the CCMA, the purpose and need 

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has been modified in the PRMP/FEIS to emphasize the need to consider new information 

regarding the San Benito evening primrose and habitat needs for California condor. Otherwise, 

BLM believes that the purpose and need for the RMP/EIS, as discussed in Section 1.0 in the 

FEIS, is consistent with the directives described under the ESA. 

C. Social and Economic Conditions 

These comments requested that the purpose and need be broadened and that additional 

alternatives be identified based on the broader purpose and need. 

Response: 

The purpose and need for the project provided Chapter 1.0, Introduction and Purpose and Need, 

in the Final Environmental impact Statement (FEIS) is based on two key considerations, as stated 

under Section 1.4 Planning Criteria (DEIS, pg. 9), “Principles of ecosystem management as well 

as a continuing commitment to multiple use and sustained yield will also guide land use decisions 

in the Planning Area. The commitment to multiple uses would not mean that all land would be 

open for all uses. Some uses may be excluded on certain lands to protect specific resource values 

or uses. Any exclusions, however, would be based on laws or regulations or be determined 

through the planning process and subject to public involvement. 

As discussed in Chapter 2.0 (FEIS Section 2.5), a range of alternatives (A-G), were evaluated in 

detail in the Draft RMP/EIS and included multiple public use scenarios in the Serpentine ACEC: 

five of which entailed Motorized access (Alternatives A, B, C, D, and E), one Non-motorized 

access alternative (Alt. F), and one alternative that considered closure of the Serpentine ACEC to 

all forms of public entry (Alt. G). 

In general, the CCMA Draft RMP/EIS range of alternatives analyzed combined management 

actions, resource allocations, and allowable uses that BLM considered reasonable based the 

purpose and need for the CCMA RMP/EIS and the issues identified during the public scoping 

period. 

The suggestion that the project purpose should be expanded to “...focus on the need to enhance 

OHV opportunities outside of CCMA...” is outside the purview of the BLM. Clearly, the primary 

action that BLM is considering is related to responding to the EPA Risk Assessment and the need 

to address the risk to visitors on public land managed by the BLM. As a result, the BLM 

determined that a key purpose of this project was to revise existing land use decisions to reduce 

human health risks from exposure to asbestos and minimize airborne asbestos emissions from 

BLM management activities in the CCMA. 

Accordingly, BLM considered seven alternatives, including the No Action Alternative, as 

described in detail in Chapter 2.0 of the CCMA Draft RMP/EIS. These alternatives were 

considered in the Draft RMP/EIS but were not carried forward for detailed evaluation in the FEIS 

as explained at the beginning of Chapter 2.0. Refer also to Common Responses, Section 3 (A-C), 

for BLM responses to comments in the PRMP/FEIS for additional discussion of alternatives 

considered in the Draft RMP/EIS and why these alternatives were either not considered or were 

considered but not carried forward for detailed analyses in the FEIS. 

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Section 3: Project Alternatives 

A. Range of Alternatives 

Example: 

AG-DPR-OHMVRD: 

The Division is concerned all relevant alternatives and other impacts are not thoroughly 

addressed within the Draft RMP/EIS. In particular, the Draft RMP/EIS offers no consideration to 

viable options or substitutes for the CCMA recreational opportunities. Instead, the establishment 

of new OHV recreation areas outside the CCMA is relegated to the Section 1.3.3 — “Issues 

Considered but Not Further Analyzed” (page 8). The subsequent suggestion in the Draft 

RMP/EIS (page 9) that the Hollister Field Office and OHMVR Division work together at a later 

date to find additional OHV recreation areas elsewhere in the Hollister Field Office, while a 

welcome proposal, is seemingly counter to the scope of the document and not a satisfactory 

solution. In fact, the Hollister RMP offers no OHV recreational opportunity on par with the 

CCMA. 

ORG-AMA36 

Creation of a viable, challenging and long term sustainable trail system at the CCMA has long 

been the goal of many in the riding community. Access to privately held lands, opportunities for 

other motorized recreationists as well as protection of the resources are all part of a well 

developed and managed facility, and something the public has repeatedly requested and 

demonstrated a willingness to support. 

Indeed direct financial support (day use permits, annual passes and OHV grants) as well as 

volunteer efforts (such as fencing of threatened and endangered species) had been ongoing until 

the emergency closure was implemented. The agency has a ready partner but has simply not 

taken full advantage of the opportunity presented. As a result of this deficient process one or 

more viable, if not superior, alternatives have been omitted from the DEIS. 

MSBT –LAW: 

Every alternative in the DEIS contemplates further restriction on access to roads and trails and 

areas by motorized means. It is apparent from the DEIS that the purpose and need for the project 

is to minimize asbestos exposure and reduce asbestos emissions. DEIS at Executive Summary p. 

III. Thus, the DEIS accepts as a foregone conclusion that the CCMA is hazardous enough to 

justify limiting but one factor in exposure, based on questionable science. 

Thus the purpose and need, from which the range of alternatives flow, illegitimately creates a 

range of alternatives that precludes meaningful analysis. Every alternative, save the no action 

alternative, results in significant limitations on motorized recreation access. Thus, the decisionmaking paradigm is constrained to options that rely on achieving the purpose and need through a 

single means: limiting recreational access. Hazards exist throughout the public lands; not every 

one can be identified, evaluated, and protected against. Even assuming that the underlying 

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science conclusively demonstrates the conclusion for which it is accepted, a range of alternatives 

that aims solely to reduce access precludes consideration of legitimate alternative means to 

achieve the result. In sum, the range of alternatives, and the preferred alternative, derive from an 

erroneous premise and result in the impossible enterprise of closing areas based on unknown 

hazards. 

The DEIS’s range of alternatives fails to address reasonable alternative mitigation measures and 

instead favors closure to achieve its goal. However, numerous alternative mitigation measures 

exist and have been presented to the HFO; BLM cannot summarily disregard, without analysis, 

these reasonable alternatives. 

Response: 

The Hollister RMP (2007) considered viable options for motorized recreational opportunities in 

the remaining areas beyond the bounds of CCMA. The CCMA Draft RMP/EIS also includes a 

range of alternatives that considers viable options for motorized recreation opportunities both 

inside and outside the Serpentine ACEC based on the purpose and need described in Chapter 1. 

Pursuant to 40 C.F.R. § 1502.14, the BLM’s Hollister Field Office conducted multiple public 

scoping meetings and interdisciplinary team discussions to rigorously explore and objectively 

evaluate all reasonable alternatives in the CCMA Draft RMP/EIS. Numerous interested parties, 

including a consortium of OHV organizations and clubs participated in the public scoping 

meetings and helped generate the range of alternatives analyzed in the CCMA Draft RMP/EIS. 

As a result, five out of the seven alternatives analyzed in the CCMA Draft RMP/EIS (Alternatives 

A - E) incorporated technical and administrative measures to improve monitoring of 

meteorological conditions, airborne asbestos emissions, and CCMA visitor use in order to enable 

limited OHV use in the planning area. 

B. No Action Alternative 

Example: 

ORG-CA4WDC: 

Per the CEQ Forty Questions, (CEQ 40 CFR 1502.14), a no-action alternative must contain the 

following: “This analysis provides a benchmark, enabling decision makers to compare the 

magnitude of environmental effects of the action alternatives. It is also an example of a 

reasonable alternative outside the jurisdiction of the agency which must be analyzed. Section 

1502.14(c)”. 

There is little to nothing in this document that qualifies under a no-action alternative because 

every piece of evidence contained in the document is contaminated by the results of the 2008 EPA 

study and it's conclusions. All alternatives in the document contain the assumption of risk implied 

in the EPA report. A true no-action alternative would not be prejudiced by questionable 

conclusions contained in the aforementioned report. 

Alternative A, represented in the document as the no-action alternative actually incorporates 

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action alternative, therefore the document does not comply with CEQ regulations. Please rewrite 

the document to show a true no-action alternative not tainted by the 2008 EPA study. 

Response: 

Pursuant to 40 C.F.R. § 1502.14, the BLM’s Hollister Field Office conducted multiple public 

scoping meetings and interdisciplinary team discussions to rigorously explore and objectively 

evaluate all reasonable alternatives in the CCMA Draft RMP/EIS. Numerous interested parties, 

including the consortium of OHV organizations and clubs participated in the public scoping 

meetings and helped generate the range of alternatives analyzed in the CCMA Draft RMP/EIS. 

The CCMA Draft RMP and EIS clearly explains that the “No Action” alternative is based on the 

existing land use plan decisions that were in place prior to the May 1, 2008 Temporary Closure 

Order for the CCMA Serpentine ACEC (pg. 19). 

The following statement (referenced above) also reappears in the CCMA Proposed RMP and 

FEIS, “Alternative A represents the ‘No Action’ alternative required by NEPA, and 

would reaffirm current management under the original Hollister RMP (BLM 1984) and 

its’ associated Clear Creek Amendments (1986, 1999, 2006). Alternative A does not take 

into account the temporary closure of the Serpentine ACEC. Management of recreation 

opportunities, special status species habitat, and other resources would be maintained at 

existing levels prior to the May 1, 2008 closure order. This alternative would not modify 

allowable uses to address emerging issues on public lands; however, this alternative 

would incorporate new human health risk information into BLM’s public outreach and 

education asbestos hazard information program and new guidance for management of 

natural and heritage resource, rangelands, energy and minerals, and lands and realty 

established after the 1984 Hollister RMP, as amended.” 

C. Alternative D 

Examples: 

ORG-CORVA: 

The draft RMP-EIS does not provide adequate discussion of Alternative D that would allow a 

reasoned choice between alternatives. The draft RMP-EIS must be revised to include an adequate 

discussion of the issues related to Alternative. 

The analysis provided in the draft RMP-EIS is inadequate because Alternative D is not given fair 

and thorough discussion and is not established as a reasonable and viable alternative. The draft 

RMP EIS cites a previous study of the Cantua area but provides only the most limited discussion 

of the results of the study and how they might apply to motorized recreation in the adjacent 

CCMA. 

To summarize, the draft RMP-EIS provides contradictory statements related to the availability of 

public access to the Condon Peak and Cantua zones and little if any information about possible 

public access to the Tucker Mountain zone. The maps provided indicate that two alternatives, D 

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and E, include development of recreation sites in the Condon and Cantua zones and that public 

access from New Idria Road and Los Gatos Road is planned for these areas. But there is no 

discussion of why recreational opportunity for off highway vehicles should be included or 

excluded for these areas. This is a key element of alternative D, yet any discussion of this element 

is lacking. 

Response: 

The Draft RMP/EIS analyzed potential impacts of Alternative D in Chapter 4. Resources issues 

that were identified included potential for additional disturbance of asbestos bearing deposits in 

the Condon and Cantua areas. Information to support this statement is included in the CCMA 

Draft RMP/EIS and Proposed RMP/FEIS in Appendix I, Map 5, which illustrates the location of 

serpentine (and serpentine-derived) soils based on soil survey results for San Benito County. 

Other concerns identified in the CCMA Draft RMP/EIS related to increasing and/or improving 

motorized access to CCMA public lands outside of the ACEC for recreation opportunities are 

addressed in Section 4.4.6.2 (Vegetation), 4.6.6.2 (Special Status Species) 4.8.6.2 (Soils), and 

4.9.4.2 (Water). 

The analysis of new OHV recreation opportunities in the Tucker zone is limited because 

vehicular access to the BLM public lands in this area does not currently exist and is not 

reasonably foreseeable. 

D. Preferred Alternative 

Example: 

ORG-SCC: 

The EIS must not specify a preferred alternative that clearly does not satisfy the Purpose and 

Need and which is not the best alternative according to the... vast majority of the public. 

Example: 

ORG-VWA: 

CCMA and surrounding management zones are too vast, rugged and remote to be managed for 

off road vehicle recreation. Furthermore, the diverse soils that support rare and sensitive 

biological resources are unsuitable for intensive and newly developed OHV recreation activities. 

[However,] limitation to the Idria - Spanish Lake road does not provide adequate access to Clear 

Creek where both rock hounds and botanists find highly desirable. We believe that the public 

should be allowed to drive (“tour”) through the CCMA on all of the county roads and access this 

beautiful area for passive recreational uses (such as hiking, birding, photography, scientific 

research, rock hounding), including within the Serpentine ACEC. 

We strongly encourage BLM to work with San Benito and Fresno counties to resolve the access 

and maintenance issues of the county roads for non-consumptive uses. The Idria Road is 

impassable to standard vehicles which would unfairly limit access to the CCMA. 

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We request that the Clear Creek Road and entrance be kept open. ALT E should be modified to 

include the all of the County Road Network. We suggest that the county road network be open 

year round to highway (touring) vehicles with permits required in the dry season. 

Response: 

The Clear Creek Management Area (CCMA) is an area of naturally occurring asbestos. Asbestos 

is a known human carcinogen. EPA’s Clear Creek Management Area Asbestos Exposure and 

Human Health Risk Assessment (2008) determined that the asbestos exposures for many 

recreational activities at CCMA exceed the acceptable risk range for carcinogens. The EPA risk 

assessment also led to the following conclusions about asbestos exposures and health risks at 

CCMA: (1) the higher the asbestos exposure, the higher the risk of developing asbestos-related 

disease; (2) reducing the exposure to asbestos will reduce the risk of developing asbestos-related 

disease; and (3) children are of special concern because in a majority of activity-based samples at 

CCMA, the concentration of asbestos measured in the child’s breathing zone exceeded the 

asbestos concentration in the companion adult sample. Furthermore, a child’s life expectancy 

exceeds the latency period for asbestos-related disease. 

In light of these considerations, the BLM’s “Preferred Alternative” best meets the purpose and 

need identified in Chapter 1 of the CCMA Draft RMP/EIS because it would help protect human 

health and safety by reducing exposure to airborne asbestos fibers and significantly improve 

environmental resources at CCMA by minimizing asbestos emissions associated with BLM 

management acitivities. 

Based on public comments, the BLM’s “Preferred Alternative” was modified in the Proposed 

RMP and Final EIS to include 32 miles of designated routes in the Serpenetine ACEC that would 

be limited to highway-licensed vehicles. These routes include all of the former county roads in 

CCMA. Additionally, the Draft RMP/EIS’s “Preferred Alternative” and the Proposed 

RMP/FEIS’s “Proposed Action” both establish goals, objectives, and management actions for 

BLM-administered lands in CCMA that address current issues, knowledge, and conditions and 

designate areas in CCMA for motorized, mechanized, and non-motorized/non-mechanized 

recreation opportunities; protect sensitive natural and cultural resources from impacts due to 

recreation and other land uses; provide guidance for mineral and energy development; as well as 

other land use authorizations and tenure adjustments. 

E. Alternatives Considered, but Not Analyzed in Detail 

Example: 

ORG-TMC: 

Not considering designation of CCMA as an ‘Open’ area in the range of alternatives unless 

posted limited or closed use (2.2.3.). as the no action alternative is clearly a violation CEQ 

401502.14 (d) and NEPA (6.6.1.1) Using the EPA’s risk assessment as reason not to consider this 

alternative is not relevant. 

Response: 

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The Draft RMP/EIS explains on page 20 that the alternative to designate CCMA an ‘open’ area 

for OHV use was considered, but not analyzed because “this type of designation would not meet 

the purpose and need for this RMP/EIS to minimize human health risks from exposure to asbestos 

and reducing airborne asbestos emissions from BLM management activities. The Federal 

government has concluded that all forms of asbestos are hazardous to humans, and that all can 

cause cancer; although the chrysotile form may be less potent than the amphibole family in 

causing mesothelioma (U.S. Department of Health and Human Services, Public Health Service, 

Agency for Toxic Substances and Disease Registry, Toxicological Profile for Asbestos)”. 

Section 4: Impact Analysis 

A. Risk Assessments & Uncertainty 

Example: 

MSBT-LAW: 

There is unquestionable uncertainty in the EPA’s own report regarding the actual conditions; 

ergo, its sampling, testing, and conclusions do not necessarily correctly characterize the risk. 

The DEIS fails to address the ambiguity of the data, and therefore, in sum, the DEIS fails to take 

the requisite “hard look” at the data it accepts as true, thus failing to consider an important 

aspect of the problem. 

Response: 

Section 4.2.2 of the CCMA Draft RMP/EIS addresses the Limits and Constraints of the Analysis, 

including but not limited to Incomplete and Unavailable Information (4.2.2.1), and Exposure and 

Risk Uncertainties (4.2.2.2). 

“The assessment of risk as a probability of an outcome always has unknown values that 

are estimated in health protective ways to ensure that the risks are neither underestimated 

nor grossly overestimated. The largest uncertainty in the assessment of risk to users of 

CCMA is that the risk evaluation only assesses excess lifetime cancer risk. It is known 

that asbestos causes debilitating and fatal diseases other than cancer, such as respiratory 

and pleural disease. The non-cancer effects are not quantitatively taken into account in 

the assessment because there is no asbestos toxicity value for non-cancer health effects, 

even though non-cancer effects could actually be more significant to total disease 

outcome from CCMA asbestos exposure. Therefore, the general probability of 

developing disease from exposure related to activities at Clear Creek may be significantly 

underestimated in the report. Uncertainties related to the exposure parameters in the 

CCMA assessment that could cause the estimated risk to be less or greater than the actual 

risk include: the frequency of exposure and the time actually engaged in dust-generating 

activities; the effect of the exposures on children; and the representativeness of the areas 

used for the sampling as accurate models of typical CCMA conditions. One exposure that 

was not measured, and which could cause the exposure and risk to be higher, is the 

continued exposure that results when asbestos fibers from CCMA are taken home in 

vehicles and on equipment. Uncertainty related to the toxicity parameters of the risk 

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characterization includes the application of the IRIS and OEHHA asbestos toxicity 

values, which were developed from epidemiological studies of occupational exposures, to 

infrequent and episodic recreational exposures. This uncertainty could mean that the 

actual risks could be much lower than those estimated in the CCMA assessment. Another 

uncertainty, adjustments for early lifetime childhood exposures, could mean that the 

actual risks are higher than those estimated in the report.” 

There are many comments that confuse uncertainty related to Risk Assessment with variability 

and imprecision. The caveats and uncertainties discussed in the EPA risk assessment are included 

in the report to notify the reader of the bounds to the estimates. The actuarial data is not in 

question. Disease and death result from asbestos exposures, and the variability presented is only 

in the magnitude of the cancer effect and the possible range of estimates. In fact, the EPA 

findings were consistent with previous exposure studies conducted at CCMA. Full disclosure of 

the uncertainties is standard in Risk Assessments and does not invalidate the overall finding that 

the asbestos exposures at CCMA, and the attendant risks, are significant. 

B. Impacts to OHV Recreation 

Example: 

ORG-SCC: 

The negative impacts of reducing OHV recreation opportunities in the CCMA are not adequately 

discussed in the EIS. These include important impacts to other federal and state lands designated 

for OHV recreation. Such impacts are directly relevant and must be included in the CCMA 

RMP/EIS because the CCMA RMP/EIS process has immediate and predictable consequences and 

impacts to these other lands, and directly and significantly affects current and potential users of 

the CCMA. 

Response: 

The Draft RMP/EIS analyzed the impacts to OHV recreation in Chapter 4.1.2.2, and specifically 

acknowledges “the proposed action would have major long term adverse impacts to OHV 

(motorized) recreation opportunities in the ACEC because the miles of routes and trails available 

for OHV use would be reduced by more than 75%.” 

The Draft RMP/EIS and Proposed RMP/ FEIS also describe “minor long-term adverse effects on 

other existing recreation resources due to limits on annual visitor use days in CCMA”, as well as 

indirect impacts related to the proposed action. As suggested by SaveClear Creek.org, the BLM 

recognizes that as restrictions on allowable uses increase and recreation opportunities decrease, 

“These restrictions would displace thousands of OHV recreationists, who would end up seeking 

OHV recreation opportunities in other County, State or Federal recreation areas. Many of these 

other areas are smaller than CCMA and additional visitors would contribute to overcrowded 

conditions and additional impacts to the human environment in those areas. Overcrowding can 

lead to increased conflicts among user groups, decreases in recreational quality and experience, 

and adverse impacts to other resources like vegetative cover, wildlife habitat, soil loss and 

erosion, and water and air quality.” 

C. Impacts to Non-ACEC Zones 

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Examples: 

AG-SJVRCD: 

Given the fragility of the soils in the upper Los Gatos Canyon watershed, the construction and 

use of new dirt roads in the upper Los Gatos Canyon watershed would cause a huge increase in 

soil erosion and sediment loads in Los Gatos Creek. 

With regard to air quality, the dust stirred by off-road vehicles, the fine particulate matter emitted 

by their engines and the emissions of oxides of nitrogen from their engines are all harmful to 

human health.... To knowingly increase fugitive dust, PM 2.5 engine emissions, and oxides of 

nitrogen by establishing new ORV roads and campground facilities for new and renewed off-road 

vehicle use in the Coastal Range amounts to a willful disregard of the resulting respiratory 

illness among our most vulnerable Valley residents. 

IND-105: 

The serpentine landscapes are easily abused. On the barrens lichens, mosses, and plants that are 

able to tolerate shallow, nutrient poor soils take years to form in the harsh climate. They are 

fragile, easily uprooted. Open OHV use on these unique geologic features causes devastation that 

may never be restored. 

Clear Creek Management Area (CCMA) was visited by hikers, naturalist, rock hounds, and 

people just looking for a unique and beautiful place to visit. Don’t close the main Clear Creek 

Road to the people that use the area responsibly. 

As for a recreational staging area at the Condon Peak access and new roads including a road to 

Condon Peak I am strongly opposed. We need areas where there are no roads only hiking trails. 

The area is used by hikers, hunters, rock hounds, and naturalist including bird watchers and 

botanists. It would be impossible for BLM to keep OHV use out of the area, and would provide 

access for traffic to the red zone. Law enforcement would need to be upgraded and constant. The 

soil in that area is highly erodible adobe, not suited for a staging area. 

Response: 

Soils of the CCMA are introduced and described in the CCMA RMP Chapter 3.8 (includes Soils 

Map 5) and analyzed in Chapter 4.8. Table 3.8-1 and Map 5 identify soil series of the CCMA and 

factors important to soil erosion including slope, permeability, surface run-off class, and erosion 

hazard. 

Under the proposed action, BLM would prepare separate Travel Management Plans to designate 

routes outside the ACEC for vehicle use and identify appropriate mitigation measures to alleviate 

the effects to public land resources using the screening criteria and route designation 

methodology described in Appendix II. 

Routes and trails to be considered in these Travel Management Plans would be designed to 

minimize surface disturbance associated with management activities and visitor use within the 

serpentine formation and serpentine derived soils known to have high concentration of asbestos 

fibers. 

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Construction of any new routes within the CCMA would take soil erodibility into account, 

resulting in avoidance of soils having high erosion hazard and incorporating erosion control 

measures into route design. By taking these measures, soil erosion within- and sediment loads to 

the CCMA watersheds can be reduced. 

D. Social and Economic Effects 

Examples: 

AG-SBC: 

Since the temporary closure of the CCMA, significant revenue has been and will continue to be 

lost adversely affecting local and regional businesses due to the closure. Due to the temporary 

closure of Clear Creek, the Hollister Hills OHVA is full by 10:00 a.m., and frequently has to turn 

people away, further hurting the economy of the area, and forcing people to go further away for 

OHV activity. More analysis should be provided on this important issue, as area businesses and 

the County are very concerned. 

ORG-AMA36: 

It is our contention that The DEIS is fatally flawed because it did not properly analyze the 

socioeconomic impacts to local and regional businesses including restaurants, motorcycle shops, 

hotels, sporting goods stores, gas stations, and grocery stores. This important omission must be 

addressed prior to a record of decisions being issued. 

MSBT –LAW: 

The DEIS fails to adequately account for the socioeconomic and environmental impacts to other 

areas or the local economies caused by the alternatives, including the preferred alternative, in 

violation of NEPA. Socioeconomic impacts are characterized in conclusory terms without specific 

analysis of data to support the conclusions. See generally, DEIS at 520-23. 

Response: 

The CCMA Draft RMP/EIS and the Proposed RMP and Final EIS present the baseline for current 

social and economic conditions in Chapter 3.15 and analyze the impacts of the proposed CCMA 

land use decisions to social and economic values in Chapter 4.15. 

These values and the social and economic contributions associated with visitor use activities in 

CCMA were identified through public scoping and previous CCMA land use planning efforts 

The HFO conducted additional outreach following the release of the CCMA Draft RMP/EIS 

through a social and economic workshop to provide information and gather feedback from private 

landowners, businesses, elected officials, and other interested parties within the communities 

most directly affected by BLM’s land use decisions for CCMA. The information gathered during 

the social and economic workshop has been incorporated into the affected environment and 

environmental consequences chapters of the PRMP/FEIS. A summary report of the information 

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discussed and the public input that was gathered during the workshop is also included in 

Appendix XI. 

E. Cumulative Effects 

The comments regarding the cumulative impacts analyses discussed several topics, as 

suggested below. 

Example: 

ORG-CA4WD: 

Any or all of the [cumulative] effects of closing the Clear Creek Management Area are not 

evaluated by the DRMP/EIS. Besides the economic effects on local businesses in the affected 

areas, including Coalinga, King City and Hollister, there are the effects of travel for recreational 

opportunities to other areas, and impacts their facilities, whether it be State and County owned, 

such as the Hollister Hills SVRA, or Metcalf Motorcycle Park in Santa Clara County. 

Response: 

Chapter 4, Cumulative Effects, describes the rationale for identifying the planning area to be 

evaluated in the cumulative impacts analysis. Although all reasonably foreseeable route 

designation plans known at the time the Draft RMP and EIS analyses were considered in that 

analysis, it is also acknowledged that the impacts of these route designation plans on OHV 

opportunities in California is unknown because they are likely to maintain existing OHV 

opportunities in most locations, even where some routes and trails are designated closed to 

address conflicts on public lands managed by the BLM, the US Forest Service, or the CA 

Department of Parks and Recreation’s Off-Highway Motor Vehicle Recreation Division. 

Given these uncertainties, the level of analysis for cumulative impacts for an environmental 

document is commensurate with the level of information available regarding the range of projects 

that are under consideration. Given that not all of the projects identified in the cumulative projects 

list have been evaluated to a level where the project specific impacts have been assessed and 

identified, the analyses in the DEIS and FEIS identify the potential environmental impacts of the 

cumulative projects commensurate with the level of detail available for those projects at the time 

the analyses were completed. The cumulative analysis in each topical section identifies the 

impacts of the BLM current management of the CCMA, the effects of the cumulative projects, 

and the potential contribution of the proposed action to cumulative impacts in addition to the 

impacts of the cumulative projects, consistent with the requirements of the NEPA. 

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II.	 AGENCY AND ORGANIZATION COMMENTS 

The following sections contain: 

 ̈		 A list of the agencies and organization that submitted comments on the CCMA Draft 

RMP/EIS (Table X-1) 

 ̈		 The language of each of those comments, from the written comment letters/emails (Table 

X-2) 

 ̈		 A brief response to the comments and issues addressed in the CCMA Draft RMP/EIS, 

and/or a reference to the Common Response that addresses the issues raised in those 

comments (Table X-2) 

Table X-1; Commenting Agency and Organization List 

Comment Code Agency/ Organization Commenter 

AG-EPA 

United States Environmental Protection 

Agency Kathleen M. Goforth 

AG-USFWS 

United States Fish & Wildlife Service 

Sacramento & Ventura Offices 

Ken Sanchez, 

J.Miesanderwier 

AG-USGS United States Geological Survey Brenda Johnson 

AG-DTSC 

Department of Toxic Substances 

Control Steven Ross 

AG-DPR-OHMVRD Department of Parks and Recreation Daphne C. Greene 

AG-CALFIRE 

Department of Forestry and Fire 

Protection Robert E. Taylor 

AG-DWR Department of Water Resources Teodoro Z. Alvarez 

AG-OPR 

California Governor’s Office of 

Planning and Research, State 

Clearinghouse Scott Morgan 

AG-MBUAPCD 

Monterey Bay Unified Air Pollution 

Control District Jean Getchell 

AG-SBC County of San Benito 

Reb Monaco, Board of 

Supervisors (Chairman) 

AG-CAOHVC 

California State Off-Highway Motor 

Vehicle Recreation Commission Gary Willard (Chairman) 

AG-CANAHC 

California Native American Heritage 

Commission Dave Singleton 

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Comment Code Agency/ Organization Commenter 

AG- WRCD 

Westside Resource Conservation 

District Philip Erro 

AG-SJVRCD 

San Joaquin Valley Resource 

Conservation and Development Council Philip Erro 

ORG-AMA36 

American Motorcycle Association, 

District 36 Nick Haris 

ORG-ALAA American Land Access Association Marshall Havner 

ORG-BAM Bay Area Mineralogists Bill Spence 

ORG-BRC , 

inc. 

MSBT-LAW 

BlueRibbon Coalition Don Amador 

Moore, Smith, Buxton, Turcke, 

Chartered Paul A. Turcke 

ORG-CA4WDC 

California Association of Four Wheel 

Drive Clubs, Inc. Amy Granat 

ORG-CERA California Enduro Riders Association Bruce Brazil 

ORG-CFMS 

California Federation of Mineralogical 

Society 

Comments submitted by 

individual societies and 

members. 

ORG-CMDA California Motor Dealers Association John Paliwoda 

ORG-CNPS California Native Plant Society Rosemary Foster 

ORG-CORVA 

California Off-Road Vehicle 

Association Bruce Whitcher 

ORG-CBD Center for Biological Diversity Ileene Anderson 

ORG-CRS Coalinga Rockhound Society 

Comments submitted by 

individual members. 

ORG-FOCCMA 

Friends of Clear Creek Management 

Area Mike Wubbels 

ORG-FGMS Fresno Gems and Mineral Society 

Comments submitted by 

individual members. 

ORG-GRMC Ghost Riders Motorcycle Club 

Comments submitted by 

individual members. 

ORG-HVPO Hernandez Valley Property Owners 

Mark Henze, 

et. al. 

ORG-LADBR Los Altos Dirt Bike Riders 

Comments submitted by 

individual members. 

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Comment Code Agency/ Organization Commenter 

ORG-LGMC(1) Lemoore Gems and Mineral Club Karin Kissinger, Kathy Corbett 

ORG-LGMC(2) Los Gatos Motorcycle Club 

Comments submitted by 

individual members. 

ORG-RUTS Racers Under The Son Steven Craig 

ORG-RRMC Ridge Runners Motorcycle Club 

Comments submitted by 

individual members. 

ORG-SRMC Salinas Ramblers Motorcycle Club Matt Beck 

ORG-SVRGC Salinas Valley Rock and Gem Club Gary V. Beck 

ORG-SFGMS 

San Francisco Gem and Mineral 

Society Kevin Anderson 

ORG-SCVGMS 

Santa Clara Valley Gem and Mineral 

Society 

Comments submitted by 

individual members. 

ORG-SCGMS Santa Cruz Gem and Mineral Society 

Comments submitted by 

individual members. 

ORG-SCC SaveClearCreek.org Curt McDowell 

ORG-TMC Timekeepers Motorcycle Club 

Martin Markham, 

Terry Pederson, 

Ross Ross, 

James Strenfel, 

Alex 

Wagner-Juaregg, 

Michael Zesiger, (cc: John 

Davis) 

ORG-3ROCKS Three Rocks Research Ray Iddings 

ORG-TGMC Tule Gems and Mineral Club 

Comments submitted by 

individual members. 

ORG-VWA Ventana Wilderness Alliance Tom Hopkins 

ORG-WOHVA 

Wisconsin Off-Highway Vehicle 

Association John Schnorr 

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Table X-2; Agency and Organization Comment Summary and Response 

AG-EPA: United States Environmental Protection Agency 

Comment: Resource Impacts Recommendations: 

For several resources, the Draft EIS presents the environmental impacts of the The Final EIS should provide the projected emissions of 

Preferred Alternative and the other alternatives in relative terms. However, a more criteria air pollutants for each of the alternatives and 

quantitative comparative analysis should be presented to more clearly describe the discuss the predicted effectiveness of measures to 

differences in magnitude and significance of the direct, indirect, and cumulative mitigate these emissions under each of the alternatives. 

impacts between the alternatives. For example, the Draft EIS does not provide The Final EIS should describe the air quality monitoring 

emissions estimates for criteria air pollutants under each alternative. and mitigation effectiveness monitoring that would be 

conducted under each of the alternatives. 

The Draft EIS does not present the average sediment yield predictions for different 

areas (e.g., undisturbed soil, barren hillclimbs, and the road network) of the CCMA 

under each alternative. This information would be useful in characterizing how each 

alternative would affect soil resources, water quality, watershed conditions, and aquatic 

life in the CCMA. In addition, based on Dynamac (1998)1, five mine areas in the 

CCMA were determined to pose the greatest risk to water quality from metals 

contamination (Draft EIS, p. 206). It is unclear from the Draft EIS what actions BLM 

has conducted since the publication of that study to reduce surface water contamination 

in CCMA watersheds, and what the results are for water quality monitoring conducted 

since that time, including monitoring conducted since the closure of the CCMA in 

May, 2008. 

BLM Response: The Final EIS provides the projected emissions of criteria air pollutants for the proposed action and measures to mitigate these 

emissions. The proposed action also includes air quality monitoring and mitigation effectiveness monitoring that would be implemented to ensure 

public health standards are enforced and hazardous emissions from management activities are minimized. 

The DEIS reference to the Dynamac (1998) report characterizes the risk to water quality from metals contamination. Remediation of the areas 

identified in the study has been implemented through the BLM’s abandoned mine lands program, and is described in Section 3.2.3.3 (DEIS, pg. 

144). Management actions to address potential impacts of other abandoned mine lands to resources are common to all alternatives. 

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A summary of results for water quality monitoring conducted since the temporary closure order or the Serpentien ACEC was issued in May, 2008 

are included in Section 3.9.4 of this PRMP/FEIS.. 

Comment: Dust Suppression Measures Recommendations: 

The Draft EIS identifies several dust suppression and surface hardening measures that could be 

implemented “as needed” on major routes under all alternatives. While the costs of various measures are 

estimated and compared in Table 3.3-1, neither the feasibility nor the potential effectiveness of each of 

these measures is discussed in the Draft EIS. In addition, it is unclear what BLM’s decision criteria would 

be for selecting a specific method, how likely implementation would be, and how many miles of routes 

and which routes would be treated. 

Information regarding the feasibility and effectiveness of mitigation measures is essential to analyzing the 

realistic environmental impacts of alternatives. If the proposed mitigation is significantly underfunded or 

infeasible for other reasons and, therefore, not implemented, the potential environmental impacts could be 

significantly different than what is predicted for each alternative. 

In addition, the cost of each measure should be compared against its effectiveness so that BLM can make 

an informed decision about whether the project, as proposed, is cost effective. For example, BLM’s 1999 

Record of Decision for the CCMA (p. 10) committed to dust suppression at staging areas and along 

approximately 30 miles of main transportation routes “as appropriate” to reduce dust generation and 

associated asbestos exposure. However, we understand that only a few miles of roads were ever dust 

suppressed with water a few times between 1999 and 2004 because water was not available and road 

watering was not found to be very effective (pers. comm. between George Hill, BLM, and Jeanne 

Geselbracht, EPA, 9/9/04). In light of the projected cost, BLM’s past findings regarding feasibility and 

effectiveness, and EPA’s health risk assessment findings under moist soil conditions, we do not believe 

road watering has been proved to be a feasible or effective measure for the CCMA. 

The Final EIS should identify the 

goals of the dust suppression and 

surface hardening measures 

identified in Table 3.3-1, include an 

evaluation of the feasibility and 

effectiveness of these measures, 

identify the decision criteria BLM 

would consider in selecting such 

measures, and describe how likely 

implementation of each measure 

would be. The Final EIS should also 

describe the effectiveness monitoring 

that would be conducted under each 

alternative to determine how well 

dust suppression and surface 

hardening measures are working and 

discuss contingency measures that 

may be needed if monitoring 

indicates that initial measures are not 

as effective as predicted. 

BLM Response: Section 4.2.2 of the DEIS discloses the limits and constraints of the analysis, including Sec. 4.2.2.4 “Estimates of Asbestos 

Emissions Reductions, Cost, Effectiveness, and Feasibility of Mitigation Measures”. The feasibility and the potential effectiveness of dust 

suppression measures are further discussed in Section 4.3.2 (DEIS pg. 358). Appendix V, under MP-17 (DEIS pg. 643) BLM describes how 

mitigation measures would be implemented and identifies the need for effectiveness monitoring to determine how well dust suppression and 

surface hardening measures are working. 

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Comment: Typographical Errors Recommendations 

Page 334: First paragraph refers to Figure ES-I of EPA’s Risk Assessment, but this figure does not appear in the Draft EIS. 

Page 353: The first line of section 4.2.7.1 should say “>18” rather than “< 8.” 

Page 193: Paragraph 2 states, “The air basin is designated as non-attainment for the Federal PM1O and PM2.5 standards.” 

Please note that, although the San Joaquin Valley Air Basin is in non-attainment for PM2. 5, it is in maintenance status for 

the PM10 standard. 

Page 449: Paragraph 1 reiterates this misstatement and should be rectified. 

Page 449: Paragraph 7 also states that San Benito and Fresno counties are in non-attainment for the PM1O National 

Ambient Air Quality Standards. This should be changed to indicate that San Benito County is in attainment for PM1O, and 

Fresno County is in maintenance status for PM1O. 

-noneBLM Response: Page 334: Inserted reference EPA to risk assessment.
 

Page 353: The first line of section 4.2.7.1 should say “>18” rather than “< 8.”
	

Page 193: Paragraph 2 states, “The air basin is designated as non-attainment for the Federal PM1O and PM2.5 standards.” Please note that, 

although the San Joaquin Valley Air Basin is in non-attainment for PM2. 5, it is in maintenance status for the PM10 standard.
 

Page 449: Paragraph 1 reiterates this misstatement and should be rectified.
 

Page 449: Paragraph 7 also states that San Benito and Fresno counties are in non-attainment for the PM1O National Ambient Air Quality
 

Standards. This should be changed to indicate that San Benito County is in attainment for PM1O, and Fresno County is in maintenance status for
 

PM1O.
 

Thank you. 

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AG-USFWS: United States Fish & Wildlife Service [Sacramento Field Office]
 

Comment: CCMA Watersheds Recommendation 

The Clear Creek upper-watershed provides runoff into numerous west and east-flowing streams, 

[including a tributary (San Carlos Creek)] to Silver Creek which eventually connects with Panoche 

Creek in western Fresno County. During heavy rainfall events, Panoche Creek can influence water 

quality in downstream waters including the Grasslands Marshes and the San Joaquin River. The 

State Water Resource Control Board (SWRCB) listed Panoche Creek (from Silver Creek to 

Belmont Avenue) as impaired for mercury, sedimentation and selenium in 2006 (SWRCB 2006). 

The sources of selenium in this waterway were listed as agriculture, livestock grazing, and 

highway/road/bridge construction (SWRCB 2006). In the 2006 303(d) list of impaired 

waterbodies for California, the SWRCB recommended that the affected size of Panoche Creek be 

expanded to include the length from its headwaters to Silver Creek, which increased the entire 

segment by 27 miles. 

We encourage BLM to consider downstream 

water quality impacts associated with land 

management of the upper-watershed in the 

DRMPIEIS. Further, we ask that BLM 

consider implementation of a preferred RMP 

alternative that would provide the greatest 

benefit to downstream water quality. Such 

management actions could include reduced 

grazing prescriptions on upper watershed 

lands within the Clear Creek Management 

Area. 

BLM Response: The DEIS references a report prepared by Dynamac in 1998 that characterizes the risk to water quality from metals 

contamination in the CCMA. Remediation of the areas identified in the study has been implemented through the BLM’s abandoned mine lands 

program, and is described in Section 3.2.3.3 (DEIS, pg. 144). Management actions to address potential impacts of other abandoned mine lands to 

resources are common to all alternatives. 

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AG-USFWS: United States Fish & Wildlife Service [Ventura Field Office]
 

Comment: 

San Benito Evening Primrose & Other Listed Species That May Occur In CCMA 

Recommendation 

The San Benito evening-primrose is restricted to serpentine-derived alluvial terraces and deposits near San Benito We recommend that 

Mountain, within and adjacent to the CCMA (Service 2009). Of the 63 known populations of San Benito evening- biological surveys for the 

primrose, all but 5 occur within the boundaries of the CCMA (Bureau 2009). Identified threats to this species include, previously mentioned 

but are not limited to, off-highway vehicle (OHV) recreation, camping, soil loss and erosion, facilities construction species that have the 

and maintenance, mining activities, and habitat alteration due to invasive species; the most significant of these threats potential to occur in the 

being OHV use. Implementation of the Bureau’s 2006 Record of Decision, specifically, the closing of some routes CCMA be conducted if 

and barrens, in addition to the temporary closure of the CCMA and ongoing monitoring and management of the San suitable habitat is present. 

Benito evening primrose and its habitat, has helped to reduce threats to the species and maintain populations (Service We recommend that 

2009). survey results and any 

related appendices be 

If the land use management alternative implemented by the Bureau has the potential to adversely affect the San submitted to our office for 

Benito evening-primrose, consultation pursuant to section 7 of the Act is required. review. 

BLM Response: Biological surveys for the rare species that have the potential to occur in the CCMA has been conducted throughout the 

management history f the CCMA and would continue under the proposed plan, and survey results are submitted to the FWS for review on an 

annual basis. 

Comment: Land Disposal and Acquisition Recommendation 

We recommend that biological surveys for listed species be conducted on lands proposed for disposal or acquisition, and on 

any lands that may be redesignated for recreational purposes. We recommend that the survey results and any related 

appendices be submitted to our office for review. In addition, if the intent of use of lands that are disposed of, or acquired by 

the Bureau, may have an impact on listed species or their habitats, consultation pursuant to section 7 of the Act is required. 

-noneBLM Response: Biological surveys for listed species would be conducted on lands proposed for disposal or acquisition, and BLM shall consult 

with FWS on any actions that may have an impact on listed species or their habitats. 

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Comment: California Condor Recommendation 

The CCMA is located well within the range of the California condor, and there is additional concern regarding lands that 

may be left unmanaged by the Bureau following the designation of a land use management plan. For instance, the “Tucker 

Mountain Zone” proposed for disposal in the northwestern CCMA is located within approximately 16 miles of the Pinnacles 

National Monument, a California condor release site. Hunting, development, and construction of communications towers 

and/or wind turbines, are a few examples of land use that could be cause for concern in the area. For this reason, we 

recommend that the utmost consideration is taken when determining the use and long term goals of the proposed disposal 

lands to ensure the California condor is not adversely affected. 

-noneBLM Response: The proposed action analyzed in the Proposed RMP and Final EIS has been modified to retain the public lands in the Tucker 

Zone in order to preserve wildlife habitat in cooperation with the California Department of Fish and Game and private property owners in the area. 

Comment: Bald and Golden Eagle Protection Act Recommendation 

On November 10, 2009, the Service implemented new rules (74 FR 46835) governing the take of golden eagles (Aquila 

chrysaetos) and bald eagles (Haliaeetus leucocephalus). The new rules were released under the existing Bald and Golden 

Eagle Protection Act, which has been the primary regulation protecting unlisted eagle populations since 1940. All activities 

that may disturb or incidentally take an eagle or its nest as a result of an otherwise lawful activity must be permitted by the 

Service under this act. 

-noneBLM Response: Comment noted. 

Comment: Communication Towers Recommendation 

The Draft CCMA RMP/EIS includes management actions that 

would serve to mitigate impacts to visual resources, including 

regulating communications towers to appropriate areas. 

Construction of communications towers (including radio, 

television, cellular, and microwave) in the United States has 

been growing at an exponential rate, increasing at an estimated 

6 percent to 8 percent annually. The construction of new 

towers creates a potentially substantial adverse impact on 

migratory birds, especially some 350 species of nightmigrating birds. 

We recommend that the Bureau review the enclosed interim guidelines the 

Service has adopted concerning the siting, construction, operation, and 

decommissioning of communications towers. These guidelines were developed 

because the number of communications towers in the United States has increased 

dramatically and evidence suggests that these towers pose a hazard to migratory 

birds. Implementation of these guidelines is voluntary, and the recommendations 

must be balanced with Federal Aviation Administration requirements and local 

community concerns where necessary. (Enclosure: U.S. Fish and Wildlife 

Service Interim Guidelines For Recommendations On Communications Tower 

Siting, Construction, Operation, and Decommissioning) 

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BLM Response: BLM decision makers have reviewed the interim guidelines the Service has adopted concerning the siting, construction, 

operation, and decommissioning of communications towers; and the recommendations would be balanced with Federal Aviation Administration 

requirements and local community concerns where necessary. 

AG-USGS: United States Geological Survey 

Comment: Recommendation 

The U.S. Geological Survey has reviewed the Draft Clear Creek Management Area California. We do not have substantive 

comments at this time. 

NA 

BLM Response: Thank you.
 

AG-DTSC: Department of Toxic Substances Control
 

Comment: General Recommendation 

DTSC agrees that the 

alternatives have been 

thoroughly established and 

continues to recommend that 

any alternative that is selected 

be evaluated for potential 

human health risk due to 

asbestos exposure and to 

implement mitigation 

measures as appropriate. As a 

recreational user of a 

proposed new area may 

encroach on the Atlas 

Asbestos Mine Operable Unit 

of the Superfund Site, the site 

should be secured as 

necessary from potential 

trespass. 

1. Recommend all possible precautions be used to minimize potential exposure to asbestos. 

2. Map 5 contains boundaries for serpentine and non-serpentine formation. Recommend the existing and proposed 

new recreational facilities identified in Alternative F outside the ACEC be verified with USGS maps as clearly 

outside the overlying serpentine formation. If found, recommend assessing the existing and proposed routes for 

the occurrence of asbestos and use of activity based monitoring and assessment of potential risk as deemed 

necessary. Appropriate mitigation measures should be considered for minimizing asbestos exposures to all 

proposed uses. Consider similar scenarios to those assessed by USEPA for the ACEC to determine potential risk 

to adults and children using OHVs in these areas. Develop an activity based scenario for any new uses as well 

(e.g equestrian). 

3. Recommend the road proposed for the scenic route through the ACEC be resurfaced to reduce asbestos 

emissions. 

4. Consider reducing speed limits of 15-25 miles per hour on the scenic route to no more than 10 unless 

resurfacing to mitigate asbestos emissions is completed. 

5. For potential asbestos areas, consider establishment of public use vehicle washing and HEPA vacuuming 

stations at the entrance(s) with standard operating procedures so that vehicles can be cleaned upon leaving. 

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From review of the document, 6. Consider not allowing livestock grazing on the ACEC BLM managed lands in order to minimize dust 

the grouping of the generation and release of asbestos. 

management actions and 

BLM’s preferred alternative 7. To the extent feasible, recommend adding precautions to protect fire fighters using Best management Practices 

are well defined in section 2. from asbestos exposure during wildland fires and controlled burns within the ACEC. 

From our review of the 

RMP/EIS, the following 8. Recommend for Best Management Practices (Appendix V) a) trigger for 

comments [i.e. initiating each measure, b) conditions in which the management practices will \ be used, and c) measuring 

recommendations] are techniques and criteria for measuring effectiveness 

provided: 

BLM Response: Under the proposed action, BLM would prepare separate Travel Management Plans to designate routes outside the ACEC for 

vehicle use and identify appropriate mitigation measures to alleviate the effects to public land resources using the screening criteria and route 

designation methodology described in Appendix II. 

Map 5 only depicts soils derived from serpentine parent materials. All recreational facilities outside the ACEC, including routes and trails to be 

considered in these Travel Management Plans, would incorporate the recommended information from USGS maps to minimize surface 

disturbance associated with management activities and visitor use within the serpentine formation and serpentine derived soils known to have high 

concentration of asbestos fibers. 

AG-DPR-OHMVRD: Department of Parks and Recreation 

Comment: Scope of the Draft RMPIEIS Recommendation 

The Division is concerned by the basic scope of the Draft RMP/EIS. As stated in its Introduction, the Draft RMP/EIS is a 

“stand alone” document designed exclusively to guide the management of the Clear Creek Management Area (CCMA). 

Alternatively, the Hollister Field Office Resource Management Plan (Hollister RMP) (2007) provides for management by 

BLM’s Hollister Field Office of the remaining areas beyond the bounds of CCMA. Thus, the BLM presents a mutually 

exclusive situation in which management actions proposed in the Draft RMPIEIS are limited solely to the CCMA, 

independent of the surrounding area. 

Accordingly, the Division is concerned all relevant alternatives and other impacts are not thoroughly addressed within the 

Draft RMP/EIS. In particular, the Draft RMP/EIS offers no consideration to viable options or substitutes for the CCMA 

The Division believes 

it essential for the 

BLM to examine 

every possibility 

before this important 

OHV recreation area 

is permanently lost 

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recreational opportunities. Instead, the establishment of new OHV recreation areas outside the CCMA is relegated to the 

Section 1.3.3 — “Issues Considered but Not Further Analyzed” (page 8). The subsequent suggestion in the Draft 

RMP/EIS (page 9) that the Hollister Field Office and OHMVR Division work together at a later date to find additional 

OHV recreation areas elsewhere in the Hollister Field Office, while a welcome proposal, is seemingly counter to the 

scope of the document and not a satisfactory solution. In fact, the Hollister RMP offers no OHV recreational opportunity 

on par with the CCMA. Indeed, few areas in the country offer an OHV experience like that provided at CCMA. 

BLM Response: The Hollister RMP (2007) provides for management by BLM’s Hollister Field Office and considers viable options for motorized 

recreational opportunities in the remaining areas beyond the bounds of CCMA. The CCMA Draft RMP/EIS also includes a range of alternatives 

that considers viable options for motorized recreation opportunities both inside and outside the Serpentine ACEC based on the purpose and need 

described in Chapter 1. 

Comment: Purpose and Need Recommendation 

The BLM asserts the need for the CCMA RMP/EIS arises from numerous changes in circumstances since the current land 

use plan decisions were adopted. As evidence, the BLM suggests the existing RMP and subsequent amendments do not 

address current public health and safety and resources protection issues in CCMA. However, the list of factors that illustrate 

the “Purpose and Need” for the RMP appear disingenuous: 

First, the BLM claims the May 2008 CCMA Asbestos Exposure and Human Health Risk Assessment (Health Risk 

Assessment) prepared by the United States Environmental Protection Agency (EPA) “provides significant new information 

that must be incorporated into a land use plan to evaluate the public health risk associated with BLM land use 

authorizations.” 

Second, the BLM asserts the “current management plan does not specifically address listing and/or additional habitat needs 

for species protected under the federal 1973 Endangered Species Act (ESA), including the California condor, red-legged 

frog, and 

tiger salamander.” 

Lastly, the BLM suggests “changes in social and economic conditions in San Benito County, the San Joaquin Valley, and the 

entire State of California have led to increased demand for use of public lands for recreation and energy production as well as 

an increased awareness and social value placed on the cultural and natural resources in the Planning Area.” 

Of the three items listed above, the first (asbestos) is clearly the driving force of the entire document. However, the 

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significance and accuracy of the information presented in the Health Risk Assessment is subject to debate. 

The second item is irrelevant to the Draft RMP/EIS. The California condor does not exist within the CCMA and is only 

found to be “potentially present within the CCMA” (pg. 174). The red-legged frog is present fifteen miles or more 

downstream from the CCMA and has never been recorded in or near the CCMA (pg. 174). Further, the tiger salamander has 

“never been recorded in the environs of CCMA” (pg. 174). The third item, changes in socio-economic conditions, is poorly 

supported. The purported increase in demand and social awareness are not demonstrated in the discussion of the affected 

environment. 

BLM Response: Refer to Common Response Section 2: Purpose and Need. 

Comment: Recommendation 

The BLM actions are prompted predominantly by the EPA’s Health Risk Assessment. The BLM believes the Health Risk 

Assessment provides significant new information that must be incorporated into a land use plan to evaluate the public health 

risk associated with BLM land use authorizations.” 

However, the EPA report included substantial caveats regarding the accuracy and assumptions used to develop the report. 

The following items appear in the “Limitations of the Assessment”: 

- “... there are assumptions and variables that can cause the calculations to either overestimate or underestimate the actual 

risk.” 

- “The CCMA assessment may overestimate or underestimate risk if EPA’s measurements of exposure and the assumptions 

of exposure frequency are either greater or less than actual conditions.” 

- “Additional uncertainty is introduced because both the IRIS and the OEHHA toxicity values for asbestos are based on 

epidemiological studies of work place exposures to intermittent high asbestos concentrations over extended periods. While 

the concentrations measured for activities at CCMA are significantly elevated, the exposure is infrequent and episodic.” 

- “Because there is no clear mode of action for asbestos-induced disease and no threshold for cancer health effects, using a 

direct time-weighted extrapolation from the longer, chronic occupational exposures to shorter-term, episodic exposures may 

underestimate or overestimate the risk.” 

- “The risks could be much lower because the exposures may be too infrequent or the total retained fiber burden too few to 

initiate the asbestos disease process.” 

Given the uncertain conclusions of the document, it seems inappropriate for BLM to rely on the document to guide 

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substantial and controversial land management actions. Decisions based on such variable and imprecise studies should be 

cautiously and conservatively implemented, if at all. Instead, the preferred alternative reduces the acreage available within 

the Area of Critical Environmental Concern (ACEC) for OHV recreation to 1.5% of the area, defined as a “Scenic Route,” 

and restricts use in the ACEC to single vehicle class during the day. Such a dramatic reduction of opportunity should only be 

recommended if the supporting documentation is considerably more definitive. 

The Division believes serious questions have been raised about the Health Risk Assessment, such as identification and 

differentiation of chrysotile and amphibole asbestos, asbestos-related epidemiology, appropriateness of risk models, and 

activity based sampling methods. The Division contends further research and characterization of the potential hazard at the 

CCMA is warranted. Since the preferred alternative effectively closes the CCMA to OHV recreation, the Division finds it 

imperative the hazard risk be independently verified before a final decision is made. 

BLM Response: 

During the public comment period on the Draft CCMA RMP/EIS, the California State Park Off-Highway Motor Vehicle Recreation 

Division (OHMVRD) requested that BLM wait until an independent asbestos exposure study in the CCMA could be prepared before 

issuing the CCMA Proposed RMP and Final EIS. 

The BLM agreed to the OHMVRD’s request, and on March 22, 2011 the OHMVRD released the report, titled “Preliminary Analysis 

of the Asbestos Exposures Associated with Motorcycle Riding and Hiking in the Clear Creek Management Area (CCMA) San Benito 

County, California.” The report was completed by scientists from the International Environmental Research Foundation (IERF), and is 

linked on the OHMVRD’s website: http://ohv.parks.ca.gov/pages/1140/files/ierf_ccma_final_3_8_11-web.pdf 

The purpose of the OHMVRD commissioned report was to determine if management and operational strategies could be employed at the CCMA 

to mitigate risk while still allowing access for off-highway vehicle recreation. However, BLM has determined the IERF report does not offer any 

new technical or scientific information that alters analysis of human health risks and impacts to the environment associated with exposure to 

airborne asbestos emissions from the range of alternatives described in this PRMP/FEIS. 

Both the EPA and the California Department of Toxic Substances Control’s (DTSC) Human and Ecological Risk Office (HERO) prepared 

comment letters that identified significant concerns about the IERF report. These comment letters are also linked on the OHMVRD website: 

http://www.parks.ca.gov/pages/1140/files/ccmaepacommentsierfreport12may11.pdf 

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http://www.parks.ca.gov/pages/1140/files/dtsc-analysis-ierf-report.pdf 

IERF’s rebuttal to the comments from EPA and DTSC are also linked on the OHMVRD website: 

http://www.parks.ca.gov/pages/1140/files/ierf-epa-rebuttal-ccma.pdf 

http://www.parks.ca.gov/pages/1140/files/ierf-dtsc-hero-rebuttal-ccma.pdf 

Upon evaluation of the IERF and EPA studies as well as comments received on the CCMA Draft RMP/EIS, BLM determined that adaptive 

management criteria would be needed to allow for adjustments to land use in light of new information regarding asbestos exposures. The 

variability of meteorological conditions and soil moisture in the Serpentine ACEC indicate that greater attention to detail and more information 

will be helpful to manage all forms of use in the area. The IERF and EPA studies conclude there is a need for more detailed management and a 

need to consider forms of mitigation to offset exposures to the public while using the area. Through adaptive management BLM is committed to 

evaluating all new and credible information on strategies for continued public use in the area. 

BLM acknowledges that controversy exists regarding the human health risks associated with exposure to naturally occurring asbestos. The EPA 

risk assessment and the IERF report both highlighted the need for further research to determine effective strategies to reduce risk to CCMA 

visitors. Therefore, the preferred alternative identifies “adaptive management criteria” that would allow the BLM to make changes to designated 

route systems and addresses how routes may be modified within the transportation network in the future. The adaptive management criteria were 

developed in response to the issues and concerns identified in the IERF study and public comments on the CCMA Draft RMP/EIS (2009). If one 

of these criteria are met, then BLM would reassess CCMA RMP land use decisions associated with human health risks from exposure to airborne 

asbestos fibers, and potentially apply adaptive management should significant new information become available that warrants modifications to 

the limits on annual visitor days or the total miles of routes available for motorized use in the ACEC. At a minimum, the BLM will re-examine the 

body of peer-reviewed data available on this subject within three years following issuance of a record of decision for the CCMA RMP. 

It should be noted that routes designated “open” for motorized use under the range of alternatives analyzed in this PRMP/FEIS satisfy the 43 CFR 

8342.1 “minimization criteria” for protection of public land resources. Whereas, the miles of designated routes and restrictions on vehicle types in 

the ACEC are based on the “limited” area designation, and the need to reduce asbestos emissions from BLM management activities and minimize 

human health risks associated with exposure to airborne asbestos in the CCMA. 

Comment: Waiver of Liability and Indemnification of Risk Recommendation 

A waiver of liability has been consistently proposed as an option to allow continued recreational use of the CCMA. -none250
 
 

 

 

 

 

 

 

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However, BLM dismisses the concept of a waiver for recreational users of CCMA in the discussion of Section 4.2.6.2 

Mitigation (page 352). In the BLM’s view, “developing a waiver of liability, or establishing indemnification of risk, would 

have no beneficial impacts on public health and safety because neither approach would actually reduce exposure to airborne 

asbestos or improve overall protection of human health and the environment.” 

The Division disagrees with this assertion and contends a waiver should be considered as a practical option to mitigate the 

concerns of the BLM. The prospect of a waiver of liability should give a reasonable individual cause to consider 

participating in an activity at that location. On an individual basis, potential exposure to airborne asbestos may be reduced or 

avoided should a person opt not to enter the CCMA due to the waiver and potential hazards identified therein. 

The waiver discussion in the Draft RMP/EIS continues, “. . . the potential for waivers of liability or indemnification of risk 

as ‘stand-alone’ mitigation measures for human health and safety do not satisfy the purpose and need for the CCMA 

RMP/EIS.” 

This statement is contrary is to the stated purpose of the Draft RMP/EIS, which is to “establish goals, objectives, and 

management actions for BLM-administered lands in CCMA that address current issues, knowledge, and conditions.” 

Requiring a waiver is undeniably a management action within the purview of BLM, and there is no obligation that it be 

implemented on a “stand alone” basis. Furthermore, BLM finds the waiver of liability to be an acceptable tool when used in 

conjunction with other management circumstances in the Draft RMP/EIS, including the preferred alternative. For example, 

requiring “. . . signed waivers of liability to indemnify BLM against risk of tort claims associated with CCMA visitor use and 

exposure to airborne asbestos fibers” is presented in the Management Actions Common to Alternatives B through G (page 

41). A similar statement also appears in the presentation of the preferred alternative (page 86) and in the discussion of 

mitigation measures (page 351). 

The Draft RMP/EIS further states, the action of providing waivers of liability or indemnification of risk as “stand-alone” 

mitigation measures, “would likely have major long-term adverse impacts on human health and the environment due to the 

perception that exposure to airborne asbestos fibers above the acceptable risk range established under the EPA Superfund 

Act is permissible and authorized by the Federal government.” 

This statement is entirely speculative in nature. The statement also contradicts Table 2.6-2, which presents a comparison of 

impacts to public health and safety and hazardous materials (page 100). Discussing HAZMAT Mitigation Measures, this 

table identifies ‘moderate (emphasis added) adverse effects from signed waivers of liability...” The justification for the 

different level of impact is unknown. Moreover, it is counterintuitive that a waiver disclosing potential risks would serve to 

lessen the public’s perception of the risk. 

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BLM Response: Refer to Common Response Section 3: Range of Alternatives. 

Comment: Alternative OHV Recreational Management Strategies Not Considered Recommendation 

The EPA’s Health Risk Assessment of CCMA demonstrated that risk regarding exposure to naturally 

occurring asbestos is present when different recreational activities are conducted at CCMA, including OHV 

recreation. The Health Risk Assessment did not evaluate how the risk might be lowered if mitigative 

management measures were implemented. Consequently, mitigative OHV management measures - short of 

eliminating OHV recreation at CCMA - were not truly given consideration from a risk analysis perspective. 

The Division believes there are many management strategies that could be implemented that could reduce 

asbestos exposure risk, such as seasonal operation of CCMA, trail re-routing and reducing trail widths, and 

limiting single-track trail use to motorcycles only. These and similar strategies should be evaluated from a 

health-based risk assessment perspective to determine if risk from potential asbestos exposure is reduced to a 

degree that is acceptable by BLM. 

The Division is troubled by the 

ramifications of this proposed 

RMP/EIS and its adverse 

impacts to OHV recreation. As 

always, the Division is prepared 

to work closely with the BLM in 

developing alternatives which 

will lead to reopening the CCMA 

to continued OHV recreation. 

BLM Response: Refer to Common Response Section 3: Range of Alternatives. 

AG-CALFIRE: Department of Forestry and Fire Protection 

Comment: Recommendation 

After reviewing the Draft Environmental Impact Statement for the Clear Creek Management Area, I have no significant 

concerns. CAL FIRE and the Bureau of Land Management have long enjoyed an excellent, cooperative working 

relationship on fire management issues in the Clear Creek area and I would expect that to continue in the future. 

-noneBLM Response: Thank you.
 

AG-DWR: Department of Water Resources
 

Comment: Impacts from Increased Recreation Activities Recommendation 

(BLM) is proposing to increase the recreational activities of the Clear Creek Management Area (CCMA) which was closed 

to the public in May 2008” and that “as a State Agency with lands and facilities that may be affected by the change in land 

use in the CCMA, we have reviewed this plan from a flood and sediment management perspective. 

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BLM Response: All the alternatives in the Draft CCMA RMP/EIS (except for the No Action Alternative) would actually reduce the amount of 

recreation activities in the CCMA. Refer to Common Response Section 3A and 3B. 

Comment: Impacts to California Aqueduct Recommendation 

The CCMA is located in San Benito and Fresno Counties in Central California. It includes part of the New Idria The RMP/EIS does not 

Formation, a serpentinite rock body that contains the largest asbestos deposit in the country. This area is part of the describe the impact of 

Arroyo Pasajero watershed which ultimately drains into the ponding basin along the California Aqueduct. increased activities in the 

CCMA on the operation 

DWR and Reclamation owns, operates, and maintains the ponding basin as part of the California Aqueduct which and maintenance 

serves 25 million people in Southern California and hundreds of thousands of acres of farmland in the San Joaquin activities in the ponding 

Valley. DWR cannot support any increased recreational activity in the CCMA because it will likely increase basin at the California 

sedimentation into the Arroyo Pasajero Ponding Basin including sediments containing naturally occurring asbestos Aqueduct. 

fibers sourced from the New Idria Serpentinite outcrop within the CCMA and therefore could potentially affect our 

operations and maintenance activities in the basin. These activities include maintenance of a channel in the Arroyo Asbestos is a known 

Pasajero to guide its flows into the ponding basin to reduce flooding along Lassen Avenue and the town of Huron. carcinogen according to 

the U.S. Environmental 

The watershed is drained by several streams that drain into Los Gatos Creek, which in turn drains into the Arroyo Protection Agency (EPA), 

Pasajero ponding basin managed by DWR. Historical flood events have brought a significant amount of floodwaters and the CCMA is part of 

and asbestos-laden sediments into the ponding basin at the California Aqueduct. Many of these flood events cause the Atlas Asbestos Mine 

significant damage to roads and surrounding farmlands and can be a threat to the aqueduct. DWR is concerned that Superfund Site. It should 

any increased activity in the CCMA would increase sediment loads and naturally occurring asbestos concentrations in be noted that an 

floodwaters, potentially reducing the ability to effectively operate the ponding basin during flood events and send overwhelmingly vast 

floodwaters into the aqueduct. We are further concerned that these increased sediment loads would reduce the storage majority of the asbestos 

capacity of the basin and reduce the flood protection that the basin provides to surrounding farmlands and State and fibers contained in 

federal water users who depend on the high quality deliveries from the California Aqueduct. In 2005, DWR and sediments from this area 

Reclamation spent over $16 million to restore storage in the basin. Increased sediment deposition in the basin will are from naturally 

require DWR to conduct this work more often at a further cost to water users. occurring outcrops and 

not the superfund sites; 

DWR is also concerned that any increased activity within the CCMA could potentially further restrict maintenance these superfund sites 

activities of DWR and Reclamation in managing the ponding basin at the California Aqueduct. In coordination with encompass approximately 

EPA due to the Superfund sites that formerly existed on the Los Gatos Creek drainage of the New Idria Serpentinite 1,300 acres or about 4 

outcrop, DWR and Reclamation have significantly restricted the activities in the ponding basin to ensure that the percent of the total 

basin is managed to reduce airborne asbestos and the inflow of floodwaters into the California Aqueduct that may exposed asbestos-bearing 

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contain asbestos. EPA continues to make certain that DWR’s and Reclamation’s maintenance activities in the serpentinite body. 

ponding basin reasonably reduce the amount of airborne and waterborne asbestos. 

The RMP/EIS does not 

Several studies have documented the flood-sediment-asbestos problems within the Arroyo Pasajero watershed and describe the impact of 

ponding basin. These studies show that prudent watershed management is necessary to reduce the magnitude of increased activities in the 

floods and transported sediments and asbestos from flood runoff. The Coordinated Resource and Management CCMA on floodwater 

Planning (CRMP) groups formed inthe watershed have worked hard to inform landowners that responsible watershed runoff, sediment 

management is necessary to reduce floods and preserve the water quality in the watershed. DWR, Reclamation, and transport, and suspended 

BLM have all participated in the CRMPs and we should also ensure that our activities are also protecting the valuable asbestos fibers in the 

resources in the area. creeks that drain the 

CCMA. 

BLM Response: Section 4.9 of the CCMA Draft RMP and EIS and the Prospoed RMP and FEIS describe the potential impacts from seven 

management alternatives and various land use allocations on the water quality and quantity in creeks that drain the CCMA. 

AG-OPR: California Governor’s Office of Planning and Research, State Clearinghouse 

Comment: CCMA Draft RMP/EIS SCH#: 2004074007 Recommendation 

The State Clearinghouse submitted the above named Draft EIS to selected state agencies for review. The review period 

closed on March 8, 2010 and no state agencies submitted comments by that date. This letter acknowledges that you have 

complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California 

Environmental Quality Act. 

-noneBLM Response: Thank you.
 

AG-MBUAPCD: Monterey Bay Unified Air Pollution Control District
 

Comment: Health Risk to Exposure to Naturally Occurring Asbestos in the CCMA (Page 1) and Enforcement of 

Health Risk Standard 

Recommendation 

Given the recommended health-based limitation of no more than one visit per year, please explain how the BLM would 

enforce such a policy. Would an individual be issued a CCMA Passport that would be checked each time he/she visited the 

CCMA? 

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BLM Response: The Proposed Plan would limit the type and duration of public use that can occur in the ACEC, and would enhance opportunities 

for public use in the surrounding management zones within the CCMA. Roads entering the ACEC would be gated to provide for controlled 

access. An access permit system would be implemented to address frequency and duration of public use. 

Comment: State Regulatory Requirements Recommendation 

As specified in the environmental document, asbestos can be released from serpentine and ultramafic 

rocks when the rock is broken or crushed. “At the point of release, the asbestos fibers may become 

airborne, causing air quality and human health hazards.” (Technical Advisory, CEQA and Asbestos: 

Addressing Naturally Occurring Asbestos in CEQA Documents. State of California, Governor’s Office of 

Planning and Research, July 2008.) 

Serpentine and asbestos-bearing ultramafic rock materials used for surfacing applications subjected to 

vehicular, pedestrian, or non-pedestrian use, such as cycling and horse-back riding, may not contain more 

than 5% asbestos under the Asbestos Airborne Toxic Control Measure (ATCM) for surface applications 

adopted by the California Air Resource Board (CARB) in 1990. In July 2000, CARB amended the ATCM 

to lower the allowable asbestos content to less than 0.25% for surfacing applications. In addition, the 

amended rule prohibits the use of surfacing material from ultramafic rock units identified on specific 

geological maps developed by the California Department of Conservation unless testing of the material 

demonstrates that it is below the 0.25%. Exemptions for exemptions can be filed with local air pollution 

control districts. In July 2001, CARB approved the ATCM for Construction, Grading, Quarrying and 

Surface Mining Operations to minimize naturally occurring asbestos (NOA) through application of best 

management practices for fugitive dust. 

Prior to commencement of project activities, this ATCM requires notification to the local air pollution 

control district, which would require the Bureau of Land Management to contact the Monterey Bay 

Unified Air Pollution Control District (MBUAPCD). 

The MBUAPCD would like to work 

with the BLM to ensure that human 

health risk associated with activities 

within the CCMA is reduced to an 

acceptable level and that those 

activities do not result in the release 

of airborne asbestos that could affect 

the general public. This would 

include an evaluation of the health 

risk posed by any of the Alternatives 

except Alternative G, which would 

make permanent, the current 

temporary closure order “designating 

the entire Serpentine ACEC as 

“Closed” to vehicle use, and prohibit 

all forms of public entry into the 

30,000-acre area of serpentine high 

in asbestos fibers.” (Page 31) 

BLM Response: Per the ATCM requirements, the BLM would contact the Monterey Bay Unified Air Pollution Control District (MBUAPCD) to 

provide notification to the local air pollution control district prior to commencement of project activities to implement the proposed land use plan. 

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Comment: Section 4.7, Air Quality. Page 444. Recommendation 

“The goal for air quality management is to ensure that BLM authorizations and management activities comply with local, 

State and Federal air quality regulations, requirements, State Implementation Plans, and Regional Air Board standards and 

goals.” 

As specified in Section 3.7, Air Quality (pages 190 et seq.); the North Central Coast Air Basin (NCCAB) is currently 

designated as attaining all federal air quality standards. It is designated non-attainment for the state ozone and P1M0 

standards. However, the recent EPA proposal to lower the ozone standard to 0.060-0.070 parts per million would result in the 

NCCAB being designated non-attainment for the federal standard. 

-noneBLM Response: Comment noted. 

Comment: Section 4.7.3.3, Mitigation. Page 446. Recommendation 

Mitigation of the impacts associated with various project alternatives is described in terms of compliance with various 

federal, state and local regulations, but does not provide sufficient detail to allow a meaningful analysis. 

-noneBLM Response: Comment noted. 

Comment: Section 4.7.7.3, Climate Change. Page 451. Recommendation 

Despite references in the document to the growing population of California and increasing demand for recreational resources, 

as well as the travel (vehicle miles traveled) induced by the recreational opportunities currently offered and planned for the 

CCMA, the document provides no plan or strategy to address California’s Global Warming Solution Act of 2006 (AB 32) 

requirement to reduce greenhouse gases to 1990 levels by 2020. 

-noneBLM Response: Comment noted. The DEIS (pg. 451) and CCMA Proposed RMP and FEIS (Section 4.7.1.2.2) state the following wuth regards 

to climate change. “This analysis assumes that global climate change will make the planning area warmer and drier by the end of the 

21st century. However, the body of information and predictive models for climate change is in its infancy regarding prediction of site 

specific impacts to areas such as the CCMA, and the plan assumes that knowledge will advance quickly with the current emphasis on 

climate research and model development. As the RMP is implemented, BLM managers would place a continued emphasis on 

research, and studies may include components to assess the impacts of changing climate. In the event that climate change made 

achievement of RMP objectives themselves infeasible, the plan would need to be amended accordingly.” 

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Comment: Impacts of Proposed Resource Management Plan and Potential Non-Attainment Designation 

of the NCCAB and General Conformity 

Recommendation 

As specified on page two of this comment letter, EPA’s recent proposal to further lower the federal ozone standard to 0.060 ­ As previously 

0.070 parts per million would increase the efforts already needed to bring air quality in the NCCAB into compliance with stated, the 

both federal and State ozone standards. MBUAPCD 

would like to work 

The BLM’s Resource Management Plan for the CCMA is a project subject to the National Environmental Policy Act with its with the Bureau of 

potential to degrade air quality and obstruct implementation of federal and State air quality standards. When the NCCAB is Land Management 

designated non-attainment for the federal ozone standard, all federal actions would become subject to the Clean Air Act’s to ensure that all 

General Conformity Rule. air quality impacts 

are minimized to 

One effect of being designated non-attainment for a federal air quality standard is becoming subject to federal conformity the lowest possible 

requirements, which include transportation conformity and general conformity. Established under the Clean Air Act (Section level. 

176 (c), the General Conformity Rule requires that “...no department, agency or instrumentality of the Federal Government 

shall engage in, support in any way or provide financial assistance for, license or permit, or approve any activity which does 

not conform to an applicable implementation plan.” (42USC7506(c)) 

BLM Response: The CCMA Draft RMP and EIS (pg. 191) and the Proposed RMP and FEIS (Section 3.7.3 provide the following information 

regarding conformity with state implementation plans. “The BLM’s National Science and Technology Center prepared an Air Conformity 

Analysis and updated PM emission inventory for the CCMA based on soil type, silt loading, and vehicle type to analyze the impacts to air quality 

from the Proposed CCMA RMP Amendment and Final EIS for Route Designation (2005). This data quantifies the PM10 and PM2.5 contribution 

from vehicles under current management (i.e. No Action Alternative) and is located in Appendix IX. The results of the 2005 Air Conformity 

Analysis determined that emissions associated with BLM’s land use decisions and public vehicle use in the CCMA are below de minimis levels.” 

Section 4.7 of the CCMA Draft RMP and EIS and the Prospoed RMP and FEIS describe the potential effects of the seven management 

alternatives considered for CCMA, and all the alternatives in the Draft CCMA RMP/EIS (except for the No Action Alternative) would actually 

reduce the amount of emmissions from the recreation activities in the CCMA analyzed in 2005. 

AG-SBC: County of San Benito 

Comment: Potential Effects for San Benito County Recommendation 

Air Quality: 

 ̈ Prescribed fires are mentioned as a vegetation management measure in all alternatives, but the specific procedures to be 

used could be further detailed. 

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BLM Response: Section 2.4.17 of the CCMA Draft RMP and EIS and Section 2.5.17 of the Prospoed RMP and FEIS describe BLM’s proposed 

wildland fire strategies and targets for prescribed fire and mechanical treatments in CCMA fire management units. Resource condition objectives 

and management action specific to prescribed fire are identified under the Proposed Action for fire management (Section 2.5.17). The Hollister 

Fire Management Plan (FMP) identifies high priority wildfire risk areas (e.g., wildland-urban interface, critical habitats and cultural areas) and the 

communities at risk within each FMU. (These lists may change as communities are removed or added each year). BLM would work 

collaboratively with appropriate Federal and State agencies, the San Benito Fire Safe Council, and other local partners to develop cross boundary 

fire management strategies, plans for risk reduction. and implement prescribed fire and fuels management projects across agency boundaries 

where this interaction would improve the overall success of the project. Management actions for prescribed fire and mechanical treatment 

activities on BLM-administered lands in the CCMA under the Proposed Action are summarized in Tables 2.5-6, 2.5-7 and 2.5-8. 

Comment: Potential Effects for San Benito County Recommendation 

Transportation: 

#1. The document focuses on closure of public right of ways to mitigate asbestos issues. The County is concerned with 

reverse condemnation issues and the potential devaluation of privately-owned property. There is no discussion of proposed 

alternative routes or analysis of condemnation to mitigate the devaluation issue. 

#2. Many of the alternatives within the EIS show the closure of Clear Creek Road. The document does not address new or 

increased use of New Idria Road that could result from this closure. New Idria Road is currently not maintained, and is 

posted as such. There is no analysis of the level of effort required to bring that road to a usable condition or the potential 

associated health risks associated with traversing the old New Idria mine property. There do not seem to be any data, such as 

a traffic study, that would indicate what impacts existing residents on New Idria Road would experience. 

#3. In addition to New Idria Road, the document should also address impacts to other roads in San Benito County that will 

see an increase in traffic due to the Clear Creek closure. Special attention should be paid to Cienega Road, as it is the access 

road for the Hollister Hills State Vehicular Recreation Area. 

#4. There are statements that indicate that roads should be closed to lessen the impacts on storm runoff and vegetation. The 

construction of new routes identifies the impacts as minimal. 

This is a discrepancy that needs to be addressed. Where are the new routes and why are those impacts minimal? 

#5. There is discussion of acquiring land as it becomes available to mitigate health risks, yet no discussion of condemnation 

or eminent domain of private or public (County-owned) land. 

This item needs to be addressed. 

#6. There are provisions for limiting access based upon rainfall totals. When the seasonal rainfall total reaches eight inches, a 

series of measures designed to control and maintain runoff go into effect. This proposed policy is flawed. A severe storm 

could bring substantial rainfall early in the year and the control measures would be unavailable. Conversely, if rainfall is 

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spaced throughout the season and eight inches are achieved in March, there may be no reason to enact these measures. An 

alternate strategy would be to base mitigation measures on individual storms or a much smaller ‘rolling’ window of time 

(e.g., measures could kick in when two inches of rainfall are exceeded in two weeks). 

#7. Alternatives B and C propose to extend the dry season use restriction period for roads from April 15 to December 1 and 

to enforce wet season closures when eight inches of precipitation has been reached (additional rainfall exceeding half an inch 

with a 24-hour period or one inch within a 72-hour period would result in a three-day closure). The reasons for wet season 

closure could be expanded. 

#8. Page 87 mentions designating the Cantua, Condon, and Tucker Mountain Zones as “limited” vehicle use areas under 

Alternative E, with only full-sized vehicles and ATV/UTVs allowed on designated routes. The map for Alternative E does 

not show any designated routes for the Tucker Zone. A “potential public route” is shown in the Cantua Zone, but it is not 

clear from the map legend what type(s) of vehicles will be allowed to use this route. 

BLM Response: 

#1. Refer to Common Response Section 3A. Section 2.4.3 of the CCMA Draft RMP and EIS and the Prospoed RMP and FEIS describe BLM’s 

proposed routes under each alternative. Analysis of private property condemnation and devaluation is outside the scope of the CCMA RMP/EIS. 

#2 & #3. The Draft RMP and EIS and the Proposed RMP and Final EIS both address the impacts of transportation and travel management actions 

from the range of alternatives and the BLM’s “preferred alternative” in Chapter 4, Seciton 4.3. Alternatives E, F, and G include proposals to 

decommission or vacate Clear Creek Road. The analysis of impacts to other roads in the Planning Area that could result from these alternatives is 

described in Secitons 4.3.8, 4.3.9, and 4.3.10, respectively. 

BLM's Proposed Action (Section 2.5.3) would allow for continued public access on Clear Creek Road (R1) for most popular uses, except OHV 

recreation, due to the human health risk identified in Chapter 4 and the EPA Asbestos Exposure and Human Health Risk Assessment (2008). 

Section 4.3.11 says the impacts to the transportation network in the Planning Area would be minor because the designated route network would 

maintain access for highway-licensed vehicles on all the existing major roads that provide public access to BLM-administered land in CCMA. 

#4. Refer to Section, 4.8.10.2 (Soil Disturbance by Travel and Transportation Management). 

During the mid-90’s, BLM funded research and field studies on the roads and trails network in the CCMA for two major watershed and 

geomorphic studies to evaluate road related erosion and sediment problems for over 100 miles of roads and trails in the CCMA and to determine 

which barrens are at most risk due to accelerated erosion which delivers increased sediment to surface water. 

The 1998 Pacific Watershed Associates (PWA) report identified the portion of the CCMA route network having erosion and sediment problems 

and also recommended specific engineered treatments at selected problem locations. This report further characterized that 40% of the accelerated 

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erosion was related due to poor road design and lack of maintenance and recommended that 9 miles of major roads be re-shaped to reduce 

sediment from entering into Clear Creek and other surface water. 

Under the Proposed Action, reclamation or restoration of closed roads in the Serpentine ACEC on routes with stream crossings, or other areas with 

high potential for sedimentation of waterways would have the potential to create moderate to major long-term beneficial impacts to water 

resources through decreased soil erosion, vehicle-related contaminant introduction to water bodies, and enhanced watershed functions. 

As described in Section 4.3.2, closure of redundant routes can result in beneficial impacts on water and biological resources and visual quality; 

however, the potential added burden on the remaining open routes may result in negative impacts such as soil erosion or compaction, loss of 

vegetative cover, or traffic congestion on the remaining route network. The development and construction of new routes and the abandonment and 

restoration of existing routes would also have minor negative, indirect impacts on private property owners and other existing rights-holders that 

would be required to obtain rights-of-ways to travel across BLM public lands on authorized on specific routes. Similarly, changes in the level and 

types of traffic on roads accessing CCMA could result in minor negative, indirect impacts on local and State governments that manage the road 

system if additional maintenance or patrol becomes necessary. 

#5. Eminent domain is not an issue or concern that was identified during scoping. BLM considers eminent domain to be beyond the scope of the 

CCMA RMP because it is not reasonably foreseeable. Under the range of alternatives and the Proposed Action, BLM would cooperate with valid 

exisitng rights holders, including private property owners, to provide access to non-federal lands in the CCMA and consider land tenure 

adjustments from willing sellers. 

#6 & #7. During periods of extreme wet weather, sustained vehicle use may compromise the integrity of the road surface and public land 

resources as a result of rutting of roads and trails and sediment transfer. Under current management (No Action Alternative) BLM restricts vehicle 

access after the seasonal rainfall total reaches eight inches and 1 - 2” of rain falls within a 24-72 hour period. This is an implementation-level 

decision that is based on the need to ensure public safety and reduce impacts to roads and resources during extreme weather conditions. 

Dry season use restrictions were also considered among the range of alternatives to mitigate human health risks. However, EPA determined that 

wet weather reduces but does not eliminate exposure, and there are still unacceptable risks associated with vehicle use during the “OHV use 

period” that would be authorized under Alternative B and C. 

Therefore, under the BLM’s Proposed Action, the Hollsiter Field Office would develop a more flexible strategy (i.e. through adaptive 

management) to determine when it is necessary to restrict vehicle use during periods of extreme dry and wet weather in areas where vehicle use 

may compromise the integrity of the road surface and/or public safety. 

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#8. Under Alternative E and the BLM Proposed Action (TRANS-E3 & TRANS-E4), BLM would designate the Tucker, Condon, Cantua, and San 

Benito River Zones as “Limited” vehicle use areas and prepare Travel Management Plans to designate routes of travel. Vehicle use in the Tucker, 

Condon, Cantua, and San Benito River Zones would be limited to highway licensed vehicles and ATV/UTV use only on designated routes 

(including potential routes and route construction proposals) identified on the Proposed Action Map in Appendix I. 

Within 5 years of the Record of Decision for the CCMA RMP, BLM will prepare a Travel Management Plan to designate approximately 30 miles 

of routes and trails in the Tucker and Cantua Zones that would be developed and maintained to support non-motorized recreation opportunities 

using the route designation methodology described in Appendix II and 43 CFR 8342.1 minimization criteria. 

Comment: Potential Effects for San Benito County Recommendation 

Biological Resources: 

 ̈ The management of biological resources discussion includes control of non-native wildlife species (pages 51 and 89). 

Further specification of what control measures will be used is needed. 

-noneBLM Response: There are no actions planned to control non-native wildlife species in the CCMA. Specification of control measures would be 

provided to the appropriate agencies in the event control on non-native wildlife species is needed. 

Comment: Potential Effects for San Benito County Recommendation 

Recreation: 

 ̈ San Benito County is very concerned that restrictions on motorized vehicle recreation within the CCMA will adversely 

affect recreation opportunities and related businesses within the County and the region as a whole. Additionally, the RMP 

does not appear to contain a discussion about how restrictions in the CCMA will impact Hollister Hills State Vehicular 

Recreation Area in the long-term, though mention is made that increased wear and tear on Hollister Hills may encourage 

some people to seek out OHV opportunities in other locations, legal or not. 

 ̈ Page 85 mentions improved recreation opportunities in the Cantua, Condon, and Tucker Mountain Zones under Alternative 

E. More specific information about these opportunities would be useful in analyzing their impacts. The alternative maps do 

not elaborate about the specific location, type, or size of these facilities. Is the “potential public route” in the Cantua Zone 

related to these proposed recreation opportunities? 

-noneBLM Response: Please refer to BLM Common Response Section 4B, 4C, and 4D. 

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Comment: Potential Effects for San Benito County Recommendation 

General: 

 ̈ BLM has utilized a preferred project alternative with a menu approach to responding to the issues before them. Under 

Section 15126.6(d) of the California Environmental Quality Act (CEQA), an Environmental Impact Report (EIR) would 

typically present environmental impacts of the proposal and alternatives in a comparative form, allowing for meaningful 

evaluation, analysis, and comparison. While an EIS prepared by a Federal Agency is not required to follow CEQA 

guidelines, the Preferred Alternative does not include all actions that would take place from the menu approach. This 

alternative could be further clarified. 

 ̈ The Superfund Atlas Operable Unit and Coalinga Operable Unit are delineated on all of the alternative maps except for 

Alternative E. Was this an oversight? 

 ̈ Since the temporary closure of the CCMA, significant revenue has been and will continue to be lost adversely affecting 

local and regional businesses due to the closure. Due to the temporary closure of Clear Creek, the Hollister Hills OHVA is 

full by 10:00 a.m., and frequently has to turn people away, further hurting the economy of the area, and forcing people to go 

further away for OHV activity. More analysis should be provided on this important issue, as area businesses and the County 

are very concerned. 

 ̈ Resource damage is occurring due to the temporary closure, both within Hollister Hills, as well as the general area. 

 ̈ More independent research and peer review needs to be done regarding the specific health risks of the asbestos, and more 

research needs to be conducted on the difference between asbestos and chrysotile, as the latter appears common to many 

counties in California and appears to be more benign. The EPA study needs to be peer reviewed prior to adoption of any 

permanent closure. 

-noneBLM Response: Table 2.6 of the PRMP/FEIS presenta summary of environmental impacts from the range of alternatives to allow for a 

meaningful evaluation, analysis, and comparison to inform the public and decision-makers. 

The Superfund sites should have been included on the Alt. E map in the Draft RMP/EIS.The Superfund Atlas Operable Unit and Coalinga 

Operable Unit are delineated on all of the alternative maps in the PRMP/FEIS. 

Please refer to BLM Common Response Section 1A and 1B. 

AG-CAOHVC: California State Off-Highway Motor Vehicle Recreation Commission 

Comment: Recommendation 

The Commission understands and recognizes the BLM is facing many challenges and is under significant On behalf of the California Off262
 
 

 

 

 

 

 

 

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pressure to meet project deadlines throughout the state. However, the CCMA is currently closed and therefore Highway Motor Vehicle 

poses no health risk to the public at this time. In view of this, it is the belief of the Commission that an action as Recreation Commission 

significant and far-reaching as permanently closing the CCMA to OHV use requires thoughtful consideration (Commission), I respectfully 

by all interested parties. Therefore, given the amount of time required by the BLM to prepare the in-depth Draft request an extension of the 

RMP/EIS, it is only fair the public be given further consideration, and for that reason, sufficient time to review public comment period for the 

these large and complex documents. Clear Creek Management Area 

(CCMA) Draft Resource 

The decisions generated by this Draft RMP/EIS will have far-reaching impacts and are important to the entire Management Plan (RMP) and 

California OHV community. To this end, the constituents of the Commission and the BLM should be afforded Draft Environmental Impact 

the necessary time to provide thoughtful comments. Thank you for your consideration. Statement (EIS). 

BLM Response: The public comment period was extended for an additional 45 days. 

AG-CANAHC: California Native American Heritage Commission 

Comment: Recommendation 

The Native American Heritage Commission (NAHC), the State of 

California Trustee Agency for the protection and preservation of Native 

American cultural resources (c.f. CA Public Resources Code §21070; 

also of. Environmental Protection Information Center v. Johnson (1985) 

170 Cal App. 3’’ 604), was able to perform a record search of its Sacred 

Lands File (SLF) for the affected project area (APE) requested. 

The NAHC SLF search did not indicate the presence of Native 

American cultural resources within one-half - mile radius of the 

proposed project (APE). There are, however, Native American cultural 

resources in close proximity to the APE. 

Enclosed are the names of the nearest tribes and interested Native 

American individuals that the NAHC recommends as ‘consulting 

parties,’ for this purpose, that may have knowledge of the religious and 

cultural significance of the historic properties in the project area (e.g. 

APE). We recommend that you contact persons on the attached list of 

Native American contacts. 

Consultation with tribes and interested Native American consulting 

parties, on the NAHC list should be conducted in compliance with the 

requirements of federal NEPA (42 U.S.C. 4321-43351) and Section 106 

and 4(f) of federal NHPA (16 U.S.C. 470 [f)]et seq), 36 CFR Part 

800.3, the President’s Council on Environmental Quality (CSQ: 42 

U.SC. 4371 at seq) and NAGPRA (25 U.S.C. 3001-3013), as 

appropriate.. 

BLM Response: Thank you. 

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AG-WRCD: Westside Resource Conservation District
 

Comment: General Recommendation 

The death and destruction caused by the 1995 Arroyo Pasajero flood was due largely because of the abnormally high 

sediment load in-stream at the time of the flood. Since 1996 the Westside Resource Conservation District has supported the 

efforts of the Stewards of the Arroyo Pasajero to stabilize soils in the upper watersheds of Clear Creek and Los Gatos 

Creek. Livestock ranchers have developed ranch plans that include distributing water to areas far from streams to minimize 

the trampling of stream banks, which causes soil erosion. 

The soils in the upper Los Gatos Canyon watershed are extremely erodible. The construction and use of new dirt roads in 

the upper Los Gatos Canyon watershed would cause a huge increase in soil erosion and sediment loads in Los Gatos Creek. 

This is precisely the environmental degradation the Stewards of the Arroyo Pasajero have sought to reduce. Any activity 

that increases soil erosion and sediment loads in Los Gatos Creek categorically contradicts long standing Westside Resource 

Conservation District policy of stabilizing upper watershed soils in the Arroyo Pasajero catchment basin. 

The Westside Resource Conservation District has also supported the closure of the Hazardous Asbestos Area for public 

health reasons. Any new or renewed off-road vehicle activity in that area will cause human respiratory illness and is 

opposed by the Westside RCD. 

The Westside Resource Conservation District also opposes a shift away from grass-fed beef production to accommodate 

recreational uses of Bureau of Land Management properties in the upper Clear Creek watershed. Range fed beef is the low 

carbon sector of our domestic beef production in the United States. Replacing natural forage-based meat production with 

carbon-intensive ORV activity denies the reality of the carbon restricted economy of the twenty-first century. 

For the above reasons, the Westside Resource Conservation District opposes any new or renewed use of off-road vehicles in 

the Clear Creek Management Area. Of the seven alternatives set out in the Clear Creek Management Area Draft Resource 

Management Plan and Draft Environmental Impact Statement, Alternative G comes the closest to restricting ORV use 

sufficiently. Any off-road vehicle activity would cause increased sediment in area streams and larger flood flows than if 

ORV use were banned altogether. The Westside Resource Conservation District supports the complete closure of the Clear 

Creek Management Area to off-road vehicle use. 

-noneBLM Response: Soils of the CCMA are introduced and described in the CCMA RMP Chapter 3.8 (includes Soils Map 5) and analyzed in Chapter 

4.8. Table 3.8-1 and Map 5 identify soil series of the CCMA and factors important to soil erosion including slope, permeability, surface run-off 

class, and erosion hazard. 

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Soils within the Serpentine ACEC of the extreme uppermost reaches of White Creek within the Los Gatos Canyon watershed are primarily of the 

following series: Atravesada-Pits; Atravesada-Pits, asbestos complex; Hentine-Franciscan rock outcrop complex; and Dumps-Pits, complex, 

asbestos. There are extensive natural serpentine barrens and disturbances associated with asbestos exploration and mining (Atlas Mine). Erosion 

hazard is generally moderate to severe due to steep slopes and poor vegetative cover on the natural serpentine barrens and asbestos exploration 

disturbances. This results in very high sediment and debris (cobble – boulder-sized rocks) loads within White Creek, much of which is due to high 

background sediment levels from the natural barren areas. 

Nonserpentine soils outside of the Serpentine ACEC, but within the CCMA, include the following series: Roacha-Millsholm-Lilten association; 

Lilten-Millsholm association; Millsholm-Borreguero complex; Anela-Vernalis association; Millsholm-Wisflat-Lilten association; Lilten-GrazerArburua association; and Rock outcrop-Borreguero complex. Erosion hazard is generally moderate to severe due to steep slopes. 

Construction of any new routes within the CCMA would take soil erodibility into account, resulting in avoidance of soils having high erosion 

hazard and incorporating erosion control measures into route design. By taking these measures, soil erosion within- and sediment loads to the Los 

Gatos Creek watershed can be reduced. 

AG-SJVRCD: San Joaquin Valley Resource Conservation and Development Council 

Comment: General Recommendation 

The San Joaquin Valley Resource Conservation and Development Council promotes the wise use of natural resources 

throughout the seven county area from Stanislaus County to Kern County. We support conservation practices that prevent 

soil erosion, minimize sediment loads in streams and rivers, keep our air clean, and foster low carbon food production. The 

Bureau of Land Management proposals that would increase off-road vehicle use in the Coastal Range of western Fresno 

County would increase soil erosion, flood damage, air pollution, and the carbon footprint of local meat production. 

Given the fragility of the soils in the upper Los Gatos Canyon watershed, the construction and use of new dirt roads in the 

upper Los Gatos Canyon watershed would cause a huge increase in soil erosion and sediment loads in Los Gatos Creek. 

You may recall that it was Los Gatos Creek along with the other streams of Arroyo Pasajero that tore out the bridge on 

Interstate 5 in 1995, resulting in five deaths. This is precisely the kind of environmental degradation and public safety 

hazard our Council seeks to prevent. 

With regard to air quality, the dust stirred by off-road vehicles, the fine particulate matter emitted by their engines and the 

emissions of oxides of nitrogen from their engines are all harmful to human health. One in six 

school children in the San Joaquin Valley has asthma exacerbated by bad air quality. Bad air quality in the San Joaquin 

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Valley also shortens the lives of 1,200 elderly people annually. To knowingly increase fugitive dust, PM 2.5 engine 

emissions, and oxides of nitrogen by establishing new ORV roads and campground facilities for new and renewed off-road 

vehicle use in the Coastal Range amounts to a willful disregard of the resulting respiratory illness among our most 

vulnerable Valley residents. 

BLM Response: See response to comments from Westside RCD above. 

Table X-2 (cont.) Comments from Organizations and BLM’s Response 

ORG-AMA36: American Motorcycle Association, District 36 

Comment: Organized Events Recommendation 

As your office is well aware, many of our bay area members and indeed thousands of our riders and clubs throughout 

northern California have used this unique facility for decades. In fact the Salinas Ramblers regularly hosted what was the 

longest running nationally sanctioned enduro at the CCMA for many years. Additional events at the CCMA hosted by other 

clubs and groups have a long-standing history and would be a huge loss to the surrounding area both socially and 

economically. 

-noneBLM Response: Section 3.1.4.1 of the Draft RMP/EIS acknowledges the long history of organized events in CCMA, and Section 4.1.4.1 states 

“the restrictions on [special recreation permits] for organized events in the ACEC would have major long-term negative impacts on OHV clubs 

and groups that have historically held competitive motorcycle races, jeep tours, and other events; as well as any other organizations or clubs that 

promote group activities in the Serpentine ACEC because of the lost opportunity for fundraising and events sanctioned by the American 

Motorcycle Association.” 

Comment: Social and Economic Impacts Recommendation 

The financial repercussions from the current closure at the CCMA have been felt throughout the surrounding 

communities. Aside from the local motorcycle shops, numerous other local business owners, many of whom may have 

no personal interest in motorized recreation, expressed concerns with the effects they have experienced first hand. 

Loss of revenue to local stores, hotels, gas stations and the carry-over effect created in these communities cannot be 

overstated. Likewise loss of income from ongoing projects at the CCMA, and the job losses directly and indirectly 

associated with them can only further compound the effects of this closure. 

We further request that 

BLM formally announce 

its intent to re-initiate 

scoping, which must 

involve all affected 

organizations, private 

property owners and 

individuals. This should 

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A full review and documentation of the economic impact this closure corresponds to must be undertaken. The fact that include a thorough 

the BLM only saw fit to reach out directly to the business community less than 2 weeks ahead of the comment analysis of an alternative 

deadline was a serious oversight on the agencies part. These proprietors need time to fully articulate and document the that will both maximize 

financial effects they have experienced during the current interim closure. Equally important, this data will fully resource protection and 

illustrate the future monetary impacts of a permanent closure of the CCMA would have on local businesses. recreational 

opportunities in the 

It is our contention that The DEIS is fatally flawed because it did not properly analyze the socioeconomic impacts to Clear Creek 

local and regional businesses including restaurants, motorcycle shops, hotels, sporting goods stores, gas stations, and Management Area. 

grocery stores. This important omission must be addressed prior to a record of decisions being issued. 

BLM Response: The CCMA Draft RMP/EIS and the Proposed RMP and Final EIS present the baseline for current social and economic 

conditions in Section 3.15. In particular, Section 3.15.4.4 describes the contributions of recreation opportunities to social and economic conditions 

within the Planning Area, specifically noting that “data shows that travel and recreation in San Benito County generate some $78,300,000 in 

spending in the county, $25,300,000 in earnings, and 940 jobs in the county (directly and indirectly). This amount ranks San Benito number 47 of 

58 counties with revenues generated and number 52 of 58 counties with jobs created from travel and recreation tourism (Dean Runyan Associates, 

Inc. 2009).” Additionally, the CCMA Draft RMP/EIS states “much of the economic benefit for income and employment, from people’s 

expenditures for motorized recreation, appears closer to the urban homes in the visitor-shed, than in the communities near the CCMA. Other 

factors that influence economic conditions are associated with restaurants, lodging, and gas stations where visitors spend money traveling to and 

from the CCMA. Purchases of vehicles for recreation use are prime examples of big-ticket expenditures that occur at considerable distances from 

the CCMA, although several notable retail motorcycle and OHV businesses are located in San Benito County.” 

Section 4.15 describes the socioeconomic impacts to local and regional businesses from CCMA land use decisions unde the range of alternatives 

and the Proposed Action. More specifically, Section 4.15.2.4 provides an overview of impacts from recreation and transportation management 

actions. Based on likely increases in visitor use levels as the population increases and “competition for recreation space accelerates”, BLM 

determined that “annual expenditures in support of recreation on public lands in the CCMA might reach as much as $4 million in current dollars.” 

During the social and economic workshop to discuss effects to social and economic values, participants insisted that BLM overlooked the financial 

repercussions of CCMA land use decisions on other local businesses, many of whom may have no personal interest in motorized recreation, still 

experienced loss of revenue. 

Based on these public comments, the following statement has been added to Section 4.15.2.4 of the CCMA PRMP/FEIS: 

Aside from the local motorcycle shops, recreation opportunities in the CCMA also contribute revenue to other local and regional businesses 

including restaurants, hotels, sporting goods stores, gas stations, and grocery stores in these communities. Likewise, income from ongoing 

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projects at the CCMA, and the job directly and indirectly associated with them provide benefits to social and economic conditions in the Planning 

Area. 

Comment: Range of Alternatives Recommendation 

On numerous occasions the BLM staff has repeatedly and publically encouraged riders to Creation of a viable, challenging and long term 

request a major modification to or the creation of an entirely new trail system at the CCMA. It sustainable trail system at the CCMA has long 

is well know that the Salinas Ramblers Motorcycle Club worked hard to formulate their draft been the goal of many in the riding community. 

alternative, incorporating their preferred management alternative. They did this both to assist Access to privately held lands, opportunities for 

the agency and better convey their desired management strategy in a comprehensive manner. other motorized recreationists as well as 

protection of the resources are all part of a well 

Serious consideration must be given to this proposal as it represents a good balance between developed and managed facility, and something 

protection of both specific areas and recreationists and providing sufficient recreational the public has repeatedly requested and 

opportunities for the future. The BLM would indeed find wide spread support for this idea, demonstrated a willingness to support. 

however given that a “citizens prorecreation alternative” has in fact been previously submitted Indeed direct financial support (day use permits, 

and rejected (during the 2007 DEIS process) it is difficult to again request the recreation annual passes and OHV grants) as well as 

community put much effort into developing yet another alternative. Instead we request the staff volunteer efforts (such as fencing of threatened 

revisit and reconsider the previously submitted documents (we can assist with providing and endangered species) had been ongoing until 

another copy if necessary). the emergency closure was 

implemented. The agency has a ready partner 

This “new trail system” idea, while encouraging, further illustrates the ongoing frustration felt but has simply not taken full advantage of the 

by many who have tried to work with the BLM previously. A re-route of those trails that the opportunity presented. As a result of this 

agency feels present the highest potential for exposure should have been included in this deficient process one or more viable, if not 

document. Literally years have gone by yet this idea is no more developed than it was the last superior, alternatives have been omitted from 

time the public was asked to be involved. the DEIS. 

BLM Response: Refer to Common Response Seciton 3A. 

Comment: Health and Safety Mitigation Measures Recommendation 

In the current DEIS the BLM incorrectly asserts that OHV users would not be willing to use a wash rack at the agency’s 

new decontamination center located at the main entrance to the CCMA. In fact it is our contention that the vast majority of 

riders would jump at the chance to wash off their vehicles before leaving the area. If needed, a study should be done to 

analyze user compliance with a wash rack facility before assuming and incorporating the idea that it wouldn’t be utilized 

into any alternative. 

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Likewise if the plan for the newly constructed washout station had been fully presented to the public the BLM could have 

better utilized the facility as both a clean up station and welcome center for arriving visitors. The chance for agency staff to 

have a face to face conversation with riders and help explain any current issues facing the CCMA would only help the 

public to better comply with and understand agency management decisions and strategies. A valuable opportunity was lost 

when the decision to construct this expensive facility didn’t include a welcome center component. 

BLM Response: Inserted the following paragraphs into Section 4.2.4.1: 

“Public comments from representatives of the American Motorcycle Association District 36 (and other planning participants within the OHV 

community) contend that the vast majority of riders would jump at the chance to wash off their vehicles before leaving the area and recommend 

the newly constructed decontamination facility be utilized as both a cleanup station and welcome center for arriving visitors. This would provide 

the opportunity for visitor outreach and education to explain CCMA resources concerns and land use management issues. 

Although many CCMA visitors may be willing to use vehicle wash racks, it is not feasible to maintain the cost of operating a state-of-the-art 

decontamination facility to industrial hygiene standards for public use. Furthermore, the effectiveness of this mitigation measure is limited because 

only one vehicle can be decontaminated at a time and it is unclear whether there are water resources available for public use of the 

decontamination facility to support the visitor use levels under the range of alternatives.” 

Comment: EPA Risk Assessment Recommendation 

If the agency is serious about their desire to create a new system of routes one of the first issues it must address is the visitor 

use scenarios regarding time spent traveling on routes in the ACEC. The human risk analysis contains a number of flawed 

assumptions, such as stating the average speed dirt bikes travel on single-track trails is 15-20 mph. With the exception of a 

few national caliber riders few if any have ever maintained such speeds over any long time frame on single-track trails. 

The DEIS is also flawed because it ignored the recent scientific work in process at the EPA’s Office of Solid Waste and 

Emergency Response to create a new risk analysis methodology for chrysotile since there is a growing body of scientific 

opinion that chrysotile is not a significant public health risk. The BLM must analyze all currently available science before 

permanently closing CCMA to OHV recreation. 

The EPA’s sample collection script states: “The distance between riders varied depending on visibility, terrain, and safety 

considerations, with the ultimate objective to realistically simulate the behavior of recreational riders. The second and third 

trailing riders rode in the dust cloud of the lead rider, to the extent safe and practical.” Incredibly this narrative does not 

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match the BLM’s ongoing 20-year educational outreach that instructs riders to not ride in another rider’s dust cloud. Most, 

if not all, riders actually try to avoid riding in a dust cloud. 

The EPA Risk Assessment is also fatally flawed because a majority of the samples were collected during dry periods when 

Clear Creek was in fact closed to the public. Also over use of Clear Creek Road during sample collection presents a major 

flaw in the riding simulation as it does not accurately represent the trail based experience the vast majority of riders come to 

the CCMA for. The vast majority of rider would in fact avoid the road as it lacks the very challenge they are seeking. 

Safety concerns would in fact force riders to alter greatly their typical riding style (speed and distance between riders for 

example) when on the road due to potentially encountering larger vehicles. While it appears the sample includes a 30% road 

use average a more realists one would be less than 10% and as such could have had a major impact on sampling and test 

results observed. 

BLM Response: Refer to Common Response Section 1C. 

Comment: Cumulative Impacts Analysis Recommendation 

The Purpose and Need in the DEIS notes the; “Changes in social and economic conditions in San Benito If indeed a visitor health risk is 

County, the San Joaquin Valley, and the entire State of California have led to increased demand for use of identified by a new assessment or a 

public lands for recreation and energy production as well as an increased awareness and social value review of the EPA’s latest report, the 

placed on the cultural and natural resources in the Planning Area.” BLM should use signs and 

educational outreach as a way to 

Recent public testimony at both the Economic impact meeting and the OHMVR Commission meeting inform the public and allow them to 

illustrated that displaced CCMA OHV riders are now threatening to overcrowd other regional OHV areas make their own decisions rather than 

that include the Jawbone OHV Area, Hollister Hills, Prairie City and Carnegie. A Cumulative Effect closing this important OHV area on a 

analysis must be included in this planning process. permanent basis. Other state and 

federal agencies have utilized similar 

Visitor surveys have shown that 80% of the past visitors at the CCMA were in fact motorcyclists yet the methods to both inform the public and 

agency identified and historical use at CCMA. The preferred alternative should include a similar minimize liability and there is no 

motorcycle trail mileage to what was preferred alternative has no provisions for motorcycle recreation. reason to discount the value of such 

This would represent a total reversal of the current available before the emergency closure. efforts in this case. 

BLM Response: Refer to Common Response Section 4D and 4E. 

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ORG-ALAA: American Land Access Association
 

Comment: American Lands Access Association Proposal Recommendation 

As an American Lands Access Association Representative I am proposing the Bureau of Land Management 

Hollister Field Office follow other California BLM District’s proven procedures for dealing with public land 

use issues which are so complex and set up a Clear Creek Management Area Advisory Council Committee. 

This approach is working in other California BLM Districts and provides the Public, Elected Officials, 

Professional Consultants, Geologists, Ecologists, Botanists, Federal Grazing, National/Regional 

Environmental, Wildlife, Non-Renewable Resources, Renewable Resources, Transportation/Rights of Way, 

and Recreational interests opportunities to work with the Bureau of Land Management in Using, Sharing, and 

Appreciating the Clear Creek Management Area while complying with the National Environmental Policy Act 

(NEPA). This is a reasonable proposal which promotes an environmentally harmonious approach to providing 

respectful, compliant, and cooperative solutions to CCMA’s social, political, and environmental concerns. 

The American Lands Access 

Association (ALAA) respectfully 

requests an opportunity to be 

represented in a Hollister BLM 

Field Office CCMA Advisory 

Council to ensure the American 

Lands Access Association’s 

concerns are reasonably and 

appropriately addressed. 

BLM Response: BLM currently supports a Central California Resource Advisory Council (RAC), including an OHV sub-committee, which 

comprises a diverse group of representatives from various backgorounds (i.e. recreation, ranching, conservation, elected officials, etc.) that meet 

quarterly to address resource management issues and promote public participation in BLM decision-making processes. 

The Central California RAC consists of 12 members that advise BLM officials for the Hollister, Mother Lode, Bakersfield and Bishop field offices 

aimed at achieving a balanced outlook that the BLM needs for its mission, which is to manage the public lands for multiple uses. 

Individuals may nominate themselves or others to serve on an advisory council. Nominees, who must be residents of the state or states where the 

RAC has jurisdiction, will be judged on the basis of their training, education, and knowledge of the council’s geographical area. Nominees should 

also demonstrate a commitment to consensus building and collaborative decisionmaking. All nominations must be accompanied by letters of 

reference from any represented interests or organizations; a completed background information nomination form; and any other information that 

speaks to the nominee's qualifications. 

Nomination forms and additional information about the Central California RAC are available on the web at 

http://www.blm.gov/ca/st/en/info/rac/ccrac.html 

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ORG-BAM: Bay Area Mineralogists
 

Comment: General Recommendation 

Most rockhounds live some distance from CCMA and must drive 2 hours or more to 

get to the CCMA entrance. Carpooling is commonly practiced, and passenger loads of 

2-3 persons per vehicle are the norm for day trips. Arriving at or before dawn is 

generally not practical. Typically another hour(+/-) of low speed driving over the 

CCMA road system is required to reach a rockhounding destination, and typically trips 

are limited to one or, at most, two collecting destinations per trip. Trips may be 

planned for 1, 2 or in the case of long weekends, 3 days duration. Multi-day trips 

necessitate overnight camping, which usually involves sleeping inside one's vehicle; 

tents are rarely used. Because the known and probable rockhounding sites are widely 

dispersed within CCMA; the serpentine zone is not suitable for extended hiking; and 

most rockhounds are too old to endure extended hiking, rockhounds have always 

utilized the network of roads and jeep trails maintained by BLM to drive to within a 

few (i.e. less than 100) yards of their collecting destination. Steel hammers, chisels 

and pry bars are the usual equipment, and these tools militate against long treks from 

one's car. The preferred seasons for rockhounding are Spring and Fall when roads are 

clear, and temperatures are moderate. Arbitrarily selected closure dates frequently do 

not reflect these conditions. All rockhounds polled for this document indicated that 

their needs can be accommodated by 6 visits per year or less. 

The economic impact to the local economy for the Bay Area groups included in this 

proposal is probably $100-150 per vehicle per Clear Creek visit, that money being 

spent in Hollister and/or Tres Pinos for meals, gas and groceries. 

In the spirit of a "menu driven" approach to the 

Alternatives, we suggest that Alternative E (or 

whatever Alternative BLM adopts) can be modified 

to accommodate rockhounds by including the 

following features: 

a) Explicitly and formally designate 

rockhounding as an authorized recreational 

activity in CCMA 

b) Authorize up to 6 rockhound visits per 

year under permit 

c) No visit to exceed 3 days/2 nights 

d) Authorize rockhound access to the existing 

network of roads and jeep trails within 

CCMA, including the serpentine zone. 

e) Authorize up to two consecutive nights of 

overnight camping per visit adjacent to 

rockhounding sites. 

f) Authorize visits at any time of year that 

temperature and road conditions permit 

g) Rockhounds to use full size vehicles only 

and only on R- or T- designated roads 

BLM Response: Refer to Common Response Section 3D. 

Comment: Asbestos Exposure Recommendation 

Given the statistical padding and methodological uncertainties of the 2008 EPA Risk Assessment (the "EPA Study") it is 

our position that up to 6 visits per year can be accommodated for rockhounding activities without exceeding the CERCLA 

Acceptable Risk Limit. Noteworthy components of this position are as follows: 

Even accepting 

EPA's risk 

assessments (which 

in general, we do 

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a) Our greatest exposure to dust occurs during the drive in/drive out activities on the primary access roads, i.e., not), rockhounding 

R001 and R011. By authorizing overnight camping at the collecting sites, we can eliminate successive drive in accordance with 

in/drive out events related to a 2- or 3-day visit. We do not object to the imposition of speed limits or the posting the above proposals 

of minimum following distances. Due to road conditions, travel on the interior roads of the ACEC (i.e. roads other should keep 

than R001 and R011) is generally done at speeds significantly less than 10 mph, which generates very little dust. rockhound asbestos 

CONTINUED ACCESS TO THESE INTERIOR ROADS IS CRITICAL TO THE ROCKHOUNDING exposures within 

COMMUNITY. limits that are 

acceptable by 

b) Because we tend to be stationary in our on-site activities, it is our view that while actually recreating in CCMA, EPA/CERCLA 

we would generate less dust than hikers or hunters, which is to say, virtually none. standards. 

c) EPA explained that camping activities produced unexpectedly high asbestos readings because campers slept 

close to the ground, and the activities associated with setting up camp, cooking, socializing generated dust. 

Rockhounds generally do not camp in tents or on the ground as theorized by EPA, preferring to sleep in their 

vehicles. Moreover we tend to go to bed early and do not ordinarily stay up to socialize. Meals are simple; 

cookouts are not the norm. 

BLM Response: Refer to Common Response Section 1D and 4B. 

Comment: Explicit Authorization of Rockhounding Recommendation 

As often is the case in Federal land law, rockhounds' rights to access 

and collect are not explicitly addressed in the Draft. Rather it is 

necessary to infer from the various proposals and analyses in the Draft 

what rockhounds may do without violating the various restrictions. 

Moreover, rights implied but not explicitly granted can be more easily 

taken away at a later date. We believe that in view of the unique 

mineralogical values present in CCMA, the final RMP should explicitly 

authorize rockhounding in CCMA and make specific provisions related 

to that activity. 

The East Hernandez Landowners have made a proposal to provide 

BLM and the public with rights-of-way to the Tucker Zone if BLM 

designates the latter a "Wildlife Conservation and Wilderness Study 

Area". Although not explicitly stated in their February 20 proposal, it is 

the landowners' intent that rockhounding and fossicking should be 

permitted in this area. This was explicitly stated in the February 22 

meeting at San Juan Oaks. Subject to BLM's acceptance of this 

condition, the rockhounding community supports the landowners' 

Tucker Zone proposal 

BLM Response: Refer to Common Response Section 3D. 

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Allowable uses under the range of alternqatives for the CCMA Draft RMP and EIS (2009) and this PRMP/FEIS are identified in Table 2.4-1. 

Under the “Proposed Action” analyzed in this PRMP/FEIS, non-motorized recreation opportunities, including hobby gem and mineral collection
 

(i.e. rockhounding), would be considered an allowable use in the Serpentine ACEC and the Tucker management zone (ref. Table 2.5-1). 

Comment: Access Routes & Times Recommendation 

Collectible mineral species are usually found at the contact of two rock types, such as the basaltic serpentine Our proposal is that visits 

intrusion and the surrounding or enclosed Franciscan rocks of San Benito and Fresno Counties. Not should be permitted 6 per year 

surprisingly, therefore, collectible minerals in CCMA are almost exclusively found on the immediate perimeter with potential duration not to 

of the serpentine emplacement (the ACEC) and in the calc-silicate outcrops within the serpentine zone. These exceed 3 days per visit. This 

outcrops are scattered around the ACEC, some near the periphery but some also in the heart of the ACEC. scenario will accommodate 

Alternative E would restrict vehicles to R011 and permit only foot access to areas within hiking distance of even the most active members 

R011. This is not acceptable. of our fraternity. For the vast 

majority of rockhounds actual 

Most rockhounds accessing CCMA are over the age of 45, some over 70. For people in this age group usage will probably not exceed 

rockhounding offers an ideal means of obtaining light recreation in the out-of-doors. However, for this age 3 visits/6 days per year under 

group extended hiking in potentially extreme weather conditions on hilly terrain is not practical and is this proposal. 

potentially dangerous. Alternative E as currently proposed (traffic limited to R011) would so limit the access 

by Seniors to CCMA that it would effectively constitute age discrimination. Seasonal restrictions should be 

governed by the practical 

Historically the rockhounding community has been able to utilize the road and trail network maintained by realities of CCMA. In the 

BLM within the serpentine ACEC to gain access to collecting sites that could be reached only with a great deal summer it can become too hot 

of difficulty on foot. The ability to drive to close proximity of collecting sites has always been an important to collect, and in the winter it 

consideration in the popularity of CCMA. THIS IS CRITICAL. Any proposal intending seriously to meet may to too cold, too rainy or the 

the needs of rockhounds, mineralogists and geologists must provide for continued access to the unpaved roads too impassible. Access 

and collecting should be 

trails. Permits would be an acceptable means of securing such access. 

roads and trails network within the ACEC as well as for the continued maintenance of said roads and 

broadly permitted as the seasons 

dictate, including warm winter 

It is noteworthy that while mineral collectors are interested in the entire spectrum of mineral species in CCMA days or cool summer days. 

(including those at the Clear Creek Mine), lapidarists are interested primarily in CCMA's jade and "plasma Arbitrary date cut-offs may 

agate" which are only found at or in close proximity to the Clear Creek Mine. For purposes of accessing these needlessly limit collecting 

resources, some means of permitting limited access to R001 must be provided. opportunities. 

The Draft prominently proposes "surface hardening" and "dust suppression" treatments of the "designated route Dawn-to-dusk access limits and 

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network". If these measures are feasible and money is available for them, they would be welcome day-use-only restrictions would, 

improvements. However, treating R011 at the cost of prohibiting travel on the existing network of roads and in most cases, negatively and 

jeep trails is not a fair trade-off and would benefit environmentalist sightseers, whose destinations lie on or severely impact rockhounding 

within easy reach of R011, at the expense of rockhounds whose destinations do not lie on R011. activities, especially if 

combined with road access 

Preliminarily we would like to point out that the EPA Scenarios were constructed to simulate fiber exposures limitations (such as limitation to 

per visit, not per day. The Draft seems to have dropped that distinction, as use restrictions seem invariably to R011). From an asbestosbe stated in "days". This becomes an issue when evaluating the most expedient way to reconcile the practical avoidance perspective as well as 

needs of the activity with the restrictions that BLM deems necessary to promote health and environmental a practical one, rockhounds 

values, such as minimizing "drive in/drive out" exposure through overnight camping. need the ability to camp over 

and not have to leave at dusk. 

BLM Response: Refer to Chapter 2: Section 2.3.1, which describes major changes to the “preferred alternative”, which include “approximately 

21 additional miles of vehicle routes in the Serpentine ACEC have been added to the area designations for limited vehicle use under 

the Proposed Action that include major routes R1, R10, R13, R14, R15, and other minor routes including T103, T104, T151, T153, 

and T158.” 

Comment: Camping Recommendation 

The Draft is not very explicit about where and under what circumstances 

camping will be permitted. It seems to suggest that camping will only be 

permitted in the Jade Mill campground. That would seem to benefit only 

hunters, as the Jade Mill will not be accessible from the New Idria entrance 

and R001 would be closed. This is not practical for rockhounds. 

Most rockhounds drive 100 miles or so to access CCMA, so they 

are usually loathe to limit their visits to a single day trip. Twoday excursions are preferred, which necessitates camping at least 

one night, usually sleeping in the back of one's vehicle. 

Permission to stay over one night (two nights in the case of 3-day 

weekends) must be granted by BLM 

BLM Response: Refer to previous response regarding publc access and vehicle use on major roads in the Serpentine ACEC. As indicated on page 

35 of the CCMA Draft RMP and EIS (2009), recreation management action REC-USE-B1 would prohibit camping in the Serpentine ACEC, 

except for Jade Mill campground because this site has already been developed and overlays non-serpentine soils that reduce exposure to airborne 

asbestos emissions to acceptable levels. Under the “Proposed Action” analyzed in this PRMP/FEIS, non-motorized recreation opportunities, 

including overnight camping, would be an allowable use in all the non-ACEC management zones (ref. Table 2.5-1). 

Comment: Access Permits Recommendation 

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To the extent that BLM wishes to control access by means of permits, rockhounds should not, in general, find them -noneobjectionable per se. Administrative procedures should be implemented to make the permits easy to obtain, e.g., by mail. 

BLM Response: Under the proposed permit system, BLM would develop a process to make permits easy to obtain similar to other special 

recreation management areas administered by BLM. 

Comment: Collecting Sites Recommendation 

Beauty is in the eye of the beholder. Conservationists may see a scattered mine dump as an eyesore to be remediated and 

strewn with wildflowers. To mineralogists, these same dumps are virtual playgrounds, some with on-site antiques to be 

photographed or painted. Abandoned mines and mine dumps are rich mineral collecting sites where mining activities have 

utilized the mechanized tools of the industry to bring mineral specimen material from the depths of the mines and put it on 

the surface where it can be examined by mineralogists. The Clear Creek Mine, in particular, has been the source of many 

newly described mineral species which would have remained undiscoverd if not revealed by mining activities. In contrast, 

the reclaimed Aurora Mine property is now a mineralogical/rockhounding dead zone. While we recognize the possible need 

to prevent contamination of streams and groundwater by mine wastes, such remediation should be planned and executed with 

an eye to preserving access to these mineralogical resources to the maximum extent possible. Burying these valuable 

mineralogical resources would be a crime. The rockhounds' aesthetics are no less valid than those of the conservationists. 

Where naturally occurring contamination is the source of undesired stream runoff, remediation is unlikely to eliminate 

pollution in any event, and it is preferable to preserve the availability of collectible mineral species at such sites. 

-noneBLM Response: Refer to the energy and minerals discussions in Sections 3.12 and 4.12 of this PRMP/FEIS for an explanation of BLM’s 

abandoned mine lands program and the associated impacts to the enviropnment. 

Comment: Integrated Risk Information System (IRIS) Recommendation 

The formal basis for EPA's risk assessments at CCMA is EPA's so-called "IRIS" standard, which was developed in 1986. 

IRIS in turn was based on 14 epidemiological studies performed by researchers in the 1970's and 1980's. Generally these 

studies correlated, for persons who had been subjected over several decades to substantial occupational exposure to 

"asbestos" fibers, death records of respiratory disease with the length and extent of asbestos exposure. In these studies 

"asbestos" was presumed to mean one or more of six commercially used mineral species. Although a primary species was 

generally identified, none of these studies examined the specific mineral content of the asbestos in any detail. These studies 

relied for quantification of "asbestos" fiber counts in the workplace on PCM technology or, worse, subjective estimates of 

what had been present in the workplace decades before. The author of the IRIS study, Dr. Nicholson, was also the author of 

one of the anti-asbestos studies included. Thirteen of the 14 studies were anti-asbestosis studies, and Dr. Nicholson re-wrote 

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the 14th study to comply with his vision. The study calculated mean risk values for occupational exposure (now used by 

OSHA) and more conservative 95th %ile Upper Control Limit ("UCL") values (or some similarly padded number) for 

environmental exposure which have been used by EPA at CCMA and elsewhere. These UCL factors estimate a significantly 

higher risk of disease by a factor of between 2 and 20 than the OSHA number. The Nicholson study precipitated the public 

hysteria over asbestos in schools and public buildings which has since been determined to have been unwarranted. 

Since 1986 the IRIS standard has not been revised despite new studies relating to specific mineral species and their 

culpability in lung disease. Significantly, new studies have indicated that chrysotile (the most common asbestos type in 

CCMA) is relatively harmless in recreational exposure doses; that non-asbestos minerals have been implicated in lung 

diseases in Asia Minor that were previously attributed to asbestos; and that tremolite (previously regarded as a contaminant 

in commercial asbestos) was implicated in the highly publicized employee mesothelioma scare at Libby, Montana where it 

comprised a whopping 25% of the ore mined for "vermiculite" products. ATSDR subsequently determined that the Libby 

employees were contracting asbestosis, rather than mesothelioma. 

Therefore the situation facing EPA is that their formal IRIS standard is now suspect with respect to chrysotile, while 

evidence is pointing to the 5 asbestos minerals known as amphiboles as the more likely health hazards. The nature of the 

health hazard attributable to amphiboles, however, has not been quantified in any generally recognized study. In this 

situation EPA has continued to defend the IRIS standard while alleging, without government standards to support them, 

that the amphibole minerals are even more dangerous than the IRIS standard would imply. In the context of CCMA, EPA 

has therefore collected numbers to demonstrate that the overall fiber load presents a risk according to IRIS but has also 

analyzed amphibole fibers in an effort to demonstrate that even if chrysotile turns out to be less dangerous than previously 

thought, there is still a dangerous amphibole burden at CCMA. 

BLM Response: Refer to Common Response Section 1C. 

Comment: EPA Risk Assessment Methodology Recommendation 

The methodology of EPA's Clear Creek study is riddled with methodological problems which seem to have been contrived to 

assure the shutdown of CCMA. BLM's own toxicologist addressed some of these issues in his letter to Rick Cooper (Dr. 

Karl Ford, Feb 8, 2008), at the end of which Ford concluded that "a combination of some additional analyses...and continued 

monitoring and institutional controls governing where, when, how, and who can ride, may reduce risk into the [EPA defined] 

acceptable range...." Methodological issues with the EPA study, including those cited by Ford, include the following: 

1. The CCMA study specified vehicle runs in northern CCMA to determine asbestos dust levels associated with scenario­

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specific activities. All such runs were limited to Clear Creek Road between staging areas 1 and 4 and the trails immediately 

north and south of the road, including the Indian Hill and Alpine Mine areas. This area was known to be the historical center 

of mercury related industrial activity and concommitant pollution, and the geology of the Indian Hill area is known to 

contain amphibole minerals. Clear Creek Road itself is notoriously dusty. This area seems to have been selected to produce 

the worst possible dust readings in all of CCMA. Substantial tracts of CCMA land to the east, south and west of the survey 

area were not included in EPA's study. Trailing riders in the vehicle runs deliberately violated posted BLM rules about 

minimum trailing distances, intentionally riding in the dust plumes of the leading vehicles. 

2. No record was kept of the specific routes taken by each rider in the study, making it impossible to correlate dust readings 

with soil samples. 

3. Dust readings were correlated to rainfall records, but as Dr. Ford pointed out, they were not correlated to actual soil 

moisture readings which would have been more meaningful. The years in which the surveys were performed were 

particularly dry years and modest rainfall did not necessarily improve dust conditions, leading to higher dust/asbestos and 

amphibole readings. 

4. The EPA study claims that nearly 8% of the fibers detected on the survey runs were amphiboles. However, 3/8 of those 

detected amphiboles were identified as "other amphiboles" which means any of approximately 75 mineral species in the 

amphibole family, none of which has historically been identified as "asbestos". This 3% is therefore presumably harmless, 

and its inclusion in the "nearly 8%" number is highly deceptive. The number of "asbestos" amphibole species detected is in 

truth barely 5% of the total fibers, virtually all of which were identified as actinolite. As noted at item12 below, there have 

been no epidemiological studies of the effects of actinolite on humans, and therefore there is no scientific basis for 

calculating risk posed to humans by actinolite in any kind of activity. EPA's assumption of human health risk from actinolite 

is purely speculative at this time. 

5. The Nicholson IRIS study asserted that there is no threshold for adverse health effects due to asbestos, which is to say that 

any small amount could trigger negative health impacts. EPA has upheld this notion in its discussions relating to CCMA, 

especially with respect to amphibole minerals. Recent studies, however, have found that dose levels and the duration of time 

over which those doses accummulate are critical for even the most dangerous types of asbestos. In other words there is an 

exposure threshold under which health risks are not significant. EPA just doesn't have enough data to pinpoint those 

thresholds. 

6. The EPA study is a case study in how to use statistics to distort the truth. Some of these "statistical" devices include the 

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following: 

 The inclusion of "other" amphiboles in the "nearly 8%" amphibole calculation referred to above. 

 The omission of relatively asbestos-free lead rider data from from all scenario risk calculations. EPA 's rationale for 

this is that they are using "health protective" (i.e. worst case) assumptions. 

 "Health protective" rounding of calculations in the computation of risks in the various study scenarios. Multiple 

calculations are required for each scenario. They add up. 

	 Redundant use of the "95th percentile Upper Control Limit" ("UCL"). EPA has asserted that this is a standard 

statistical tool. Indeed it is if one desires to make extremely conservative estimates of risk. It should be understood 

that OSHA adopted from the IRIS study a mean or average risk value for workplace safety issues, whereas EPA 

adopted a more conservative, padded number. There is some question whether it was a 95th UCL or not, but it is 

greater than the mean number used by OSHA. Using this already padded number as its risk factor, EPA calculated 

scenario-specific risks for CCMA, again calculating the 95th UCL of those field calculations and asserting that these 

artificially elevated numbers should be compared to EPA's acceptable exposure limit. This device alone virtually 

guaranteed a failing grade for most of the activity scenarios in Clear Creek. 

Again, Dr. Ford said in his memo to Rick Cooper, "It is understood that EPA guidance has a preference for arithmetic means 

and 95% UCL, however, the limited information available to me suggests the data are probably log-normally distributed. If 

true, the arithmetic mean and 95% UCL may overestimate the true concentrations." Indeed. 

7. The EPA Study was planned specifically to take advantage of newly available Transmission Electron Microscopy 

("TEM") for the analysis of air samples. EPA's belief was that TEM is better able to identify individual mineral fibers and 

therefore counts made using TEM would be more accurate. The methoodological flaw in this thinking is that TEM will 

indeed produce a higher count on a given sample than PCM. However, the IRIS standards were derived by comparing health 

data with counts made using PCM. Using an analytical method that produces higher counts in conjunction with a PCMderived IRIS standard will necessarily imply a higher level of risk than if the count had been made with PCM. In the words 

of Dr. Karl Ford, "The IRIS cancer slope factor is probably based on PCM, so use of TEM may overestimate risk." 

8. EPA has routinely ignored and/or disparaged competent studies that have arrived at findings contrary to EPA's. EPA 

regularly asserts that such studies are biased or incredible because they are funded by industry and/or published in industry 

journals. (If industry doesn't fund these studies, who will?) In fact, many of these studies have been published in generally 

accepted forums such as the New England Journal of Medicine. A fair reading of these studies indicates that they are at 

least as well documented as any anti-asbestos study relied upon by EPA and in most cases more methodologically rigorous, 

precise and objective. In comparison, EPA itself acknowledges that the studies utilized in developing the IRIS model were 

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based on only rough estimates of asbestos exposure levels in industrial environments over many decades and on imperfect 

identification of asbestos species and causes of death. The non-EPA-sanctioned studies are entitled to objective and fair 

evaluation. 

9. Current science suggests that chrysotile asbestos is subject to breakdown and expulsion by the body's defense mechanisms 

and that chrystoile fiber load from intermittent recreational exposures is ordinarily cleared in a matter of several days. It 

therefore poses little or no risk of health issues at recreational levels. EPA's IRIS model is currently being revised, at least in 

part to incorporate this emerging consensus. 

10 Although the IRIS standard does not distinguish amphibole asbestos from chrysotile asbestos, EPA asserts that the former 

are even more dangerous than chrysotile and should be viewed with extreme caution. Currently the Best Available Evidence 

with respect to amphiboles is that 

a) asbestiform amphibole minerals are not susceptible to chemical breakdown in the body like chrysotile; 

b) at some level of exposure they can contribute to the likelihood of lung diseases, especially asbestosis; 

c) all humans acquire during their lifetimes some amount of amphibole fiber accumulation in their lungs, if only 

from ambient levels in urban environments, the vast majority without developing lung related diseases; 

d) the threshhold levels of amphibole fibers required to induce lung disease have not been established with any 

degree of reasonable certainty; 

e) EPA has offered "health protective" lifetime risk estimates that are greatly exaggerated by means of 

methodological biases and statistical padding; and 

f) Best Available Evidence suggests that although the health risks related to naturally occurring amphiboles are not 

zero, EPA has nevertheless grossly overestimated the risks, and this conclusion is supported by the absence of any 

epidemiological or anecdotal evidence of elevated lung health risks in real life among people who have lived, worked or 

recreated in CCMA. In other words, actual experience in CCMA does not bear out EPA's hypothetical risk calculations. 

11. EPA has repeatedly asserted that children are at special risk from amphibole-induced mesothelioma, but BLM's own 

toxicologist has pointed out a recent study (Reid, 2007) indicating that dose and duration of exposure are the critical factors, 

not age of the subject. 

12. Virtually all of the "amphibole" identified by EPA in CCMA was identified as actinolite. EPA (Den) asserts that 

actinolite is just as dangerous as tremolite based on its chemical similarity to tremolite. EPA toxicologists in North Carolina 

confirm that there have been NO epidemiological studies relating specifically to actinolite in humans to support this 

assumption. And as noted above there are no generally accepted risk characterizations for tremolite either. (Actinolite is a 

common mineral throughout California and no doubt comprises much of the ambient airborne asbestos in California's cities.) 

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BLM Response: Refer to Common Response Section 1B, 1C, and 1D. 

Comment: Procedural Compliance Issues (NEPA, FLPMA) Recommendation 

1. The Draft's planning objectives were stated in terms of generic boilerplate, never in concrete terms applicable 

specifically to the public uses of CCMA. This is a fundamental substantive breach of BLM's obligations under NEPA. 

This failure is one of the circumstances which leads many of CCMA's users to suspect a hidden agenda and a preordained 

outcome for this process. 

-none2. The EPA Study of CCMA was clearly designed and implemented to "prove" a pre-determined result. (See 

"Methodology" above.) It is not the best available evidence. Worse, both EPA and, apparently, BLM have failed to give a 

fair and impartial review of conflicting studies and evidence. 

3. Digesting and challenging the EPA study and the proposed RMP has been a daunting task to be performed in a 90-day 

period that included the Thanksgiving, Christmas and New Year holidays, not to mention Presidents Day, the Super Bowl, 

the Daytona 500 and the Tucson Gem & Mineral Show. The Draft itself is over 700 pages, and the effort required to seek 

out and digest the historical, legal and scientific issues related to the Draft is enormous. Dozens of people from multiple 

user communities have put in thousands of hours of effort to respond to the Draft. NEPA requires that our concerns be 

taken seriously. 

4. Many of the studies relied upon by EPA and BLM are not readily available to members of the public, especially studies 

published in professional journals. As you know, there have been a multitude of FOIA requests in an attempt to get 

background information. EPA declined to provide us a copy of the TEM standard procedure on the ground that it was the 

proprietary property of the ISO. There are many such hurdles. Much important information necessary to understanding 

the EPA Study and the administrative history of CCMA has been difficult or impossible to obtain. 

5. BLM's obligation to cooperating agencies under federal law is to give such agencies' inputs a fair and objective hearing, 

including concerns relating to human health and safety. However, it is a misreading of federal law to assert that BLM is 

somehow obligated to prohibit or limit use of CCMA on the grounds of air quality concerns while the ambient air in our 

home cities contains even more asbestos than CCMA air. It is not BLM's charter to assure a completely risk-free 

recreational environment in CCMA 

BLM Response: Refer to Common Response Section 2A. 

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ORG-BRC: BlueRibbon Coalition
 

Comment: Science Flaws Recommendation 

Science Issue 1: Failure to Include BRC Scientific Submissions into the DEIS 

BRC staff and consultants submitted numerous scientific citations (e.g. papers, articles, etc). in a timely manner during 

the scoping process. These documents brought into question the methodology, findings, and conclusions of the 2008 

EPA Risk Assessment. Yet, no discussion of said documents can be found in the DEIS. 

Science Issue 2: BLM’s Attempt to Ignore or Discredit Public Comment 

According to documents discovered through FOIA, BRC finds the BLM acted in a deliberate and non-transparent 

manner in an attempt to discredit and discount BRC science materials. 

Science Issue 3: BLM Does Reference Questions in the DEIS by its own Toxicologists Regarding the EPA’s Risk 

Assessment 

BLM’s Toxicology expert, Dr. Karl Ford, on more than one occasion called into question the science and/or 

methodology of the RA. This information should be acknowledged by BLM. In fact, the questions raised by Dr. Ford 

imply that possible mitigation measures could be included in (or form the basis of) alternatives omitted from the DEIS. 

Instead, BLM appears to advance an “err on the side of closure” premise and withholds information inconsistent with 

or contradictory to that premise. 

-noneBLM Response: Refer to Common Response Section 1C and 1D. 

Comment: Science Flaws (cont.) Recommendation 

Science Issue 4: The Risk Assessment is flawed because trailing riders rode in the dust cloud of the lead rider. 

Science Issue 5: The Risk Assessment is flawed because riders spent too much time on Clear Creek Road. 

Science Issue 6: The Risk Assessment sampling routes do not simulate a typical CCMA off-highway vehicle 

experience. 

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Science Issue 7: Un-supervised test riders may have ridden off the prescribed course. 

Science Issue 8: The EPA calculated health risks in the DEIS are inherently flawed because they are based on the 

original calculations in the original risk assessment. 

Science Issue 9: The test course included several historic mill sites where commercial asbestos (amphibole) was used. 

Science Issue 10: The sampling is not representative of typical use conditions because most riding at CCMA takes 

place in the winter. 

Science Issue 11: Modification of Test Protocol 

BLM Response(s): 

Science Issue 4: The sample collection was designed to capture typical exposures. Avoiding dust would reduce the exposure to trailing riders and 

the overall risk of asbestos-related disease.
 

Science Issue 5: With the exception of the SUV exposure sampling, riding was done primarily on trails selected with the input of BLM field 

rangers and CCMA motorcycle and ATV riders. Road riding was only from the staging areas to the trail access points, which would approximate 

the routes taken by CCMA users.
 

Science Issue 6: Refer to Common Responses Section 1C.
 

Science Issue 7: EPA riders followed the approximate courses for the sampling, considering individual variation for trail conditions. EPA believes
 

that the samples are representative of exposures from riding within CCMA. 

Science Issue 8: Refer to Common Responses Section 1D.
 

Science Issue 9: Refer to Common Responses Section 1B
 

Science Issue 10: Refer to Common Responses Section 1C.
 

Science Issue 11: This comment is addressed in the Risk Assessment in Section 4.1.5 on Page 4-6.
 

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Comment: AGENCY LIABILITY - New Agency Health Risk Paradigm Recommendation 

In BRC’s June 19, 2008 public scoping letter the following suggestions were articulated... “BRC HISTORIC OHV USE – 

believes BLM should consult with sister land management agencies (e.g. Forest Service, CA State 

Parks, etc.) regarding mitigation or alternative management strategies such as adding soil or road Adopt a True No Action Alternative 

treatments, public outreach and education, or how they handle similar low risk public health issues or if (NO RISK)— 

they even consider the findings in the EPA report as mandating a closure.” 

The agency would use this 

TORT ISSUE ONE: No Consultation with BLM or Sister Agencies programmatic document to replace the 

2005 EAJFONSI EA-CA-190-05­

BRC could not find a reference to any consultation in the DEIS regarding how the BLM addresses 21 that resulted in the now infamous 

similar health risk/public access issues in other areas or how sister agencies address such issues. summer or dry-season closure. This 

would allow historic OHV use on up to 

TORT ISSUE TWO: HFO Creates New Legal Paradigm 270 miles of routes and 478 acres of 

barrens/open play areas with no 

A review the Federal Tort Claims Act, 28 usc §2671-2680, shows that Congress has already addressed seasonal closures. Permitted OHV 

this issue regarding agency liability and public access. This act has created the “acted negligently” legal events would occur. 

high-bar that all plaintiffs must meet in any court action. This law indemnifies federal agents from civil 

or criminal action in cases where recreationists have fallen off a cliff while rock-climbing at a National DEIS NO ACTION ALTERNATIVE 

Park, drowning in a federally-managed lake or waterway, or running into livestock or wildlife while the (LOW RISK - No agency liability) – 

public is driving on a highway through lands managed by BLM or another federal agency, or allowing 

pregnant women or young children to fish for mercury-laden fish in a federal waterway. This would assume the EPA or 3 party 

does a review of the RA or preferably 

Historically federal and state agencies address the aforementioned and similar health hazards in a undertakes a more valid or realistic 

number of ways. One such tool is the use of signs warning of said dangers. [The DEIS excludes this study to assess a real health risk to the 

topic.] public. If some risk is identified, the 

BLM would use the liability protections 

The BLM risks creating a new and arbitrary “health risk paradigm” at CCMA that is unwarranted and afforded the agency by the Federal Tort 

in fact actually creates a liability for the agency at CCMA and other recreation sites (naturally occurring Claims Act and allow for OHV use on 

asbestos is in 43 counties in California) where none has historically existed. Again, Congress has up to 270 miles of routes and 478 acres 

indemnified the agency as long as the land manager informs the public (usually through signing of barrens/open play area. Permitted 

prescriptions and educational outreach) of the health or safety risks. OHV events would occur. 

TORT ISSUE THREE: HFO Becomes Health Agency and Assumes Agency Liability DEIS MODIFIED NO ACTION (LOW 

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RISK — 

The aforementioned liability discussion logically leads one to call into question the health related tenets Some Agency Liability) — 

of the Purpose and Need (DEIS pages 3/4). The BLM has illogically taken upon itself the role of a 

health agency and protector of public health rather than a land management agency with a multiple-use The agency would use some of the use 

mandate. This working postulate of the DEIS is flawed and unnecessarily puts the DEIS and the agency restrictions in Alt. B (wet weather 

in legal jeopardy if not amended. This nanny-state paradigm is described on page 352 of the DEIS closures, road/campsite 

where the HFO takes responsibility for something the agency traditionally and historically has wisely mitigations, signing, educational 

steered away from. This new approach risks creating new agency liability where none has existed. outreach, signed liability release forms) 

and allow for OHV use on up to 270 

TORT ISSUE FOUR: Failure to Analyze Cumulative Environmental Impact on Other Recreation Sites miles of routes and 478 acres of 

and Associated Health Risks barrens/open play areas. Permitted OHV 

events would occur. 

If the agency is now a health agency, BRC could not find an analysis or substantive discussion in the 

DEIS of any direct health risk to the OHV public by forcing displaced users (if any of the anti-OHV DEIS MODIFIED ALTERNATIVE B 

alternatives are adopted including the preferred alternative) by forcing them to travel longer distances (LOW/MODERATE RISK. Some 

to, and recreate at, at other destination OHV areas including, but not limited to, Jawbone, Hollister Hills Agency 

and Carnegie SVRAs, Metcalf Cycle Park. The cumulative effects mandate of any NEPA planning Liability) 

document requires at least some analysis of such an issue. A cursory review by BRC - based on public 

comments at the February 25, 2010 OHMVR Commission meeting — shows the BLM’s closure of 

CCMA (or potential closure in the ROD) is already having a negative impact at other OHV recreation The agency would use the use 

sites not to mention the potential for traffic injuries or fatalities caused by the increased driving restrictions in the BRC DEIS 

distances now being driven by traditional CCMA users. Yet, no such analysis is found in the DEIS. MODIFIED NO ACTION ALT, but 

prohibit riders under the age of 16 and 

shorten the riding season to the time 

period between December 1 and April 

15, annually. Permitted events would 

occur with age restrictions. 

BLM Response: ISSUES 1 – 3: Refer to Common Response Section 1C and 4E. 

Domestic and international health and scientific organizations, including the State of California, the EPA, the Centers for Disease Control, the 

National Toxicology Program, the National Institute for Occupational Safety and Health (NIOSH), the Occupational Safety and Health 

Administration (OSHA), the World Health Organization International Agency for Research on Cancer, and the International Program on Chemical 

Safety, have all classified chrysotile asbestos as a known human carcinogen. While there is some debate within the scientific community regarding 

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the varying potencies of the different types of asbestos relative to certain cancers, there is no debate that all types of asbestos cause cancer and 

debilitating and fatal non-cancer disease. 

San Benito County abandoned maintenance of CCMA roads in 1994 based specifically on human health risk associated with asbestos exposure. 

The initial decision to issue an emergency closure order and subsequent planning documents are intentionally designed to allow BLM and other 

local, state, and federal agencies to analyze a range of alternative management strategies that could be employed at the CCMA “to mitigate risk 

while still allowing vehicular access and public recreation opportunities”. 

Results of the numerous activity-based risk assessments in CCMA conducted by BLM, EPA, and OHVMRD are similar and demonstrate that 

there is an unusually high public health risk from NOA exposure in the 30,000-acre ACEC. BLM has been performing asbestos education and 

awareness in the CCMA for more than two decades. The range of alternatives in the CCMA Draft RMP/EIS consider a variety of management 

prescriptions such as signs and public outreach to educate the recreation public about human health risk associated with asbestos. In addition to 

these activities, BLM’s Proposed Plan for CCMA would limit the type and duration of public use that can occur in the ACEC, and would enhance 

opportunities for public use in the surrounding management zones within the CCMA. 

ISSUE 4: Chapter 4, Section 4.1.4 “Impacts to Recreation Common to Alternatives B, C, D, E, F and G; subsection 4.1.4.1 Impacts 

from Recreation Management Actions” on page 311 of the CCMA Draft RMP/EIS (2009) describes the indirect effects to the OHV public 

from displaced users recreating at other OHV areas 

Indirect impacts would increase as restrictions on allowable uses increase and recreation opportunities decrease across the range of alternatives 

from A - G, particularly within the Serpentine ACEC. These restrictions would displace thousands of recreationists, who would end up seeking 

OHV recreation opportunities in other County, State or Federal recreation areas. Most of these other areas are smaller than CCMA and additional 

visitors would contribute to overcrowded conditions and additional impacts to the human environment in those areas. Overcrowding can lead to 

increased conflicts among user groups, decreases in recreational quality and experience, and adverse impacts to other resources like vegetative 

cover, wildlife habitat, soil loss and erosion, and water and air quality. 

MSBT-LAW: Moore, Smith, Buxton, Turcke, Chartered 

Comment: Public Comment Period Recommendation 

We recognize the complexity and sensitivity of BLM’s task, and do not question the reasonableness of 

BLM’s multiple delays of the DEIS release, but only ask that BLM extend similar latitude to the public in 

responding to the DEIS. 

We ask BLM to extend the comment 

period. If the State of California is 

able to seek independent review of the 

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EPA’s or other technical conclusions 

Finally, BLM has apparently magnified any procedural gaffe by selectively and informally extending the supporting the DEIS we ask that such 

comment period for certain commenters. Specifically, we believe that BLM has advised the State of information be made available and 

California and San Benito County that they may have additional time in submitting formal comments to comment be extended or reopened for 

the DEIS. This result makes no sense and frustrates NEPA’s fundamental information purpose, for it at least thirty (30) days following such 

presents the possibility, if not likelihood, that some commenters will have a different and more developed release. 

record upon which to comment than others. 

BLM Response: Section 5.3 of the CCMA Proposed RMP and FEIS provides the following details about the public comment period for the 

CCMA Draft RMP and EIS. “BLM’s official public comment period began December 4, 2009, with the publication of the NOA in the Federal 

Register (Volume 74, Number 232). The comment period was extended to April 19, 2010 to allow further public input following requests from 

planning numerous participants and elected officials. While comments are accepted throughout the CCMA land use planning process, BLM only 

accepted written comments during the public coment period to ensure that issues presented in the CCMA Proposed RMP and Final EIS reflect the 

genuine concerns of the public. A majority of the public comments were submitted by email; although BLM received many written letters that 

reflect the interest of numerous agencies and constituents, including those who attended the public comment meetings.” 

Refer to Common Response Section 1F(iii) regarding California State Parks OHMVRD independent report analyzing naturally occurring asbestos 

exposures associated with OHV recreation and hiking at Clear Creek. 

Comment: Analysis of Technical Issues. Recommendation 

The DEIS is obviously premised on the most recent (2008) EPA Risk Assessment. BLM has committed 

procedural violations in disclosing the EPA methodology and results. 

The DEIS inadequately discloses the methodology and hard data of the Risk Assessment. These 

procedural defects condemn the DEIS technical analysis and conclusions. 

Further review should occur and any 

technical materials, including 

underlying data, should be made fully 

available for public review and 

comment 

BLM Response: The comment letter from MSBT notes, “When federal agencies evaluate technical issues or apply specialized expertise, NEPA 

requires them to rely on valid sources and to disclose methodology, present hard data, cite by footnote or other specific method to technical 

references, and otherwise disclose and document any bases for expert opinion. 40 C.F.R. § 1502.24; Idaho Sporting Congress v. Thomas, 137 F.3d 

1146, 1150 (9th Cir. 1998).” 

By the commenters own admission, it is clear that the BLM’s analysis of human health risk in the CCMA Draft RMP/EIS is based on the EPA 

Asbestos Exposure and Human Health Risk Assessment (2008). The EPA study is incorporated by reference into Chapter 1 under “Purpose and 

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Need for the CCMA RMP/EIS” and “Relationship to Other Policies, Plans, and Programs”. Chapter 3 of the Draft RMP/EIS describes the 

methodology for the activity-based sampling, and Chapter 4 presents the results of the EPA’s risk assessment. Chapter 6 also cites the EPA 

document in the bibliography. 

As such, the CCMA Draft RMP/EIS references to the information in the EPA’s CCMA Asbestos Exposure and Human Health Risk Assessment 

(2008) meet the standards set forth in 40 C.F.R. § 1502.24 because the information is reasonably available to the public; is understandable without 

undue cross reference; and meets a general standard of reasonableness. 

Comment: Technical Conclusions Recommendation 

EPA’s 2008 findings do not appear against a blank slate, but instead represent a one-time assessment to be compared to 

multiple other analyses conducted by EPA, BLM, private contractors, and other sources. To belabor the obvious, a finding of 

meaningful health risk would imply some individual or population level effects manifested through incidence of disease 

connected to the CCMA. Such connection has never been established and has been persuasively disproven on multiple 

occasions. 

The DEIS references a 1992 BLM Human Health Risk Assessment for CCMA, DEIS at 332, but there is no comparative 

analysis or explanation of that document against the 2008 EPA RA. 

We ask that a 

supplemental 

analysis be 

performed. 

BLM Response: Refer to Common Response Section 1D and 1F. 

Comment: Agency Liability Recommendation 

The DEIS reflects an institutional caution apparently focused on the fear of liability from any who might contract disease 

allegedly connected to recreation activity at the CCMA. Neither the general scenario nor level of risk is new. In fact, the 

epidemiological risk suggested by EPA’s analysis, though excessive, is still less than for many other sites or other causes 

associated with public lands recreation. 

There is a well-established body of statutory and common law to address such concerns. As a general principle, a 

government agency and its employees are well-shielded from potential liability by the discretionary function exception to the 

Federal Tort Claims Act. Generally stated, an injured party must show that the challenged governmental act or omission 

violated a mandatory regulation or policy allowing no judgment or choice, and that the governmental conduct was not of the 

type designed to be shielded by the discretionary function exception. 

The rare exceptions to the discretionary function exception seemingly arise when the agency, through an explicit policy or 

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admission, disclaim discretion otherwise inherent in managing human use of natural areas fraught with worst-case scenarios 

resulting in possible injury/death. 

The DEIS reflects a strategy that inexplicably flies in the face of these protections and could be framed as a BLM admission 

of an environmental risk that history suggests does not exist. 

We are primarily concerned in these supplemental comments with the issue of the Hollister Field Office’s approach to 

perceived liability issues and the choices made by the HFO to address them. ... Indeed, “decisions whether and how to make 

federal lands safe for visitors require making policy judgments protected by the discretionary function exception” to the 

Federal Tort Claims act. Rosebush v. United States, 119 F.3d F.3d 438, 443, 6th Cir. 1997). 

28 U.S.C. § 2680(a). If a case falls within this statutory exception, known as the discretionary function exception, the district 

court lacks subject matter jurisdiction. Feyers v. United States, 749 F.2d 1222, 1225 (6th Cir. 1984), cert. denied, 471 U.S. 

1125 (1985). The Supreme Court has articulated a two-part test to determine whether a particular claim falls within this 

exception. Uhited States v. Gaubert, 499 U.S. 315 (1991). The first query is whether the challenged act or omission violated 

a mandatory regulation or policy that allowed no judgment or choice. Id. at 322-23. If the challenged act or omission is 

deemed discretionary, the second prong examines whether the conduct is “of the kind that the discretionary function 

exception was designed to shield.” Id. In other words, the more specific the scheme, the less likely it may be that the 

discretionary function exception applies. So, for example, where agency guidelines did not mandate the specific manner in 

which campground fire pits would be managed for safety, the failure to warn the public about potential hazards related to fire 

pits did not constitute an act that gave the district court jurisdiction under the FTCA. Rosebush, 119 F.3d at 442. But here, in 

addition to establishing goals and objectives, the DEIS also establishes specific management actions that remove that 

protected discretion. DEIS at 4. There is no mandate to restrict use due to naturally occurring asbestos, but the DEIS 

undertakes specific mechanisms to do so. All the mitigation and other tools the BLM seeks to implement require specific, 

intense monitoring and enforcement, and this sets up the agency for liability questions. 

BLM Response: The CCMA Draft RMP and EIS describes the regulatory framework guiding federal agency responses to public health risks from 

exposure to chrysotile asbestos in Chapter 1 under “Relationship to Other Policies, Plans, and Programs – Comprehensive Environmental 

Response and Cleanup Liability Act (CERCLA)”. In light of this relationship, Chapter 3 describes the history of the Atlas Asbestos Mine 

Superfund Site and the 1991 Record of Decision that detailed a cleanup remedy for the site and the need for a risk assessment to evaluate the 

adequacy of the CCMA land use plan for overall protection of human health and the environment (Section 3.2.3.1). 

Comment: Cooperating Agency Status for State and Local Governments. Recommendation 

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In the public scoping report, the HFO states that it will “invite federal, state, and local agencies to participate in development -noneof the CCMA RMP/EIS to provide information and/or technical assistance in evaluating public land resources in the 

planning area,” and identifies several state and local governmental entities to be included. The DIES states that BLM enlisted 

one cooperating agency (EPA), and “numerous State and local governments, and the Central California Resource Advisory 

committee . . . .“ DEIS (letter to Reader). The DEIS later identifies as a planning criteria “government to government 

consultation, including Tribal interests,” and then states that “[t]he CCMA RMP/EIS will allow BLM the opportunity to 

review existing agreements and consider cooperative agreements with Federal, State, and local agencies to improve 

management of public land resources in the Planning Area.” DEIS at 14. The HFO, at Section 5.2.5 of the DEIS, describes 

its “existing agreements with several Federal State, and local agencies to assist in the management of public land resources in 

the Planning Area.” DEIS at 552. 

The “existing agreements,” and the level and nature of participation by the entities listed in that section, are not disclosed in 

the DEIS. Thus, the DEIS suggests that the HFO has declined to pursue cooperating agency status with respect to this DEIS, 

instead delaying formal consultation on this particular action to a later time, or, relying on existing agreements that do not 

identify the manner of those agencies’ participation. 

BLM Response: NEPA and its attendant CEQ regulations mandate that federal agencies, in preparing NEPA analyses and documentations “in 

cooperation with State and local governments,” and other agencies with jurisdiction by law or special expertise. 42 USC 4331(a), 4332(2); see also 

40 CFR 1501.6. The purpose of these requirements is to benefit the decision-making process by ensuring agency stakeholder involvement, thereby 

allowing the early disclosure of relevant information, avoiding duplication of federal and other governmental and tribal entities’ efforts, and 

promoting agencies’ ability to foster intra-governmental trust. The agency responsible for the NEPA analysis should determine whether any such 

federal agencies or governmental or tribal entities are interested and capable of participating as a cooperating agency. Even if an invited entity 

declines participation, it should still be considered for inclusion in interdisciplinary teams engaged in the NEPA process. 

Comment: Range of Alternatives Recommendation 

Every alternative in the DEIS contemplates further restriction on access to roads and trails and areas by motorized means. It 

is apparent from the DEIS that the purpose and need for the project is to minimize asbestos exposure and reduce asbestos 

emissions. DEIS at Executive Summary p. III. Thus, the DEIS accepts as a foregone conclusion that the CCMA is hazardous 

enough to justify limiting but one factor in exposure, based on questionable science. 

Thus the purpose and need, from which the range of alternatives flow, illegitimately creates a range of alternatives that 

precludes meaningful analysis. Every alternative, save the no action alternative, results in significant limitations on 

motorized recreation access. Thus, the decision-making paradigm is constrained to options that rely on achieving the purpose 

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and need through a single means: limiting recreational access. Hazards exist throughout the public lands; not every one can 

be identified, evaluated, and protected against. Even assuming that the underlying science conclusively demonstrates the 

conclusion for which it is accepted, a range of alternatives that aims solely to reduce access precludes consideration of 

legitimate alternative means to achieve the result. In sum, the range of alternatives, and the preferred alternative, derive from 

an erroneous premise and result in the impossible enterprise of closing areas based on unknown hazards. 

The DEIS’s range of alternatives fails to address reasonable alternative mitigation measures and instead favors closure to 

achieve its goal. However, numerous alternative mitigation measures exist and have been presented to the HFO; BLM cannot 

summarily disregard, without analysis, these reasonable alternatives. 

BLM Response: Pursuant to 40 C.F.R. § 1502.14, the BLM’s Hollister Field Office conducted multiple public scoping meetings and 

interdisciplinary team discussions to rigorously explore and objectively evaluate all reasonable alternatives in the CCMA Draft RMP/EIS. 

Numerous interested parties, including the consortium of OHV organizations and clubs represented by Moore, Smith, Buxton, Turcke, Chartered 

participated in the public scoping meetings and helped generate the range of alternatives analyzed in the CCMA Draft RMP/EIS. 

Furthermore, the comments from MSBT-LAW demonstrate that the BLM was presented with evidence during the scoping process regarding 

appropriate response, “As noted by BLM’s own experts, the common and necessary practice is to improve the monitoring and methodology in 

order to refine “institutional controls governing when, where, how, and who can ride” in an effort to “reduce risk into the acceptable range and 

enable limited ORV use at the site.” Ford Memo., at p.2, #14.” Accordingly, five out of the seven alternatives analyzed in the CCMA Draft 

RMP/EIS (Alts. A - E) incorporated technical and administrative measures to improve monitoring of meteorological conditions, airborne asbestos 

emissions, and CCMA visitor use in order to enable limited ORV use at the site. 

Comment: Temporary Closure Order Recommendation 

40 CFR 1506.1 precludes an agency from taking an action that would have an adverse 

environmental impact the choice of reasonable alternatives. HFO states in the DEIS that “the 

closure order will remain in place during the preparation of the CCMA RMP/EIS because this 

issue is outside the scope of the planning effort and the temporary closure will not affect the 

RMP development.” DEIS at 8. The closure order during the NEPA process, while founded on less-than-conclusive science 

and thus not independently justified, in fact pre-ordains BLM’s ultimate conclusion and therefore does effectively limit the 

choice of reasonable alternatives. It 

is obvious, also, that the closure decision, which is itself among the alternatives, appears to “determine subsequent 

development or limit alternatives.” 40 CFR 1506.1 (1)(c)(3). 

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BLM Response: Refer to Common Response Section 3A. 

Comment: EPA Data and Uncertainty Recommendation 

There is unquestionable uncertainty in the EPA’s own report regarding the actual conditions; ergo, its sampling, testing, and 

conclusions do not necessarily correctly characterize the risk. 

Additionally, throughout the NEPA process for the CCMA RMP, HFO has essentially disregarded, or at least ignored, 

credible scientific data indicating that PCME fibers are located in concentrated areas, which would allow for a more tailored 

management approach than is available from the range of alternatives presented in the DEIS. It also is apparent that the EPA 

report fails to sample according to actual riding patterns. The DEIS fails to address the ambiguity of the data, and therefore, 

in sum, the DEIS fails to take the requisite “hard look” at the data it accepts as true, thus failing to consider an important 

aspect of the problem. 

-noneBLM Response: Section 4.2.2 of the CCMA Draft RMP/EIS addresses the Limits and Constraints of the Analysis, including but not limited to 

Incomplete and Unavailable Information (4.2.2.1), and Exposure and Risk Uncertainties (4.2.2.2). 

Comment: Socioeconomic Impact Analysis Recommendation 

The DEIS fails to adequately account for the socioeconomic and environmental impacts to other areas or the local economies 

caused by the alternatives, including the preferred alternative, in violation of NEPA. Socioeconomic impacts are 

characterized in conclusory terms without specific analysis of data to support the conclusions. See generally, DEIS at 520­

23. 

-noneBLM Response: Refer to Common Response Section 4D. 

Comment: Climate Change Assumptions Recommendation 

The DEIS justifies some of its analysis and conclusions on what it characterizes as the result of climate change. DEIS at 451. 

However, the DEIS contains insufficient data to support the conclusion that climate change will have the asserted impacts on 

the CCMA soils and vegetation. 

-noneBLM Response: The DEIS (pg. 451) and CCMA Proposed RMP and FEIS (Section 4.7.1.2.2) state the following wuth regards to climate change. 

“This analysis assumes that global climate change will make the planning area warmer and drier by the end of the 21st century. 

However, the body of information and predictive models for climate change is in its infancy regarding prediction of site specific 

impacts to areas such as the CCMA, and the plan assumes that knowledge will advance quickly with the current emphasis on climate 

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research and model development. As the RMP is implemented, BLM managers would place a continued emphasis on research, and 

studies may include components to assess the impacts of changing climate. In the event that climate change made achievement of 

RMP objectives themselves infeasible, the plan would need to be amended accordingly.” 

ORG-CA4WDC: California Association of Four Wheel Drive Clubs, Inc. 

Comment: No Action Alternative Recommendation 

Per the CEQ Forty Questions, (CEQ 40 CFR 1502.14), a no-action alternative must contain the following: “This analysis Please rewrite the 

provides a benchmark, enabling decision makers to compare the magnitude of environmental effects of the action document reflecting 

alternatives. It is also an example of a reasonable alternative outside the jurisdiction of the agency which must be analyzed. a true no-action 

Section 1502.14(c)” alternative not 

. prejudiced or 

There is little to nothing in this document that qualifies under a no-action alternative because every piece of evidence biased against 

contained in the document is contaminated by the results of the 2008 EPA study and it's conclusions. All alternatives in the motorized access to 

document contain the assumption of risk implied in the EPA report. A true no-action alternative would not be prejudiced by the CCMA because 

questionable conclusions contained in the aforementioned report. of the 2008 EPA 

study. 

Alternative A, represented in the document as the no-action alternative actually incorporates changes due to the assumption 

of risk. Therein lies the crux of the problem – there is no true no-action alternative, therefore the document does not comply 

with CEQ regulations. Please rewrite the document to show a true no-action alternative not tainted by the 2008 EPA study. 

BLM Response: Refer to Common Response Section 3B. 

Comment: R.S. 2477 Recommendation 

Per Congressionally enacted Revised Statute 2477, the public has a right of access of roads and highways to facilitate their 

right-of-way. This document presents various scenarios that would inhibit the right of the public to travel over previously 

designated public and county roads and highways, in opposition to all rights and privileges granted to members of the 

public. The BLM has no right to impede or restrict access over and or all the roads and highways mentioned in the 

DRMP/EIS, and the document must be rewritten to reflect this fact 

-noneBLM Response: Refer to Common Response Section 1E. 

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Comment: No Evidence of Actual Harm Recommendation 

Under every statute of law, evidence is a primary need to establish and prove a legal case. But since neither agency pursued 

on-the-ground, concrete evidence of the health risk, we must conclude that no evidence actually exists that directly links 

recreating at the Clear Creek Management Area with any increased health risk for the over 50 years+ of recreation activity 

in the area. 

We reject these supposed findings outright because they present no true information, only excuses why critical information 

is missing. 

Unless and until epidemiological studies definitely prove a risk that is beyond a supposition, the Clear Creek Management 

Area must be reopened to motorized recreational use. Please strike form the document all reference to health risk until such 

time as the appropriate epidemiological studies are conducted and prove any other than the current evidence shows – that 

there is no risk for motorized recreation in the Clear Creek Management Area. 

-noneBLM Response: Refer to Common Response Section 1F(i). 

Comment: Recreation Use Scenarios Recommendation 

We contend that the typical activity as measured in the DRMP/EIS is actually atypical activity for the Clear Creek 

Management Area in regards to motorized recreation. For many years motorcycle enthusiasts and 4WD enthusiasts have 

taken air samples as part of the regular activities during events. And yet these air samples have never indicated any health 

risk, motorized recreational activity was never stopped because of dangerous levels, nor were any closures issued because 

of evidence gathered during these activities. We would conclude that these air sample represent the true “typical” activity 

for motorcycle use in CCMA because these samples were gathered by the riders themselves. 

Contrast the methodology during the EPA study and you will find evidence in the document of riders of unproven ability 

and experience riding, in an atypical manner either too closely to one another, or off designated trails, or in exclusively 

lower elevations. Also, is the question of the moisture in the soil present during the air sampling. 

Also evident in the photo are blade marks made from 'dragging' the route prior to the EPA riders measuring the dust in the 

air. This is not typical of off-road recreation, which enjoys and treasures the idiosyncrasies of the bumps and dips present on 

an off-road trail. Therefore, this leads us to question why the road was dragged prior to the testing done by the EPA, as this 

would most assuredly lead to increased dust particles in the air, and alter the testing results. 

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BLM Response: Refer to Common Response Section 1C. 

Comment: Risk Assessment Data Recommendation 

Any and all conclusions based on data collected during the time of the dry season closure must be removed from the 

DRMP/EIS. The fact that data from the period of the dry season closure was used in the document is a fatal flaw for the 

document – because there is no alternative that proposes allowing riding during that time period. 

Only data that is relevant to the alternatives presented in the DRMP/EIS can be included in the document, and all other data 

must be removed. 

This includes any reference to dry season riding, all data collected during dry season riding, and all conclusions derived 

from data collected during this time. All data referred to in the document, and/or conclusions derived from such, are outside 

the scope of the document, i.e. data during a dry season closure (closure being the operative word). 

-noneBLM Response: Refer to Common Response Section 1C. 

Comment: 2001 BLM National Travel Management Direction Recommendation 

Strictly looking at the evidence that present itself in the DRMP/EIS, it is clear that the Hollister Field Office has purposely 

excluded one specific form of motorized recreation; motorcycle riding. This is in opposition to the 2001 BLM National 

Travel Management Direction because it restricts use by vehicle type. 

The Purpose and Need clearly states on page 2 the need to; “The CCMA RMP shall guide the management of the lands and 

resources administered by the Hollister Field Office in CCMA to achieve the following:.... 3)designate areas in CCMA for 

motorized, mechanized, and non-motorized/non-mechanized recreation opportunities;”. But the preferred alternative does 

not allow for motorcycle riding at all. Therefore the BLM has not adhered to it's Purpose and Need, and the DRMP/EIS is 

fatally flawed, and a supplemental DRMP/EIS must be issued. 

The DRMP/EIS provides little, if any, explanation why motorcycle riding has been excluded from the preferred alternative. 

Per the aforementioned 2001 direction, BLM policy does not allow for restriction by vehicle type, and the direction is clear 

in the non-discrimination between types of off-road vehicles, or uses for off-road vehicles (36 CFR 8340.0-5). The preferred 

alternative clearly excluding motorcycle riding represents a new policy direction that the Hollister Field Office is not 

entitled to establish. 

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BLM Response: BLM’s authority to regulate off-road vehicle use on public lands is promulgated by 43 CFR 8340. Pursuant to Sec. 8340.0-5. 

Definitions. As used in this part, include the following (underline added for emphasis): 

(f) Open area means an area where all types of vehicle use is permitted at all times, anywhere in the area subject to the operating regulations and 

vehicle standards set forth in subparts 8341 and 8342 of this title. 

(g) Limited area means an area restricted at certain times, in certain areas, and/or to certain vehicular use. These restrictions may be of any type, 

but can generally be accommodated within the following type of categories: Numbers of vehicles; types of vehicles; time or season of vehicle use; 

permitted or licensed use only; use on existing roads and trails; use on designated roads and trails; and other restrictions. 

(h) Closed area means an area where off-road vehicle use is prohibited. Use of off-road vehicles in closed areas may be allowed for certain 

reasons; however, such use shall be made only with the approval of the authorized officer. 

Please refer to Common Response Section 3D. The Proposed Action analyzed in this PRMP/FEIS includes 32 miles of designated routes in the 

Serpenetine ACEC that would be limited to highway-licensed vehicles, including dual sport motorcycles. 

Comment: Best Available Science Recommendation 

The latest and best science is not used in the 2008 EPA report, therefore the BLM must not use that study as the basis of a 

management plan. Other scientific evidence, by the BLM's own admission, was not used or considered by the BLM. 

All scientific conclusions are subject to peer review, and yet the BLM took this EPA study as outright fact, without 

conducting due diligence. Progressing from the fact that the best possible science was not used, is that fact that the 

DRMP/EIS was developed with alternatives that are unfairly restricted, contrary to CEQ regulations. From one misstep to 

another, this BLM prepared document represented a series off-ill-conceived calculates in an attempt to conduct a true 

scientific analysis. 

This is in direct opposition to the Data Quality Act, and the BLM's own internal guidelines to adhere to that Congressionally 

passed legislation. Please remand this document, and redo the RMP to include both the best possible science, and comply 

with all aspects of the Data Quality Act. 

-noneBLM Response: Refer to Common Response Section 1F(ii). 

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Comment: Inadequate Impact Analysis Recommendation 

The DRMP/EIS fails to evaluate the need for motorized recreation counter to visitor needs. In the Purpose and Need of the 

DRMP/EIS clearly sites; “Changes in social and economic conditions in San Benito County, the San Joaquin Valley, and 

the entire State of California have led to increased demand for use of public lands for recreation and energy production as 

well as an increased awareness and social value placed on the cultural and natural resources in the Planning Area.”, but then 

reversed the need indicated in this sentence to present a preferred alternative that does not correspond to the “ ...increased 

demand for use of public lands for recreation...”.It then follows, that the preferred alternative does not adhere to the Purpose 

and Need as stated in the DRMP/EIS, and therefore should not be the designated as the “Preferred Alternative” since it 

decreases access for public lands for recreation. 

Public scoping information is also clearly listed in the document, and indicates a very clear need for increased motorized 

recreation opportunities. So this document does not flow from scoping. 

The Social and Economic meeting held on February 22, 2010 in Hollister clearly indicated the need from the local areas 

greatly affected by the closure for a reopening of the Clear Creek Management Area. 

-noneBLM Response: Refer to Common Response Section 2C and 3A. 

Comment: Asbestos Terminology Recommendation 

Much of the terminology used in the document is mistaken and inappropriate. The Purpose and Need of the document, 

which should represent a clear plan of what the agency hopes to accomplish, is misleading in this DRMP/EIS. Quoting from 

the document, the purpose is to: “ 1) Minimize Asbestos exposure 2) minimize asbestos emissions....”. 

No less than the Unites States Geological Survey defines asbestos as; ...“Asbestos is a commercial-industrial term with a 

long history, and is not a mineralogical definition”. As the discussion in this document does not refer to a industrial setting, 

but rather a natural setting, all references to “asbestos” in this article must be removed and replaced with more accurate 

terminology. The discussion at the forefront for this document is Serpentine rock, which contains the mineral chrysotile. 

-noneBLM Response: Refer to Common Responses 1A. 

Comment: Cumulative Effects Recommendation 

Any or all of the [cumulative] effects of closing the Clear Creek Management Area are not 

evaluated by the DRMP/EIS. Besides the economic effects on local businesses in the affected 

It is a well-known axiom that every action has 

an equal and opposite reaction. The reaction to 

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areas, including Coalinga, King City and Hollister, there are the effects of travel for recreational the closure of Clear Creek Management Area 

opportunities to other areas, and impacts their facilities, whether it be State and County owned, has to be evaluated in order for this DRMP/EIS 

such as the Hollister Hills SVRA, or Metcalf Motorcycle Park in Santa Clara County. to be compliant with CEQ regulations. 

BLM Response: Refer to Common Response Section 4D & 4E. 

ORG-CERA: California Enduro Riders Association 

Comment: Children’s Exposure Scenarios Recommendation 

The risk characterizations for child exposures has two major 

flaws: 

1. The risk assessment doesn’t take into consideration the 

smaller lung capacity of the child. 

2. The risk assessment doesn’t take into consideration that a 

child would not ride the same length of time or distance that 

an adult would. 

All portions of the Draft RMP!EIS that refer to a child’s potential health hazard 

due to potential exposure to chrysotile must be removed or corrected with factual 

and documented data before the decision is made on the Final ROD/RMP/EIS. 

All portions of the Draft RMP/EIS that include age restrictions must be removed or 

substantiated with factual and documented data before the decision is made on the 

Final ROD/RMP/E1S. 

BLM Response: Refer to Common Response Section 1C. 

Comment: Waivers of Liability Recommendation 

The following three sections of the Draft RMP/EIS, while written differently, state that signed waivers would 

reduce risk to public health and safety and/or minimize exposure to hazardous materials and airborne asbestos 

fibers. 

[DEIS Page 41: HAZ-BG4. DEIS page 86: IIAZ-BG4. DEIS page 351: 4.2.6.2 Mitigation] 

This is not true. They would not mitigate exposure to hazardous materials and airborne asbestos fibers. They 

are not part of a HAZARD program. They are part of a legal program. 

A signed waiver would be to indemnify BLM against risk of tort claims. [Page 352: Waivers of Liability and 

Indemnification of Risk] confirms the problem of relating a waiver of liability to reducing risk to public 

health and safety and/or minimizing exposure to hazardous materials and airborne asbestos fibers. 

A statement for the reason of 

inclusion of a Waiver of Liability 

must be included in each of the 

Alternatives that contain a Waiver 

of Liability. 

Statements referring to waivers of 

liability as mitigation for the risk 

to public health and safety and/or 

to minimize exposure to 

hazardous materials and airborne 

asbestos fibers must be deleted 

from the Draft RMP/E1S and not 

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[Additionally] All of the Alternatives except “A” include a Waiver of Liability. While the Waiver of included in the Final RMP/EIS 

Liability would have no beneficial impact on public health and safety, there must be a reason that the BLM and ROD. 

included it in the Alternatives. That reason has not been stated in the DEIS. 

BLM Response: As noted in section 4.2.6.2 of the CCMA Draft RMP/EIS and section 4.2.4.1 of this PRMP/FEIS, “During public scoping, 

authorization of access into the Serpentine ACEC based on signed waivers of liability (i.e. indemnification of risk), was identified as a potential 

mitigation measure to inform visitors of the health risk associated with exposure to asbestos to determine their own willingness to accept the risk 

of exposure to asbestos in CCMA. In other words, this measure would allow individuals to “ride at their own risk”, and reflects the preferred 

approach identified by the majority of the public scoping comments. However, developing a waiver of liability, or establishing indemnification of 

risk, would have no beneficial impacts on public health and safety because neither approach would actually reduce exposure to airborne asbestos 

or improve overall protection of human health and the environment.” 

HAZ-BG4 says BLM would “Require signed waivers of liability to indemnify BLM against risk of tort claims associated with CCMA visitor use 

and exposure to airborne asbestos fibers”, and explains that supplementary rules would be implemented based on the overall effectiveness of 

mitigation measures. However, the Proposed Action analyzed in this PRMP/FEIS does not include waivers of liability as a public health and safety 

mitigation measure because it was determined to be ineffective, consistent with comments from CERA. 

Comment: Visitor Use Scenarios Recommendation 

Some statements, assumptions, and conclusions in the Draft RMP/EIS rely on unsubstantiated visitor statistics from 

the EPA CLEAR CREEK MANAGEMENT AREA ASBESTOS EXPOSURE AND HUMAN HEALTH RISK 

ASSESSMENT. 

The EPA’s recreation use data for CCMA visitors relies on the 1992 PTI HRA. The assumptions made in the 1992 

PTI HRA are arbitrary and capricious and cannot be relied upon by the EPA. Furthermore, the decisions made within 

the Draft RMP/EIS pertaining to the visitors should not use the information contained in the EPA assessment. 

All entries in the Draft 

MP/EIS that were derived 

from the EPA’s Health 

Risk Assessment about the 

visitors to the CCMA must 

be removed and not used 

in the final ROD and EIS. 

BLM Response: Refer to Common Response Section 1C. 

Comment: Rockhounding Recommendation 

1. Within the Draft RMP/EIS there are 27 instances of the action rock hounding. 

This action has not been defined in the Draft RMP/E1S. A definition is important to show 

what would or would not be allowed in any of the Alternatives and/or the Final EIS and 

Rod. A definition is also needed so that proper testing for potential asbestos exposure 

1. A definition of rock hounding must be added to 

the Draft and Final RMP/EIS and ROD. 

2. Rock hounding must be changed to separate 

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levels can be done. entries in the Draft and Final RMP/EIS and ROD 

and not grouped with hiking and hunting. 

2. The action of rock hounding can disturb the soil and puts the person closer to the soil. 

This action cannot be equated with hiking or hunting. There was no testing by the EPA to 3. Air sampling and analysis while rock hounding 

show the potential asbestos exposure level for this recreational activity, therefore, no must be performed to establish its potential health 

conclusions about the potential asbestos exposure can be made. The Draft RMP/EIS has hazard before any conclusions can be entered into 

failed to present any analysis of the action of rock hounding. the Draft and Final RMP/EIS and ROD. 

BLM Response: The CCMA Draft RMP/EIS characterizes hobby gem and mineral collection (i.e. rockhounding) in section 3.1.4.1 (pg. 

133).Refer to Common Response Section 1C. 

Comment: Preferred Alternative. Recommendation 

Alt E eliminates all motorized recreational use outside of the ACEC and all OHV use in 

the ACEC. Selection of Alt. E would not fulfill the requirements of 43 CFR 2410.1. 

To comply with 43 CFR 2410.1, an alternative that 

allows recreational OHV use must be selected. 

BLM Response: There is no specific requirement to authorize motorized recreation in the referenced regulations. Pursuant to 43 CFR 2410. 1, 

BLM has taken all present and potential uses and users of the lands into consideration in the CCMA Draft RMP/EIS. Refer to Common Response 

Section 3A. This PRMP/FEIS also analyzes a range of alternative land use decisions to reduce public health risks to acceptable levels while 

achieving “maximum future uses and minimum disturbance to or dislocation of existing users.” 

Comment: Planning Criteria Recommendation 

There are two (2) PROBLEMS with the following [Planning Criteria: Page 10] 

Consider the extent to which the revised plan reduces accelerated erosion and offsite 

transport of asbestos fibers on vehicles and clothes due to off-highway vehicle use. 

Problem 1: Erosion and offsite transport of asbestos fibers are two totally unrelated 

potential problems. 

Problem 2: There is no proof provided in the Draft RMP/EIS to show that asbestos 

fibers from the CCMA are being transported offsite on vehicles due to off-highway 

use. 

1. Erosion and offsite transport of asbestos fibers must be 

listed separately in the planning criteria. 

2. In the Planning Criteria of the Draft RMP/EIS, it must 

state that there is no verified data to support the claim that 

asbestos fibers from the CCMA are being transported 

offsite from the CCMA. 

The Draft RMP/EIS must state that there is no verified data 

to show a need for a public wash station. 

BLM Response: Section 4.2.2 of the CCMA Draft RMP/EIS and this PRMP/FEIS contains the following statement: 

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BLM was unable to quantify reductions in human health risk and asbestos emissions from implementation of mitigation measures because 

reliable data on the effectiveness of surface hardening techniques or dust suppression on roads in CCMA cannot be obtained because of 

cost and feasibility issues. Therefore, BLM's evaluation of such impacts is based upon theoretical approaches or research methods 

discussed in the EPA’s risk assessment and this RMP/EIS that are generally accepted in the scientific community. 

Section 4.2.2.4 of the CCMA Draft RMP/EIS and this PRMP/FEIS also states: 

Many of the other mitigation measures considered in the range of alternatives and the Proposed Action for the CCMA 

PRMP/FEIS are also limited to qualitative analysis because there is no information available on the effectiveness of such 

measures as restricting annual visitor use days/year, vehicle types, installing vehicle wash racks, enforcement of speed limits, 

indemnification of risk, and other administrative actions in reducing exposure to asbestos emissions in CCMA. 

Comment: Motorized Vehicle Use Conflicts. Recommendation 

Pages 359, 360, 362, 364, 365, 366, 368, 369, and 

370 of the Draft RMPIEIS do not contain any 

documented evidence of conflicts between 

motorized vehicles and other forms of recreation 

The contents in the section of Motorized Vehicle Use Conflicts on all pages listed above 

must be removed if documented evidence of conflicts between motorized vehicles and 

other forms of recreation cannot be established. The Hollister office of the BLM must also 

address as a mitigation possibility, restrictions on non-motorized recreation. 

BLM Response: The types of user conflicts decribed in section 4.1.2.1 of the CCMA Draft RMP/EIS and this PRMP/FEIS have been documented 

by BLM. Although these situations are often defined as “user conflicts”, there generally is no physical or safety conflict associated with one party 

encountering another party on the trail. These situations could also be described as impacts of motorized use on private landowners or nonmotorized user groups experience of the public lands. The CCMA Draft RMP/EIS and this PRMP/FEIS also consider restrictions on nonmotorized recreation to reduce human health risks associated with exposure to naturally occurring asbestos in the Serpentine ACEC. 

Comment: Hunting Recommendation 

There are 119 instances of the word hunting in the Draft RMP/EIS. There can be many opinions of what constitutes 

hunting and its application within the Draft RMP/EIS. For some, it is the quest to take game animals. For others, it 

could be trying to locate an object or place as in geocaching. For the taking of game animals, it could entail either total 

foot traffic or the scouting of an area by motorized travel. Deer and wild boar have been the main mammals that have 

been hunted within the CCMA. I have heard that Elk have also moved into the area. Upon a successful hunt, retrieval of 

any of these mammals would be very difficult without motorized access. It would be a shame to leave a carcass behind 

because the successful hunter was unable to retrieve it. 

The word hunting must 

be defined in the Draft 

RMP/EIS to clarify the 

activities allowed or 

restricted in the 

Alternatives and final 

EIS and ROD. 

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BLM Response: The CCMA Draft RMP/EIS characterizes hunting in section 3.1.4.1 (pg. 134). 

Comment: Cumulative Effects Recommendation 

Section 4.2.9 Cumulative Effects, has nothing to do with cumulative effects. This section 

is a dissertation on pneumoconiosis and contains no connection with cumulative effects. 

The contents of Section 4.2.9 must be totally 

removed before any consideration for the final 

RMP/EIS/ROD. 

BLM Response: Refer to Common Response Section 4E. 

Comment: Scarcity of OHV Opportunities Recommendation 

The scarcity of public OHV recreational land was not given adequate consideration in the Statements must be included in the Draft 

development of the preferred alternative. According to (43US.C. ]712(c,)(6,),, it is the RMP/EIS that: 

responsibility of the Hollister office of the BLM to give adequate consideration to 

replacement of lost OHV recreational opportunity. 1. Show the amount of recreational OHV 

opportunity that is available within 100 miles of 

The Draft RMP/EIS states that approximately 80% of the visitors to the CCMA are there for the CCMA and the impact that each of the 

01-TV recreation. The Hollister office of the BLM has the only public lands within 100 miles alternatives will have on that opportunity. 

of the CCMA available for OHV recreation. The emergency closure of the CCMA has 

impacted the ability of Hollister Hills SVRA to provide OHV recreational opportunity to all 2. Explain why recreational OHV opportunity in 

that wish to go there. The preferred alternative does not replace ANY of the lost OHV any part of the CCMA was not included 

recreational opportunity that would occur if that alternative were enacted. There are no in the preferred alternative, or add to the preferred 

statements within the Draft RMP/EIS explaining why recreational OHV opportunity that alternative an amount of recreational 

would be lost from the prohibition of recreational OHVs from the ACEC could not be OHV opportunity similar to what would be lost 

replaced on other areas within the CCMA. from the proposed restrictions within the 

ACEC. 

BLM Response: Refer to Common Response Section 3D and 4B. 

Comment: Serpentine ACEC Boundary Recommendation 

A legal boundary for the CCMA Serpentine ACEC does not exist. In the 1999 CCMA ROD, 

one of the items to be completed after the signing of the ROD was to formalize the 

boundaries of the ACEC. 

All entries, references to, or decisions made by 

use of the boundaries of the Serpentine 

ACEC must be removed from the Draft 

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ROD/FEIS as they must be considered as 

The declaration of new boundaries was never entered into the Federal Register. arbitrary, capricious, and have no legal standing. 

Notification in the Federal Register is a requirement to legally describe the boundaries. 

All entries, references to, or decisions made by 

With no legally binding boundaries, all entries concerning the Serpentine ACEC in the use of the boundaries of the Serpentine 

CCMA Draft RMP/E1S have no substance. Legal boundaries are necessary to denote where ACEC must he removed from consideration when 

and what type of activities can take place within the CCMA. the Final EIS and ROD are produced. 

BLM Response: Section 1.3.2.3 of the CCMA Draft RMP/EIS and this PRMP/FEIS explain that changes or modifications to special designations 

in CCMA will not be considered in the range of alternatives for the CCMA RMP/EIS. The designation of the Serpentine ACEC in the 1984 

Hollister RMP (as amended) is based on human health risks associated with exposure to asbestos within the serpentine soils. The boundaries of the 

ACEC were defined by mapping of asbestos soils derived from the New Idria serpentine formation. The Federal Register notice of availablity 

published for the Hollister RMP (1984) and the 2006 Record of Decision (ROD) for CCMA RMP Amendment and Route Designation satisfied 

legal requirements for establishment of the current ACEC boundary. 

ORG-CFMS: California Federation of Mineralogical Societies 

Comment: Comments submitted by individual members and mineralogical societies. Recommendation 

Refer to rockhounding organizations and individuals comments. -noneBLM Response: Thank you.
 

ORG-CMDA: California Motor Dealers Association
 

Comment: Recommendation 

On behalf CA over 200 franchised and authorized California motorcycle and motorsport dealers. I respectfully ask you to 

reopen the Clear Creek Management Area to motorized recreational use. This abrupt (and continuing) closure, although it 

may have been well-intentioned, did not take into account the devastating financial impact on motorcycle and all terrain 

vehicle (ATV) dealers, in the direct and feeder areas of California, to Clear Creek. 

Our Members, undoubtedly, will be advising you of their individual cases of how significantly this closure has affected their 

businesses, and I will give you an overview of its impact on the industry. Motorcycle retailing is suffering through the most 

serious challenge that we have ever experienced because of the deepest national recession since the Great Depression. 

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The Clear Creek closure exacerbates that effect, since many CMDA Member dealerships depend on their customers’ income 

from the use of this decades-old, excellent OHV riding area CMDA Members include direct, and feeder, OHV businesses 

from Bakersfield, Berkeley, Concord, Daly City, Fowler, Fremont, Fresno, Gilroy, Goleta, Hayward, Hollister, Lemoore, 

Livermore, Lompoc, Manteca, Merced, Modesto, Morgan Hill, Monterey. Mountain View, Oakland, Oakley, Paso Robles. 

Redwood City, Salinas, San Francisco, San Mateo, San Jose, San Rafael, Santa Clara, Santa Maria, Sonora, Stockton. 

Sunnyvale, Tulare, Visalia and Walnut Creek. 

On behalf of these dealers directly impacted by the closure, we respectFully urge the BLM to appmve Alternative 1. To 

justify that Alternative choice, please do more extensive air sampling, which is likely to demonstrate that the health hazards 

are much less significant than your limited study indicates. 

BLM Response: Refer to Common Response Section 4D and 1F(iii). 

ORG-CNPS: California Native Plant Society 

Comment: General Recommendation 

The DRMP/DEIS document is unnecessarily complicated and too long for the general public to assimilate and begin to 

provide germane comments. This is very unfortunate because we believe it excludes many individuals who appreciate the 

CCMA AND the surrounding ‘management zones’ and would otherwise be able to provide comments. 

-noneBLM Response: Refer to Common Response Section 1G. 

Comment: Land Tenure Adjustments and New OHV Areas Recommendation 

All of the surrounding ‘management zones’ that the Hollister BLM interdisciplinary staff designated for this document have 

many sensitive, rare plant and animal species and communities. Decisions to “dispose” and/or develop trail networks/roads 

on these public lands is incongruous with conserving and protecting the sensitive natural resources that occur therein. 

We strongly oppose development of any new OHV recreation areas by the Hollister BLM Field Office for energy 

consumptive, destructive recreation for the following reasons: 1. Inadequate funding for additional law enforcement, ranger 

patrols, restoration and rare species monitoring at the CCMA or any of the proposed ‘new areas’; 2. The southern Diablo 

Mountains are geologically and biologically diverse. These Public lands are highly sensitive and should be protected, not 

exploited. 

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Retain the lands identified in the DRMP/DEIS in the Tucker, Condon and San Benito River management zones. 

BLM Response: Refer to Common Response Section 3D and Section 1.9 of this PRMP/FEIS. 

Comment: Planning Area Recommendation 

The description of the planning area (1.2) neglects to include “high number of sensitive plant and animal species,” and also 

omits incense cedar from the “unique forest assemblage.” 

-noneBLM Response: The “high number of sensitive plant and animal species” is discussed in detail throughout section 3.6 of the CCMA Draft 

RMP/EIS and this PRMP/FEIS. Incense cedar is included in the detailed description of vegetation in section 3.4 of the CCMA Draft RMP/EIS 

and this PRMP/FEIS. 

ORG-CORVA: California Off-Road Vehicle Association 

Comment: Rationale for Vehicle Use Limits Recommendation 

Motorcycles, whether highway licensed or green sticker registered, are excluded from the entire CCMA in Alternative E 

and allowed only outside the ACEC in Alternative D. Full sized 4X4 vehicles are allowed on a permit only basis within 

the ACEC in Alternatives D and E. ATV/UTV use only is allowed in areas adjacent to the ACEC in alternative E. The 

draft RMP-EIS provides no explanation for the exclusion of motorcycle use from the CCMA in these alternatives. There 

is no mention of how motorcycles might negatively affect cultural or natural resources or be a source of conflict that 

would prelude their use within the CCMA. The primary concern appears to be the potential for negative effects on 

human health and safety that would apply to all vehicles, not just motorcycles, according to the EPA study cited in the 

draft RMP-EIS. 

The 2008 EPA study provides little if any basis for allowing one form of vehicle use while excluding others. This 

indicates that there is no clear rationale described in this document for restricting use by vehicle type and that in fact that 

all vehicle types result in some level of asbestos exposure. 

2. Alternatives that 

allow the use of full 

sized 4X4 vehicles in 

the ACEC and exclude 

other motorized 

vehicles must be 

revised to either 

exclude all vehicles 

from the ACEC or 

allow limited use of 

the area by all 

vehicles. 

BLM Response: Refer to Common Response Section 3D. 

Comment: Alternative D Recommendation 

The draft RMP-EIS does not provide adequate discussion of Alternative D that would allow a reasoned choice The draft RMP-EIS raises 

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between alternatives. The draft RMP-EIS must be revised to include an adequate discussion of the issues related to the issue of potentially 

Alternative. asbestos bearing deposits 

in the Condon and Cantua 

In Table 2.6-14, the document makes an apparently contradictory statement regarding potential public access to the areas. There is no 

Tucker, Condon and San Benito River areas. discussion of the Tucker 

Mountain area. 

“Under Alternative D, none of the 3,300 acres in the Tucker, Condon, and San Benito River zones would be available 

for disposal. Retention of these lands would have minor adverse impacts on management efficiency and public access The draft RMP-EIS 

because all of these parcels have no existing (or reasonably foreseeable) public access. Otherwise, Alternatives E and provides no information 

F would have the same effects as Alternatives B and C.” to support this statement 

such as soil survey results 

The analysis provided in the draft RMP-EIS is inadequate because Alternative D is not given fair and thorough or GIS surveys. The 

discussion and is not established as a reasonable and viable alternative. The draft RMP EIS cites a previous study of Martin Ranch SVRA 

the Cantua area but provides only the most limited discussion of the results of the study and how they might apply to Acquisition study in fact 

motorized recreation in the adjacent CCMA. indicates that asbestos 

areas were identified and 

The Martin Ranch SVRA Feasibility study indicates that this is a potentially viable area for an SVRA. This study could potentially be 

area includes BLM lands that are proposed for purchase or exchange with the intent of developing an OHV area to excluded from the 

provide opportunity for the Central Valley. According to this study there is the potential for an OHV area outside the planned SVRA. This 

Clear Creek ACEC, and that the elimination of impacts due to grazing in this area would more than offset those that statement appears to be a 

would be expected from OHV use. Furthermore, this area could be developed without including asbestos bearing matter of opinion and 

deposits within the SVRA boundary. purely speculative. 

To summarize, the draft RMP-EIS provides contradictory statements related to the availability of public access to the The document should 

Condon Peak and Cantua zones and little if any information about possible public access to the Tucker Mountain either provide supporting 

zone. The maps provided indicate that two alternatives, D and E, include development of recreation sites in the information for this 

Condon and Cantua zones and that public access from New Idria Road and Los Gatos Road is planned for these areas. statement or remove this 

But there is no discussion of why recreational opportunity for off highway vehicles should be included or excluded statement from the draft 

for these areas. This is a key element of alternative D, yet any discussion of this element is lacking. RMP-EIS. 

BLM Response: Refer to Common Response Section 3C. 

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ORG-CBD: Center for Biological Diversity
 

Comment: General Comments Recommendation 

Instead of an actual draft management plan (and associated EIS), very little baseline conditions and management guidance -noneare actually identified or evaluated in the DRMP/DEIS. The document fails to identify any qualitative or quantitative 

desired condition criteria for the resources, and instead reads primarily as a single issue off-road vehicle plan with five of 

seven alternatives incorporating ORV use, despite the fact that the CCMA Asbestos Exposure and Human Health Risk 

Assessment (Risk Assessment) indicates that all activities except day-use hiking significantly disturbed soils and increased 

the risk of airborne asbestos. In fact the Risk Assessment states that “Motorcycle riding, ATV riding, and SUV 

driving/riding had the highest exposure concentrations, in some cases exceeding even the U.S. Occupational Safety and 

Health Administration (OSHA) 30-minute Excursion Limit for asbestos. Only hiking was near ambient asbestos 

concentrations.” (Risk Assessment at pg. ES-2). 

While one of the goals of the management plan is to “Restore, maintain or improve ecological conditions, natural diversity, 

and associated watersheds of high value, high-risk, native plant communities and unique plant assemblages”, the document 

fails to identify 1) which ecological conditions, natural diversity, communities and assemblages will actually be evaluated 

(all of the 50 plant alliances? Wildlife habitat values?), 2) how they will be monitored (no methodologies or guidance is 

given), or 3) when and how often they will be monitored (with the exception of the Camissonia benitensis [CABE] 

monitoring plan which lays out monitoring protocols). Importantly criteria for the desired condition are not identified 

(including the CABE Compliance Monitoring & Adaptive Management Plan). While the DRMP/DEIS notes that the 1984 

Hollister RMP provides goals and objectives, it also states that “the 1984 Hollister RMP and CCMA RMP Amendments 

(1986, 1999, 2006) lack detailed direction and are generally outdated” (DRMP/DEIS at pg. I). This DRMP/DEIS is the 

appropriate place to identify these essential metrics including the CABE Compliance Monitoring & Adaptive Management 

Plan. 

Triggers for action if monitoring indicates deterioration of the ecological conditions, natural diversity, watershed condition, 

native plant communities or unique plant assemblages are also not included. Monitoring strategies and triggers for action 

must be included in the DRMP/DEIS in order to be able to evaluate the conditions of the CCMA, detect change and 

implement strategies to properly address those changes including adaptive management strategies (which again are not 

addressed in the DRMP/DEIS). Because the DRMP/DEIS fails to include these important components, it currently fails to 

meet the legal requirements ofFLPMA 43 U.S.C. § 1732(b), 1 732(d)(2)(a). 

The DRMP/DEIS lacks important and consequential consistency throughout the document. For example, SSS-BC 1 (at 

pg.55) is identified as “Maintain all known special status species habitat”, while SSS-BC1 (at pg. 439) is identified as 

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“prohibiting collection of SSS”. These are two very different issues relating to special status species and the intent of this 

measure is not clarified elsewhere. 

BLM Response: Chapter 3 describes baseline conditions. Current management guidance is identified and evaluated under the No Action 

alternative in the DRMP/DEIS. Desired condition criteria for the resources are identified and evaluated under the range of alternative in the 

CCMA Draft RMP/EIS and this PRMP/FEIS. Appendix III and Appendix IV of these documents also include the San Benito Mountain RNA 

Management Plan and CABE Compliance Monitoring & Adaptive Management Plan, which provide additonal details about the ecological 

conditions that would be monitored and triggers for action if monitoring indicates deterioration of the ecological conditions. 

SSS-BC1 (maintain all known special status species habitat) and SSS-BC2 (prohibiting collection of SSS) were inadvertently switched in Table 

4.6-25 in the CCMA Draft RMP/EIS. BLM corrected Table 4.6-25 in the PRMP/FEIS to provide consistency. 

Comment: Plant Monitoring Recommendation 

While we unequivocally support the monitoring of Camissonia benitensis (CABE), the DRMP/DEIS 

fails to present any monitoring strategies for the rest of the rare plants and vegetation alliances. No 

desired condition criteria are proposed and no triggers for action included. 

Clearly these components are basic 

standards in all resource management 

plans, and need to be included here. 

BLM Response: See response to comment above. 

Comment: Wildlife Protection Measures Recommendation 

In general, the management decisions in alternative F and G would lead to much greater protection and recovery of special 

status species than the decisions in any other alternative and the thus the BLM should adopt alternative F or G with some 

qualifications. 

Some of the management actions are still not based on the most recent and best available science. For example SSS-BC4 

(at pg. 55) states “Avoid disturbance, including road construction and recreation activities, within a 0.25-mile radius 

around nesting sites of the California condor, bald eagle, and prairie falcons”. This generalized and inaccurate measure is 

flawed based on unique species specific requirements. It also leaves out golden eagles which are known to or are identified 

to have potential to occur in the project area (DRMP/DEIS at Table 3.6-7). 

For example, the Recovery Plan for the California condor (USFWS 1996) specifically recommends “human disturbance 

should be restricted within 1.6 km (1 mi) of active nest sites”. In addition, the DRMP/DEIS fails to address all of the 

conservation measures necessary to adequately protect species including the California condor. For example, the document 

The appropriate 

issues and data 

should be 

incorporated into the 

DRMP/DEIS. 

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fails to address other California condor conservation requirements including the recommendation for protection of roosting 

sites from the Recovery Plan “California condors apparently will tolerate more disturbance at a roost than at a nest. 

Roosting sites and nesting sites are susceptible to similar disturbance threats, and their preservation requires isolation from 

human intrusion”. 

Despite the DRMP/DEIS acknowledgment that “California condors and bald eagles are expected to increase in frequency 

of sightings as their populations recover from historical declines” (DRMP/DEIS at pg. 187), appropriate conservation is 

not identified. Regardless of distance, a straightline view of disturbance affects raptors, and an effective approach to 

mitigate impacts of disturbance for golden eagles (and other raptors) involve calculation of viewsheds using a 

threedimensional GIS tool and development of buffers based on line of site (Camp et al. 1997; Richardson and Miller 

1997). The DRMP/DEIS must carefully re-evaluate (or in the above cases accurately evaluate) the proposed management 

actions for all of the rare species on the CCMA. 

Another example is with regards to vernal pool and the rare species that inhabit them. The document makes reference to 

“A recovery plan, Vernal Pools of Northern California, is under development”. (DRMP/DEIS at pg. 184). We bring to 

your attention the Vernal Pool Recovery Plan - Recovery Plan for Vernal Pool Ecosystems of California and Southern 

Oregon issued by the U.S. Fish and Wildlife Service in 2008. 

BLM Response: In order to be consistent with the Recovery Plan for the California condor (USFWS 1996), SSS-BC4 has been edited to read 

“Avoid disturbance, including road construction and recreation activities, within a one-mile radius around nesting sites of the California condor, 

eagles, and prairie falcons.” The reference to the vernal species recovery plan has also been edited in this PRMP/FEIS. 

Comment: Land Tenure Adjustments Recommendation 

The Center generally opposes any land disposal and the DRMP/DEIS fails to clearly identify the biological resources on the 

proposed “3,300-acres available for disposal in the Tucker, San Benito River, and Condon zones” (DRMP/DEIS at pg. 127). 

In the past, essential conservation lands for rare species were “disposed” of by the BLM. A full inventory of the resources on 

any proposed disposal lands would need to occur. We do however support land acquisitions with high biologic, geologic or 

cultural resource values. 

-noneBLM Response: Refer to Common Response Section 3D and Section 1.9 of this PRMP/FEIS. 

Comment: Air Quality Recommendation 

While we recognize the importance of the asbestos issue within the CCMA, there are other additional air quality issues -none309
 
 

 

 

 

 

 

 

 

 

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associated with the DRMP/DEIR. Here, the BLM fails to meet its NEPA burden of discussing all environmental impacts of 

the DRMP. 42 U.S.C. § 4332(C); 40 CFR 1508.7. First, it omits from the DRMP/DEIS any discussion or calculation of the 

greenhouse gas emissions from the activities on BLM-administered land within the planning area. Furthermore, the 

DRMPJDEIS fails to discuss the environmental impacts from the greenhouse gas emissions, most specifically climate 

change, that would occur under each RMP alternative. Lastly, the DRMP/DEIS fails to discuss in any meaningful way, the 

impact on both wildlife and human visitors of the massive amounts of PM 10, an estimated 1,700.5 tons per year, that is 

produced by ORV use, driving and mining. 

The DRMP/DEIS should be revised to include a discussion of the current baseline greenhouse gas emissions from within the 

BLM-administered lands in the planning area. It should also be revised to discuss the environmental and health impacts from 

future emissions of both greenhouse gases and particulate matter that would result under the five alternatives, including 

global warming, asthma and others. 

BLM Response: Comment noted. The DEIS (pg. 451) and CCMA Proposed RMP and FEIS (Section 4.7.1.2.2) state the following wuth regards 

to climate change. “This analysis assumes that global climate change will make the planning area warmer and drier by the end of the 

21st century. However, the body of information and predictive models for climate change is in its infancy regarding prediction of site 

specific impacts to areas such as the CCMA, and the plan assumes that knowledge will advance quickly with the current emphasis on 

climate research and model development. As the RMP is implemented, BLM managers would place a continued emphasis on 

research, and studies may include components to assess the impacts of changing climate. In the event that climate change made 

achievement of RMP objectives themselves infeasible, the plan would need to be amended accordingly.” 

ORG-CRS: Coalinga Rockhound Society 

Comment: 

Proposal 

Recommendation 

We realize that 

management of 

the Clear Creek 

area is a 

complex issue. 

We realize that 

We at the Coalinga Rockhounds Society have discussed this and we have come the conclusion that “Alternative A” is the only 

alternative that we prefer along with these following recommendations: 

I. There may be some health hazards in the Clear Creek area. The magnitude of which has not been firmly established. 

Therefore we suggest that an independent laboratory be charged with doing a serious, scientific study, concerning the 

possible dangers of Coalinga Chrysotile asbestos.* 

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the BLM is 

required to 

submit a 

RMP/EIS after 

the EPA has 

determined the 

area to be 

hazardous. As 

concerned 

citizens, we are 

interested in 

only the truth. 

We know that 

under this 

current 

administration, 

the EPA has 

political 

agendas that 

use science that 

may be flawed. 

We suggest that 

the BLM and 

the EPA 

recognize the 

publication by 

Geologist E.J. 

Fowkes, PhD 

published June 

20, 2008, titles 

“Geological 

A. Let the study “precisely delineate” all dangerous asbestos areas. 

B. Let roads through all dangerous areas be sealed. 

C. Let the study include a case study of the many past employees of the asbestos mines and mills that were once in 

operation many years ago. Many of these employees still reside in the Coalinga area 

1. Were they disabled because of asbestosis? 

2. Were they hospitalized with asbestosis? 

3. Are they now suffering ill effects of their work environment? 

(a.) Explain their ill effect, if any. 

II. If there be mercury processing mills where amphibole asbestos was used for insulating pipes or boilers, let that area be 

closed with fences or thoroughly cleaned up. 

III. Let rock hounds make the choice. They have read the reports and understand the risks. Let them decide if they are 

willing to accept the risk of rock hounding in the Clear Creek area. 

*Guidebook to Geological Resources of the Coalinga District California, Second Edition by E.J. Fowkes, PhD, page 52. 

IV. Waver-of-Liability forms may be acceptable for rock hounds. 

V. Let the Condon Peak area, the Joaquin Rock area, the east slope of the CCMA, and many other obviously 

unindustrialized areas be opened with access roads, trails, camping, and toilet facilities. 

A. Let rock hounds be permitted 24/7. 

B. Access restricted, by appointment only, to certain times or dates are not conducive to good public relations and are not 

acceptable. 

VI. Let the public lands with grazing rights leased to local ranchers be completely open for rock hound use with points of 

access at nearest public road. 

A. Los Gatos Road from the Condon Peak access area to Wright Mountain with no locked gates. 

B. The roads that lead to Black Mountain/Joaquin Rocks that are gated by grazing lease holders be opened. 

C. No longer let the grazing lease holders lock out the public so that they may control said lands for their own personal 

recreational benefits. 

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Creek 

Management 

Area, San 

Benito County, 

California”. 

VII. Let areas with endangered species be fenced off. 

VIII. Archeological or sites of historical significance should be viewable but protected from vandals. 

A. This will include hieroglyphics, engravings, paintings, or other artifacts. 

B. High fences, posting signs, and signs explaining the artifacts significance may be required. 

IX. Caves and mine shafts should be posted as “closed” to all visitors to the CCMA. 

X. The CCMA has been used for family activity for decades. Now is a times when “family” is more important than ever. 

Do not exclude people 18 years old and younger. This exclusion policy is generational discrimination. 

A. Allow the youngest of campers, infant through 18, use of campgrounds in and around the CCMA to camp in areas 

deemed safe for camping (ie: Condon Peak, Black Mountain, Lion Canyon, and many others). 

The social and economic impact of opening this area as suggested herein would be phenomenal. The Clear Creek area would 

soon become the most used and sought after place for family recreation in the state of California. The BLM would receive much 

applause and appreciation from everyone for their straight forward management of this complex area 

BLM Response: Comment I: Refer to Common Response Section 1D and 1F(iii). 

Comment II: Under the Proposed Action (HAZ-A3, HAZ-A4. HAZ-BG5, respectively), BLM would identify mining-related and other 

public land hazards and eliminate or mitigate as soon as possible; identify and resolve mining related trespasses with priority given to 

those cases where conflicts are occurring with visitor use and safety; and implement Best Management Practices (BMPs) related to 

Abandoned Mine Lands (AML) and mining activities outlined in Appendix V. 

Comment III and IV: As noted in section 4.2.6.2 of the CCMA Draft RMP/EIS and section 4.2.4.1 of this PRMP/FEIS, “During public scoping, 

authorization of access into the Serpentine ACEC based on signed waivers of liability (i.e. indemnification of risk), was identified as a 

potential mitigation measure to inform visitors of the health risk associated with exposure to asbestos to determine their own 

willingness to accept the risk of exposure to asbestos in CCMA. In other words, this measure would allow individuals to “ride at their 

own risk”, and reflects the preferred approach identified by the majority of the public scoping comments. However, developing a 

waiver of liability, or establishing indemnification of risk, would have no beneficial impacts on public health and safety because 

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neither approach would actually reduce exposure to airborne asbestos or improve overall protection of human health and the 

environment.”
	

Comment V - VIII: Refer to Common Response Section 3D.
 

Comment: IX: See response to Comment II.
 

Comment X: Refer to Common Response Section 3D. The Proposed Action would not restrict access based on age of visitors.
 

ORG-FOCCMA: Friends of Clear Creek Management Area 

Comment: EPA Risk Assessment Recommendation 

The Clear Creek Management Area Asbestos Exposure and Human Health Assessment did not 

achieve the goal of providing BLM with information on asbestos exposures from typical CCMA 

recreational activities. 

The Sampling and Analysis Plan for Asbestos Air Sampling Clear Creek Management Area San 

Benito County, California states that an equal amount of Asbestos Air Samples were to be used from 

each of the three separate “events (dry, moist and wet testing periods) in order to duplicate “typical 

recreational asbestos exposures”. The EPA failed to follow these approved guidelines and complete 

this task. 

The Clear Creek Management Area DRMP/DEIS and the CCMA Asbestos Exposure and Human 

Health Risk Assessment also state nearly 20 times that the goal of the Asbestos Air Sampling was to 

duplicate “typical recreational exposures”. 

The EPA failed to follow these approved guidelines and complete this task. Subsequently the Clear 

Creek Management Area Asbestos Exposure and Human Health Assessment provided data to the 

BLM of atypical visitor use being that the asbestos exposure data was not collected per the approved 

guidelines and subsequently an inordinate amount of samples from the third “event” (dry session) 

were collected and used in the Human Health Risk Assessment, furthermore “pilot” test data was also 

included in the final calculations. 

The Clear Creek Management Area 

Asbestos Exposure and Human Health 

Assessment did not provide the Bureau of 

Land Management with any asbestos 

exposure data representative of “typical 

recreation” (their goal) within the Clear 

Creek Management Area, therefore the 

Bureau of Land Management has no data, 

information or reason to base a closure on. 

Subsequently the Clear Creek 

Management Area must remain “open” to 

all public use. 

The Bureau of Land Management must 

adopt Alternative A (no change) as the 

final Alternative being that the Bureau of 

Land Management has not data 

representing typical recreational 

exposures to naturally occurring asbestos 

within the Clear Creek Management Area. 

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BLM Response: Refer to Common Response Section 1C and 1D. 

ORG-FGMS: Fresno Gems and Mineral Society 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-GRMC: Ghost Riders Motorcycle Club
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-LADBR: Los Altos Dirt Bike Riders
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-LGMC(1) Lemoore Gems and Mineral Club
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -none314
 
 

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BLM Response: Thank you.
 

ORG-LGMC(2): Los Gatos Motorcycle Club
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-RUTS: Racers Under The Son
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments of Steven Craig. -noneBLM Response: Thank you.
 

ORG-RRMC: Ridge Runners Motorcycle Club
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-SRMC: Salinas Ramblers Motorcycle Club
 

Comment: General Comments Recommendation 

The BLM presented me with a very large and technical document to review. While I have tried my best, I find that I cannot 

research and comment on all aspects of this document in the 90 days allotted. 

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Further, I have made several requests for additional information to the BLM. Some have been fulfilled but as of March 4, 

2010 have failed to receive the some of the requested information. 

Specifically, the BLM has failed to provide: 

- Results of sampling from events before 2004 

- History of road maintenance on Ri from March 2004 to October 2005. 

- A spreadsheet with calculations used by toxicologist Karl Ford on which he based a recommendation for an alternative 

that would allow up to five weekends of OHV recreation use per year. 

Regarding the last point, I did receive a spreadsheet titled CCMA Rider Risk2.xls that was forwarded to me by Rick Cooper 

that purported to show Karl Ford’s analysis. The results however did not support the recommendation shown in the attached 

e-mail and the data was laid out in a format using the alternatives listed in the DEIS. These alternatives were not developed 

until after the scooping meeting in May of 2008 so it is unlikely that this spreadsheet is the data Karl Ford used in his 

analysis. 

In the documents the OHV community received via a FOIA request there is an e-mail from Karl Ford dated 2/15/2008 with 

a spreadsheet titled CCMA Rider Risk.xls. It is that spreadsheet that I wish to examine and comment on. 

BLM Response: Refer to Common Response Section 1F and 1G. 

Comment: Purpose and Need – EPA Risk Assessment Recommendation 

What is the problem that the BLM is trying to solve? How many people who have every recreated, worked or lived in or 

near the CCMA have been diagnosed with an asbestos related disease? 

The BLM has not provided any facts in the DEIS to support the statement that there is a significant health risk of recreating 

in the CCMA as evidence by incidents of disease. 

While the EPA’s CCMA Asbestos Exposure and Human Health Assessment (2008) provides new information, it does not 

provide information so compelling that it warrants the emergency closure or the severe restrictions on OHV use proposed in 

the preferred alternative. The EPA analyzed 456 samples in conducting their study. Of these over 60% of the samples, 276 

in total were taken during dates that fall within the existing seasonal closure dates. Of the remaining samples, 151 were 

taken on days in November 2004 during the open use season but in a month that receives, historically, a low amount of 

precipitation compared to other months of the open use season. 

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While there was a rainfall event that preceded the November 2004 sampling, there were several days of dry weather 

between the rain event and the sampling. Prior to the October rain events there had been no significant rain since March 1st 

and 2’, 2004 and total rainfall for the 2003/2004 rain year was below average. 

Only 29 samples were taken during February that, historically, is a wet month. None of these samples were taken in the 

days after a rain!snow event and prior to the February 11, 2005 sampling event there had been 12 days with no or only 

minor (> .05 in) precipitation. 

BLM Response: Refer to Common Response Section 2A. 

Comment: EPA Risk Assessment Methodology Recommendation 

The conclusions and alternatives in the DEIS are built upon information from the EPA’s 

CCMA Asbestos Exposure and Human Health Risk Assessment (2008). This study, while providing 

additional sampling information, is a flawed piece of work that should not be considered significant 

new information for the following reasons: 

The EPA study is a poorly designed study. [Riders spent too much time on Clear Creek Road ]. The sample area was not 

representative of the larger CCMA, and the lack of sampling during the winter month when visitor use is at its highest. 

While not necessarily a fatal flaw, the EPA’s mix of ATV and motorcycle samples is disproportionately weighted towards 

quads when in fact the largest group using the CCMA recreate on motorcycles. 

-noneBLM Response: Refer to Common Response Section 1C. 

Comment: Appendix I Recommendation 

The maps for Alternatives B, C, and D fail to show Sawmill Creek Road, a County road. Maps for Alternatives E, F, and G 

fail to show all County roads. At the time of this comment, the County roads are still public highways and have not been 

abandoned or vacated. 

-noneBLM Response: Refer to Common Response Section 1E. 

Comment: 4.2.4.1 CCMA Asbestos Exposure and Human Health Risk, Page 332 Recommendation 

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The DEIS references “a 1992 BLM Human Health Risk Assessment” yet the BLM fails to identify this document or list it in -none6.0 References. 

BLM Response: Refer to Common Response Section 1F(ii). The 1992 PTI health risk assessment has been added to the list of references in this 

PRMP/FEIS. 

Comment: Visitor Use Data Recommendation 

The information regarding visitor use in table 3 .8-1 shows that demand for the area has fallen since 2003. In addition, 

historic use is well below the historic levels of use seen in the 1980’s. The 1992 BLM Human Health Risk Assessment for 

the Clear Creek Management Area prepared by PTI Environmental Services for the BLM states on page 22: “Although 

exact counts are not available, the BLM has estimated the annual number of visitors to the CCMA for the years 1977 to 

1990 (BLM unpublished). Visitor use appears to have peaked in 1988, when BLM estimated 80,000 visitor-days were spent 

in the area.” 

-noneBLM Response: Section 3.1.4.2 provides visitor use data prior to 2005 based on primitive infrared counters at the two main entrances. The 

program was updated to a modern and accurate traffic counting system in 2005. In 2007/2008, recreation use in the Planning Area was estimated 

at 35,000 visitor days, with about 80% of this attributed to OHVs. BLM determined that recreational use of public lands can be expected to 

increase as population grows, as described in section 4.1.2.1 of this PRMP/FEIS. 

Comment: 4.2.1.1 Assumptions Recommendation 

The BLM has failed to disclose that the EPA toxicologists used the full data set of exposure samples to determine the 

human risk associated with each alternative. The majority of the samples were from dry periods when Clear Creek was 

closed to the public (personal communication from Daniel Stralka, EPA). The use of the September 2005 samples has 

skewed the risk analysis dramatically. 

True single-track trails are very narrow and generally rocky and surrounded by brush. 15-20 mph is an extremely fast speed 

usually attained by the top enduro riders in the country. The average rider would be lucky to attain 12 mph speed on true 

single-track trails. 

The DEIS fails to take into account that many riders who use Clear Creek live outside the area and only visit the area 

perhaps once or twice a year. Clear Creek is recognized as one of the top riding areas in the United States (Dirt Rider 

Magazine, March 2002) and as such attracts visitors from a wide area. 

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BLM fails to take into account that many people who recreate on OHVs do so for only a short time in their lives and then 

life change such as marriage, children, job relocation, injuries, etc. end their OHV pursuits. 

Interviews of people attending meetings will skew the profile of the average user because people attending meetings 

generally represent local users who frequent Clear Creek more often. Users who live outside the area are unlikely to know 

of or attend meetings. Riders who have sold their bike or quad are also unlikely to attend meetings. 

Per the EPA Super Fund Report cited in the DEIS in 4.2.2.3: “Furthermore, census data shows that California Central Coast 

population is highly transitory and includes visitors or residents that travel from long distances or move in and out ofthe 

area at a rate that wouldfurther limit the efficacy of epidemiological studies ofasbestos—related illnesses.” The same logic 

should apply to the BLM’s assumption of average exposure. 

Visitor permit numbers provided by the BLM after the release of the DEIS for the months January to April 2008 seem to 

confirm the above statements. The ration of season passes to weekly passes is roughly 10 to 1. (2,578 weekly vs. 227 

season). (Personal communication from Sky Murphy on 3/2/2010) 

BLM Response: Refer to Common Response Section 1C. Section 3.1 of the CCMA Draft RMP/EIS and this PRMP/FEIS describe visitor use 

trends and forecasts based on a wide variety of user groups. Section 3.2 describes the challenges in calculating risk associated with such a wide 

varierty of visitors and uses noting that “there are assumptions and variables that can cause the calculations to either overestimate or 

underestimate the actual risk.” The EPA risk assessment also contains a detailed discussion of the exposure and toxicity parameters 

which affect the calculations of estimated risk. As such, both BLM and EPA acknowledge that the CCMA Asbestos Exposure and 

Human Health Risk Assesssment (2008) may overestimate or underestimate risk if EPA’s measurements of exposure and the 

assumptions of exposure frequency are either greater or less than actual conditions. 

ORG-SVRGC: Salinas Valley Rock and Gem Club 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you. 

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ORG-SFGMS: San Francisco Gem and Mineral Society
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-SCVGMS: Santa Clara Valley Gem and Mineral Society
 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you. 

ORG-SCGMS: Santa Cruz Gem and Mineral Society 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-SCC: SaveClearCreek.org
 

Comment: Misleading Statements Recommendation 

Pg. IV; Within the paragraph, the phrase “Allowable use restrictions would significantly reduce 

risk to public health and safety” is misleading because it implies that actual risk would be reduced 

definitively. To date, there is no absolute, quantifiable knowledge of the actual risk, but rather only 

estimates of risk that have a wide margin of error based on theoretical approaches. 

Pg. IV; Replace the misleading phrase with 

“Allowable use restrictions would 

significantly reduce estimates of risk to 

public health and safety”. 

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Pg. 16; “Protection of human health and the environment” is the mission statement of the EPA, not Pg. 16, The DEIS must be edited to change 

the BLM. Therefore these statements are misleading and likely to be misconstrued as an attempt by these statements to reflect only the official 

the BLM to expand their mission and duties beyond their legal mandate and/or usurp the and true mission of the BLM: 

responsibilities and powers of other agencies. “It is the mission of the Bureau of Land 

Management to sustain the health, diversity, 

The list of resources is inaccurate and the term resource is used loosely. “Public health” is not a and productivity of the public lands for the 

resource that could derived or extracted from the CCMA unless potential medications were found use and enjoyment of present and future 

there, or physical exercise were obtained. Even if it were a resource as such, it would be far from generations.” 

#1 on the list that the BLM is responsible for. “Safety” does not meet the definition of a resource. 

Safety cannot itself be derived or extracted from the CCMA in any way. “Recreation” is not a Public health and safety must be removed 

resource, although resources are necessary for recreation. from the list of renewable and nonrenewable 

resources. Recreation must be replaced with 

Pg. 22; “Protection of human health and the environment” is not one of the goals listed in the “recreational,” as “recreation” is almost 

Purpose and Need required by 40 C.F.R. § 1502.13, and in accordance with Comment #1 is not a meaningless as a resource but “recreational 

mission of the BLM, it therefore cannot be one of the management objectives being addressed in resources” is very meaningful. 

the EIS. Since the “overall protection of human health and the environment” is not a valid 

management objective for purposes of the EIS, the BLM’s rationale for the determination that land Pg. 22, Remove § 2.2.3 from § 2.2, 

tenure adjustments for the serpentine ACEC would conflict with management objectives is not “Alternatives Considered but Not Analyzed 

valid. Furthermore, since land tenure adjustments (excluding those to acquire private property in or in Detail”. Analyze the concept of 

next to the CCMA) are valid alternatives but have not been addressed in any Alternative, the BLM Serpentine ACEC Land Tenure Adjustments 

has failed to “inform the decision makers and the public of the reasonable alternatives” in detail. Include relevant discussion and 

(40 C.F.R. § 1502.1). analysis in the EIS of land tenure 

adjustments. 

Pg. 190; Since the “overall protection of human health and the environment” is not a valid Add Alternative(s) and/or amend existing 

management objective for purposes of the EIS, it is not appropriate to analyze Air Quality impacts Alternative(s) which include Serpentine 

on human health and the environment in the EIS. ACEC Land 

Tenure Adjustments. 

Pg. 352; “Protection of human health and the environment” is not one of the goals listed in the 

Purpose and Need required by 40 C.F.R. § 1502.13, and in accordance with Comment #1 is not a Pg. 190; Remove the [air quality sections] 

mission of the BLM, and it therefore cannot be one of the management objectives being addressed from the EIS: 

in the EIS. Since the “overall protection of human health and the environment” is not a valid 

management objective for purposes of the EIS, the BLM’s statement that “potential for waivers of Pg. 352, Remove the invalid statement from 

liability or indemnification of risk as ‘stand-alone’ mitigation measures for human health and safety the EIS and replace it with the following 

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do not satisfy the purpose and need for the CCMA RMPIEIS” is not valid. text: “Despite this, if implemented with due 

care, waivers of liability or indemnification 

[BLM DEIS, pg. 352: “Furthermore, these actions would likely have major long-term adverse of risk constitute viable means to permit the 

impacts on human health and the environment due to the perception that exposure to airborne continuation of existing levels of activity 

asbestos fibers above the acceptable risk range established under the EPA Superfund Act is within the ACEC while acknowledging that, 

permissible and authorized by the Federal government.”] although fraught with uncertainty, studies 

and reports on the postulated health risks of 

This sentence says that a mere perception, presumably in the minds of the public, would likely have asbestos in CCMA still have value.” 

major long-term adverse impacts on human health and the environment. Unless the BLM can 

corroborate the existence of ESP and/or telekinesis, this statement is certainly incorrect. Remove the entire incorrect statement 

referred to on pg. 352 from the EIS. 

BLM Response: Pg. IV: Refer to Common Response Section 1D and 4A. 

Pg. 16 & 22: Pursuant to BLM’s Land Use Planning Handbook (Appendix F, page 15), section 1.7 of the CCMA Draft RMP/EIS describes the 

overall vision for the Clear Creek Managemetn Area derived from public scoping. EPA has been a cooperating agency during the development of 

the CCMA RMP/EIS because of jurisdiction by law and special expertise in protection of the environment and human health. The BLM’s Land 

Use Planning Handbook also describes the criteria and benefits of cooperating agency status to establish a formal framework for local, State, 

Tribal, or Federal agencies engagement and active collaboration with a lead Federal agency (i.e. BLM) to implement the requirements of NEPA 

(pp. 6-7). 

. 

In accordance with 40 CFR 1502.13, the CCMA Draft RMP/EIS and this PRMP/FEIS specify the underlying purpose and need to which the 

agency is responding in Chapter 1. 

Pursuant to the Federal Land Management and Policy Act (FLPMA) of 1976, Sec. 102. [43 U.S.C. 1701] (a) The Congress declares that it is the 

policy of the United States that (underline added for emphasis) – 

(8) the public lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and 

atmospheric, water resource, and archeological values; that, where appropriate, will preserve and protect certain public lands in their natural 

condition; that will provide food and habitat for fish and wildlife and domestic animals; and that will provide for outdoor recreation and human 

occupancy and use; 

(11) regulations and plans for the protection of public land areas of critical environmental concern be promptly developed; 

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Pursuant to the FLPMA Sec. 103. [43 U.S.C. 1702] (underline added for emphasis) : 

(a) The term “areas of critical environmental concern” means areas within the public lands where special management attention is required (when 

such areas are developed or used or where no development is required) to protect and prevent irreparable damage to important historic, cultural, or 

scenic values, fish and wildlife resources or other natural systems or processes, or to protect life and safety from natural hazards 

(c) The term “multiple use” means the management of the public lands and their various resource values so that they are utilized in the 

combination that will best meet the present and future needs of the American people; making the most judicious use of the land for some or all of 

these resources or related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing 

needs and conditions; the use of some land for less than all of the resources; a combination of balanced and diverse resource uses that takes into 

account the long-term needs of future generations for renewable and non-renewable resources, including, but not limited to, recreation, range, 

timber, minerals, watershed, wildlife and fish, and natural scenic, scientific and historical values; and harmonious and coordinated management of 

the various resources without permanent impairment of the productivity of the land and the quality of the environment with consideration being 

given to the relative values of the resources and not necessarily to the combination of uses that will give the greatest economic return or the 

greatest unit output. 

Pg. 190: Refer to Common Response Section 1G. 

Pg. 352: See response to Pg. 16 & 22 above. 

Comment: No Action Alternative Recommendation 

Pg. 19; NEPA requires that a “no action” alternative be provided (40 C.F.R. § 1502.14(d)). 

However, the “no action” alternative provided (“Alternative A”) incorporates actions. “Alternative 

A” on page 19 indicates that “it would incorporate new human health information into BLM’s 

public outreach and education asbestos hazard information program” and other programs. 

Pg. 25; 

NEPA requires that a “no action” alternative be provided. However, the ‘no action’ alternative 

provided (“Alternative A”) incorporates actions, including 

 ̈ Use of dust suppressant on roads. 

 ̈ Installing a public vehicle wash facility. 

 ̈ Acquiring lands from private sellers. 

 ̈ Withdrawing the RNA and Clear Creek Canyon from locatable mineral entry. 

Pg. 19; Split Alternative A into a true noalternative action and a second alternative 

which includes the offending actions listed 

in Alternative A. Alternatively, remove the 

actions from Alternative A and incorporate 

them into later EA process(es). 

Pg. 25; If any these actions are permitted 

under a prior EIS or EA, then the 

appropriate document must be referenced to 

indicate that the action is officially 

permitted. 

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BLM Response: Refer to Common Response Section 3B. 

Comment: Purpose and Need Recommendation 

Pg. III; The CCMA comprises 0.3% of the present range of the California C,5ondor and there is no evidence or 

reason to believe that OHV activity would affect the any effort to re-introduce the California Condor, or that it 

would not improve condor habitat, such as by providing more rodent carcasses. The red-legged frog and tiger 

salamander do not exist within the CCMA as stated on DEIS page 185, § 3.6.5.4. Therefore there is no need to 

specifically address these issues in an EIS. This part of the purpose and need is invalid. 

The previous EIS was executed very recently in 2006. The EIS process is very expensive to the government in 

terms of time, money and government employer resources, and very expensive to the people in terms of time 

and money and legal outlays. There is no evidence that there are significant changes in social and economic 

conditions in the stated areas since 2006, nor is there evidence of significant increased awareness and social 

value placed on the cultural and natural resources in the Planning Area since 2006. The area has always been 

valued for decades and continues to be valued in approximately the same ways by the vast majority of 

interested parties and visitors to the area. 

The primary change in social and economic conditions in San Benito County and the San Joaquin Valley as it 

pertains to CCMA was caused by BLM actions beginning May 1, 2008 and could easily be rectified in one 

simple move, without requiring an EIS. 

The need for an EIS is not sufficiently established by the issues in the referred-to paragraph, and the issues in 

the referred-to paragraph are not significant enough to be included in an EIS. 

Remove the paragraph “The 

current management plan does 

not specifically address listing 

and/or additional habitat needs 

for species protected under the 

federal 1973 Endangered 

Species Act (ESA), including 

the California Condor, redlegged frog, and tiger 

salamander.” 

Replace the referred-to 

paragraph with: “Changes in 

social and economic conditions 

in San Benito County, the San 

Joaquin Valley, and the entire 

State of California have led to 

increased demand for use of 

public lands for recreation and 

energy production in the 

Planning Area.” 

BLM Response: Refer to Common Response Section 2B and 2C. 

Comment: Range of Alternatives Recommendation 

The Purpose and Need states that there are increased demands for recreation on public lands within the 

planning area. However, no alternative addresses these needs by enlarging the total available trail mileage 

and acreage available for OHV use. 

Modify each existing alternative so 

that each provides for increased 

recreational opportunities within or 

near the planning area, such as by 

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If the EIS is not modified the BLM will have failed to “inform the decision makers and the public of the designating an equal or greater 

reasonable alternatives” (40 C.F.R. § 1502.1) and will have failed to satisfying the Purpose and Need, number of miles of trails and acres 

which risks causing the corresponding R.O.D. to for OHV activity than the number 

of miles and acres that would be 

 ̈ violate the spirit and regulations of the CEQ and NEPA. closed for each alternative, within 

 ̈ underestimate the public needs in a manner that is severe and foreseeable. reasonable distance of the existing 

 ̈ prioritize unproven scientific estimates of negative consequences over definite, known negative CCMA recreational area and of the 

consequences. central coastal area of California 

 ̈ direct BLM personnel in a way that fails to serve the public according to the BLM’s stated mission. served by the CCMA. 

BLM Response: Refer to Common Response Section 3A. 

Comment: Impacts to 

OHV 

Recommendation 

The negative impacts of Recommendation 1: The EIS must include discussion of impacts of displacing OHV users to other federal and state 

reducing OHV recreation lands. Potential impacts include: 

opportunities in the 

CCMA are not adequately  ̈ Loss of recreational opportunities due to occupancy limits being exceeded at other OHV areas (e.g., early gate 

discussed in the EIS. metering on weekday mornings at Hollister Hills SVRA). 

These include important  ̈ Negative effects of the increasing the travel time to alternate designated OHV areas from the most populous areas 

impacts to other federal of central coastal California from around 3 hours to between 4 to 6 hours each way: 

and state lands designated  ̈ Loss of recreational opportunities and duration. 

for OHV recreation. Such  ̈ Increased fuel consumption, C2O release and highway congestion. 

impacts are directly  ̈ Increased risk of death from being in traffic longer (see Comment #23). 

relevant and must be  ̈ Increased incidence of illegal trespass in CCMA and other areas, and of off-trail riding in established OHV parks, 

included in the CCMA by the public whose demands for recreational opportunities have not been met. 

RMP/EIS because the 

CCMA RMP/EIS process: Recommendation 2: The EIS must include discussion of the impacts of displacing OHV users to other federal and 

1. has immediate and state lands that is caused by decreasing the available area at the same time the overall use trend is increasing, thereby 

predictable consequences increasing density and concentration of OHV use on those lands. Potential impacts include: 

and impacts to these other 

lands.  ̈ Increased localized environmental impact (trail overuse) leading to additional closures and further exacerbating the 

2. directly and root problem and Purpose and Need of not enough OHV recreation opportunities to support the demand. 

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significantly affects  ̈ Increased potential for injury or death due to head-on collisions and other accidents resulting from higher density 

current and potential users use. Such risk may exceed the risks calculated by the EPA for Excess Lifetime Risk of cancer. 

of the CCMA. 

BLM Response: Refer to Common Response Section 4B. 

Comment: Affected Environment Recommendation 

Pg. 116; Soil Resources: This section makes the unsubstantiated assumption that soil disturbance is undesirable by 

concentrating on limited aspects of disturbance. It fails to take into account that soil disturbance may benefit CCMA and 

public lands by several means, including 

 ̈ Assisting the spread of native vegetation through seed transport. 

 ̈ Augmenting the variety and availability of habitat for species that grow in disturbed soils on sandy slopes and along roads, 

including the evening primrose, reducing their 

probability of going extinct. 

 ̈ Improving foraging opportunities for avian and small mammals and dependent species. 

 ̈ Increasing siltation expanding the variety and types of plant and animal habitats available. 

 ̈ Improving recreational value. 

 ̈ Improving cultural and historic value. 

These benefits may offset many of the impacts deemed negative and yet they have not appropriately been considered in the 

EIS. 

State in this 

section that 

changing the level 

of OHV 

recreational 

activity, which has 

maintained with 

care for decades, 

will have unknown 

and unstudied 

effects, including 

negative 

consequences 

including those 

stated above. 

BLM Response: Refer to Common Response Section 1G. 

Comment: Risk Assessment Recommendation 

The exposure durations and visits per year do not represent typical CCMA use patterns. -noneBLM Response: The visits per year actually came from the 1992 PTI Health Risk Assessment and are based on national recreational survey data 

and statements of CCMA users. The 30-year exposure duration is standard for recreational exposures per the EPA Risk Assessment Guidance for 

Superfund. Further, many CCMA users have stated that they have been riding at CCMA for more than 30 years. The risk numbers were expressed 

in ranges to provide information that users could adjust to their personal exposure experience. 

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Comment: Risk Assessment Recommendation 

The most frequent users of CCMA ride solo or in the lead position. If this was taken into account in the risk calculations, the 

Assessment would be more accurate and the numbers would be significantly lower. 

-noneBLM Response: The concentrations measured for lead riders are lower than those measured for trailing riders and solo riding would therefore 

have a lower excess lifetime cancer risk. The risk estimation for workers used lead rider data only. EPA used lead and first and second trailing 

exposures in the analysis because it was believed that group riding more closely represents actual CCMA use conditions. 

Comment: Risk Assessment Recommendation 

The air samplers ran continuously and collected samples when the rider was encountering a dust cloud. In actual practice, a 

rider would avoid or hold his/her breath when traversing a dust cloud. Therefore, the sampling method caused overestimation 

of actual asbestos exposure. 

-noneBLM Response: The sampling pumps do not totally mimic human breathing behavior. The exposures EPA measured can overestimate or 

underestimate actual individual exposures. That is one reason why EPA uses a range of mean and upper confidence limit concentrations. 

Comment: Risk Assessment Recommendation 

The exposure measurement did not take into account the precautions BLM publishes for riding at CCMA, i.e. “If riding an 

OHV in a group, spread out along the trail, and don’t ride in another rider’s dust.” 

-noneBLM Response: The sample collection was designed to capture typical exposures. Avoiding dust would reduce the exposure to trailing riders and 

the overall risk of asbestos-related disease. 

Comment: Risk Assessment Recommendation 

The Risk Assessment overestimates the speed, distance, and time-spent while riding at CCMA. -noneBLM Response: Certainly if someone spends an hour riding, the exposure will be less than someone who rides for 6 hours. The risk factors for an 

individual may be less or more than those shown in the Risk Assessment, based on individual riding practices and exposures. 

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Comment: Risk Assessment Recommendation 

Applying the adjustments noted in Comments 15 through 19 results in revised risk numbers that are within EPA’s 

acceptable risk range. 

-noneBLM Response: Any change in concentration and duration of exposure will change the estimated risk. The EPA risk estimations reflect 

assumptions about exposure and duration in the context of standard EPA risk assessment methodology. 

Comment: Risk Assessment Recommendation 

The OEHHA toxicity value was used in the Risk Assessment and predicts disease in the rider population. Since exposures 

have occurred for decades and no one has shown disease, the OEHHA value is inapplicable and should not be used. 

-noneBLM Response: There are no studies of the rider populations to prove or disprove the assertion that there has not been any asbestos-related 

disease. In fact, a study conducted at the University of California, Davis, and published in the Journal of Respiratory and Critical Care Medicine in 

2005, found that residential proximity to naturally-occurring asbestos is significantly associated with increased risk of mesothelioma in California 

(American Journal of Respiratory and Critical Care Medicine Vol 172. pp. 1019-1025, (2005) © 2005 American Thoracic Society, doi: 

10.1164/rccm.200412-1731OC, Residential Proximity to Naturally Occurring Asbestos and Mesothelioma Risk in California Xue-lei Pan, 

Howard W. Day, Wei Wang, Laurel A. Beckett and Marc B. Schenker). 

Inclusion of the OEHAA value was intended to provide the public with information on the risk range that could be estimated based on the 

measured exposures. It is entirely appropriate for use in assessing risks at CCMA because CCMA is located in California and the OEHHA toxicity 

value is the State of California value for asbestos exposure. As with all toxicity values, it is a standard risk model that does not predict individual 

outcomes, and therefore may or may not reflect disease rates in specific populations. 

Comment: Preferred Alternative Recommendation 

Alternatives B through G fail to meet the Purposes and Needs as stated in the DEIS in at least the following ways: 

 ̈ They fail to address the “increased demand for use of public lands for recreation” Thousands of people and families count 

OHV and other forms of recreational opportunities inside CCMA and inside the ACEC as a critically important part of their 

quality of life. It is risky to human quality of life and happiness not to increase such opportunities, and especially to reduce 

them, by overemphasizing unknown risks to public health and safety, and overestimating them due to flawed scientific 

research. 

 ̈ They fail to “establish goals, objectives and management actions ... that address current issues, knowledge, and conditions” 

Change the EIS to 

state that 

Alternative A is 

the BLM’s 

preferred 

alternative. 

Change the 

appropriate 

discussion sections 

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comprising, among other things, recreational values, partly because they do not analyze the EPA’s CCMA Asbestos of the document to 

Exposure and Human Risk Assessment (2008) in a manner appropriately differentiating acceptable risk arising from a indicate why. 

recreational activity as opposed to acceptable risk according to public workplace, living place, or passive recreational 

standards. Many forms of active recreation carry risks that in general dwarf a 1 .OE-04 Excess Lifetime Risk level, making it 

relatively insignificant. 

A few examples of such activities include: scuba diving, cave diving, skydiving, car racing, motorcycle racing, street cycling, 

skiing, rollerblading, skating, snowboarding, rock climbing, parachuting, paragliding, parasailing, surfing, bungee jumping, 

gymnastics, etc. These higher risks are deemed acceptable as long as they are known by the participant or their guardian and 

these activities are not banned because they are deemed important to the mental health of participants and it is the 

participants who evaluate the risk vs. value proposition. 

They fail to “establish goals, objectives and management actions ... that address current issues partly because they do not 

analyze the EPA’s CCMA Asbestos Exposure and Human Risk Assessment (2008) in a manner appropriately differentiating 

the rights of the willing participant safety from public bystander safety. 

Specifically, in nearly all recreational activities, when a third party is not involved, evaluation of the risk vs. value 

proposition is left up to the participant, and when a third party is involved and providing a service, the third party takes 

reasonable and appropriate steps to guard against assumption of liability. Examples of that are requiring hiking permits in 

national parks, requiring liability waivers to be signed by participants at race track events, acquisition of insurance, taking 

reasonably practical safety and informational measures, etc. Banning of such activities is not normally considered and is 

inappropriate because of the incommensurate damage to human rights and happiness. 

They fail to meet intentions of “identifying regional issues, and resolving those issues through public, inter-agency, and 

intra-agency scoping efforts.” This is because the primary regional issue has plainly been identified at the BLM scoping 

meetings and public feedback to be an intense demand by the public to engage in OHV recreational activity that has been 

denied by the BLM, and which would continue to be denied based on the BLM’s choice of the preferred alternative stated in 

the EIS. Any of the Alternatives B through G are detrimental to resolving this issue as far as they would cause numerous 

lawsuits, negative feedback, and fighting between the public and the government for years, if not indefinitely. 

They do not address “listing and/or additional habitat needs for species protected under the federal 1973 Endangered Species 

Act (ESA) “18 because the primary content of the actions within the alternatives is the reduction or elimination of OHV 

activity, and such reduction does not address species protection in any verifiable way, and may cause more harm than 

benefit. That the habitat status without OHV activity would be significantly more or less desirable than the habitat status with 

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OHV activity, and that the habitat situation was not adequately addressed by previous environmental assessments and impact 

statements, are not established facts. Nor is the core idea that “reduced impacts” are “beneficial” an established fact. 

They are unsuitable for use in a BLM EIS as they clearly fail to accomplish the BLM mission to sustain the health, diversity, 

and productivity of the public lands for the use and enjoyment of present and future generations, comprising BLM 

responsibilities of which the Purpose and Need must be a subset: 

o That the health of public lands is endangered is not established because only a narrow definition of “health” is considered 

by the EIS, not including mental health and health benefits of active recreation. 

Furthermore, EIS Alternatives B through C would not demonstrably address the natural health of public lands in any 

significant way from a natural perspective because spindly roads, trails and staging areas affect negligible amounts of the 

total acreage under consideration in the ACEC and CCMA. 

o Alternatives B and C would have no discernible effects on the diversity and productivity of the public lands, while 

Alternatives D through G would reduce the diversity and productivity of the public lands because they would directly reduce 

the number and scope of distinct activities within the CCMA while not directly offsetting the reduction with any new distinct 

activities, introduce new wildlife species, or 

introduce anything else on a discrete basis that can be considered to be additions to diversity. 

o It would severely reduce the use and enjoyment of public lands by present and future generations, rather than sustaining the 

public lands in a manner consistent with its use and enjoyment. CCMA is enjoyed by present and future generations, 

especially with regards to the most popular and dominant activities (OHV recreation, through-riding, prospecting, etc.), and 

elimination or reduction of these activities will reduce the use and enjoyment of public lands. 

The EIS must not specify a preferred alternative that clearly does not satisfy the Purpose and Need and which is not the best 

alternative according to the copies evidence discussed in these Comments and those of the vast majority of the public. 

BLM Response: Refer to Common Response Section 2A and 3A-3D. 

Comment: Impacts to Public Safety Recommendation 

The DEIS has overlooked an important aspect that affects the overall health risk by considering only asbestos-related risks 

and not discussing or taking into consideration other important risks that comprise a similar Excess Lifetime Risk to the 

Incorporate the 

above information 

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Excess Lifetime Risk of developing asbestos-related cancer that would be mitigated by reduction or elimination of OHV above into one or 

recreation within the CCMA. more of the 

referred-to 

The CCMA is within a 3-hour drive of populous areas constituting most of the 35,000 visitors per year. Elimination of OHV sections of the EIS 

user will require central coastal CCMA users travel further to reach substitute recreation opportunities. They will have to as necessary to 

drive far north to areas such as Stonyford and Middle Creek (4 hours), far west to areas around Tahoe (5 hours), or far south convey the risk 

to areas around, for example, Jawbone (6 hours). Conservatively, they will have to drive at least an extra 1.5 hours (90 miles) information 

each way. crucial to public 

health and safety. 

The expected increase in miles driven can be calculated as follows: 35,000 visits/year, times 30 years (the EPA’s average 

lifetime assumption of 30 years use of CCMA), times 180 miles/visit (the expected increase in highway miles driven per 

visit), or 189,000,000 miles. 

Based on the NHTSA statistic of 1.05 fatalities per 100 million miles driven 21,189,000,000 additional miles driven will 

cause 1.98 additional fatalities over the equivalent lifetime period. 

BLM Response: Refer to Common Response Section 1G. 

ORG-TMC: Timekeepers Motorcycle Club 

Comment: 1992 CCMA Risk Assessment (PTI) Recommendation 

1992 study did not include statistical information from t..germane studies... about the mill and mine workers at CCMA . 

[BLM] has no rationale for changing the existing Plan and should revert to the existing plan. There is no purpose or need to 

change the existing plan, and the Emergency Closure should be removed 

-noneBLM Response: The risk assessment prepared in 1992 is not an EPA document. Rather it was prepared by the consulting firm known as PTI. As 

described in Chapter 1, EPA expressed concerns about the technical deficiencies of the 1992 PTI health risk assessment during the revision of the 

Hollister RMP in 2004. In particular, the EPA toxicity factor for asbestos is based on the review of 14 epidemiological studies of asbestos-related 

disease and death and combines risks from both lung cancer and Mesothelioma. Whereas, the URFs derived in the 1992 PTI report are flawed and 

do not combine both endpoints. Therefore, BLM agreed to work with EPA and the public upon completion of the study to incorporate the new 

health risk information into public land use decisions for the area. (DEIS pg. 1) Accordingly, The purpose and need for the CCMA Draft 

RMP/EIS states that “EPA’s CCMA Asbestos Exposure and Human Health Risk Assessment (2008) provides significant new information that 

must be incorporated into a land use plan to evaluate the public health risk associated with BLM land use authorizations.” (DEIS pg. 4) 

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Comment: Lack of Evidence Recommendation 

No epidermal or forensic evidence to confirm the health risk of naturally occurring chrysotile asbestos from the serpentine 

soil and rocks to produce any type of cancer? The risk assessment has been taken as a statement of fact, when it is only an 

incomplete analysis (1502.22) based on some occupational models adjusted to look like they have some sort of meaningful 

relationship to recreational usage at CCMA. The truth is risk assessment is a fancy way of saying a wild guess of what the 

future may be. Many times statistics have been used to circumnavigate the truth or lack of it. Statistically it can be shown 

that there’s a higher probability of dying, when driving to and from CCMA than recreating at CCMA. 

Motorcycle riding is not only a recreation it’s also a sport the same as baseball, football, soccer or gymnastics. If the same 

risk assessments were placed on any of these sports none of them would be below the 1,000,000 to 1 percentage that the EPA 

is saying must be met to insure the safety and health to the public .The BLM take into consideration a risk assessment that 

fits the definition of “No Significance “and uses it to exclude any and all alternatives that may have been considered for 

CCMA. 

This decision has failed to find a reasonable balance between theoretical information and the value of motor recreation 

1502.22(a), (3, and 4). 

[Referring to DEIS, Sec. 4.2.3 Overview of Impacts of Hazardous Materials on Public Lands] This is conjecture, since other 

scientific literature states otherwise. Only the EPA report comes to this conclusion, this shows no balance in the accurate 

scientific analysis. 

-noneBLM Response: Refer to Common Response Section 1F(i). 

Comment: No Action Alternative Recommendation 

The No Action alternative is the only alternative that must be analyzed in an EIS that does not respond to the purpose and 

need for the action. The BLM ‘s version of a” No Action Alternative” has incorporated no less than 5 major changes to the 

RMP/EIS which clearly shows no respect of the rules and violates NEPA 6.6.2, ruling concerning the no action alternatives. 

The BLM defines Alternative A as (Alternative A represents the ‘No Action’ alternative and would reaffirm current 

management under the 1984 Hollister RMP (as amended). BLM would incorporate new health risk information into public 

outreach and education asbestos hazard information program to mitigate public health risk.) When in fact they have added 

changes in trail use, multimillion dollar wash facility, removed rights of miners to enter their mining claims, added seasonal 

restrictions, even a plan to reseed the staging areas with evening primrose an endangered species. How can they even 

Correct the DEIS 

to reflect the actual 

no action 

alternative as 

required by law, 

not a modified 

version as is 

currently in the 

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consider this a no action alternative? DEIS. 

Page 25, there is no present application of dust-suppressant, so this has been added. If this is all that is required to 

incorporate the new EPA report, then just do an EA to amend the existing ROD. 

Page 25 also states the BLM will acquire state lands and private in-holdings from willing sellers through acquisition or 

exchange. This is not in the current management directive, as the BLM has consistently stated they will not acquire 

additional lands within CCMA due to them not being allowed to acquire any additional “contaminated” lands. 

Page 25 states they will allow no mineral leasing or sales within Clear Creek Canyon, and will withdraw the RNA and Clear 

Creek Canyon from locatable mineral entry. This is also not the existing condition, and is being added in this DEIS. 

BLM Response: Refer to Common Response Section 3B. 

Comment: Purpose and Need Recommendation 

There is no need or purpose for a new RMP for CCMA. There appears to be only one The purpose and need statement needs to be rewritten 

change since the 2006 Decision, that’s the EPA report. There is no reason to reopen all of to better define the word ASBESTOS . Thought out 

the issues that were settled in the 2006 decision. The temporary closure of the CCMA this document (Draft RMP/EIS) the word 

should be removed and the 1984 Hollister RMP with Amendments (1986, 1999, and ASBESTOS has been used as naturally occurring 

2006) should be enacted. asbestos which is an oxymoron there is no natural 

asbestos .asbestos is a manufactured product. The 

The new information has no conclusions in it which to make a fair and informed decision only natural material in question is serpentine rocks 

upon exposures to natural chrysotile deposits. Epidemiological studies are mentioned but made up of mostly chrysotile deposits. 4OCFR 

are not cited or given as evidence. If this Purpose and need statement is to be left in the 1500.2 (b) 

draft it needs to be changed to something that has to do with asbestos products brought 

into CCMA not the serpentine soil that’s there. In accordance with the National Environmental 

Policy Act (NEPA), alternatives must: meet the 

Decreasing the area available for recreation doesn’t address the “need “Thus, none of the purpose and need, as identified in Chapter 1; be 

alternatives addresses the need for this increased demand. All of the alternatives actually viable and reasonable; provide a mix of resource 

reduce the land available for recreation, not increasing it. The stated purpose and need for protection, management use, and development; be 

increased demand for public land for recreation are contradicted within the document by responsive to issues identified in scoping; and meet 

all alternatives which decrease the amount of land available, not increasing the amount the established planning criteria (also identified in 

available, which would satisfy the stated need. Given that the historic use of the area is for Chapter 1), federal laws and regulations, and BLM 

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recreation, none of the alternatives satisfy the stated purpose and need. planning policy. 

The BLM states a purpose of the CCMA DEIS is to address “Changes in social and The document and the SLM acknowledge that the 

economic conditions in San Benito County, the San Joaquin Valley, and the entire State of public overwhelmingly identified continued use of 

California”. the area for recreation as the overwhelming number 

one issue, yet the agency failed to include that 

The BLM has failed to show why or how a decrease in visitor usage requires a new priority in the purpose and need. The document also 

Management Plan or EIS for CCMA. Furthermore, the BLM has failed to show why or fails to address the public’s number one issue, which 

how energy production, which is not currently planned for the CCMA and is included in is continued access to CCMA for recreation. 

the 1984 Hollister RMP and the 1993 Oil and Gas Amendment requires a new CCMA 

Management Plan or EIS. The BLM has failed to document in the DEIS why the CCMA The following needs to be placed in the PURPOSE 

DEIS should address issues pertaining to the San Joaquin Valley and the entire State of AND NEED: 

California. 

Enhance and maintain the public’s access to high 

Based on [these comments] the BLM has failed to follow NEPA process which requires quality recreational opportunities, satisfying the 

the BLM to develop a proposal to address a need or action. The BLM’s content in the overwhelming increased demand for use of public 

November 2009 CCMA DEIS fails to document any of the purpose and needs listed in lands for recreation. Maintain CCMA’s historic use 

paragraph 1.1 of the document. This makes the November 2009 DEIS invalid. of providing a unique and challenging recreational 

opportunity for OHV’s. 

BLM Response: Refer to Common Response Section 2A – 2C. 

Comment: Other Available Information Recommendation 

In reference to a list of documents regarding chrysotile exposure. 

“The BLM’s omission of these studies in any of its analysts is evidence by their acknowledgement of them in 

the scoping report but no mention of the studies in the RMP goes to show no balance of analyst. These studies 

need to be included into the RMP to produce a more balanced analyst of the risks of Chrysotile type 

asbestos.” 

The EPA also published in December 2008 that Chrysotile asbestos is significantly less potent than 

amphibole asbestos, a position also held by the World Health Organization. Even though this was published 

prior to the release of the DEIS, this change in stance by the EPA is not reflected in their report. 

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BLM Response: BLM and EPA are aware of the documents that are referenced in the Timekeepers comment letter. While there is debate in the 

scientific community regarding the mode of asbestos toxicity, there is no debate among health experts and agencies that chrysotile asbestos 

exposure causes cancer and non-cancer disease. In 2008, EPA requested that the external Science Advisory Board (SAB) review an approach to 

address toxicities from various mineral forms of asbestos. The objective of the proposed approach was to investigate the influence of asbestos 

mineral types and fiber dimensions on estimates of cancer potency derived from epidemiological data. The Board agreed that mineral type and 

dimension are important determinants of asbestos toxicity, and that an effort to examine the relative contributions of these characteristics to 

asbestos toxicity was worth pursuing. However, the Committee found that the available exposure data was not robust enough to support the effort 

EPA proposed. In light of the Board's concerns, the EPA Office of Solid Waste and Emergency Response decided not to pursue the effort 

. 

The effort to examine the toxicity of various asbestos mineral forms and dimensions was in no way predicated on scientific evidence that 

chrysotile asbestos is benign. On the contrary, the evidence continues to support EPA’s position that chrysotile is a known human carcinogen and 

causes debilitating and fatal non-cancer disease. The serious health impacts of chrysotile exposure are recognized by the Centers for Disease 

Control, the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, the World Health 

Organization International Agency for Research on Cancer, and others. Recent follow-up studies of North Carolina textile workers confirmed the 

strong relationship between estimated exposure to chrysotile and mortality from lung cancer and asbestosis. M. Hein, L. Stayner, E. Lehman, J. 

Dement. Follow-up study of chrysotile textile workers: cohort mortality and exposure-response Occup Environ Med 2007; 64:616-625 doi: 

10.1136/ oem.2006.031005. Additional studies of the textile workers confirmed “that workers exposed to chrysotile are at increased risk of 

mesothelioma, as well as lung cancer.” Loomis D, Dement JM, Wolf SH, Richardson DB. Lung Cancer Mortality and Fiber Exposures among 

North Carolina Asbestos Textile Workers, Occupational and Environmental Medicine, published online March 11, 2009 by the BMJ Publishing 

Group Ltd. 

Comment: Social and Economic Conditions Recommendation 

[Impacts]The Hollister Field Office (HFO) incorrectly states because the number of people and size of the 

economy associated with that population dwarf any of the social and economic contributions that might be 

made by public land resources. This is only an assumption on the part of HFO. The public outrage from 

closing CCMA may be proof of the social contribution these public lands have on the public. With lack of a 

survey or any baseline to make an informed judgment this statement should be removed. 

[Goals and Objectives] The Agency states they will provide for customary uses, but no customary usages are 

stated. Customary uses have been recreation and mining. When the KCAC mine closed, the last active large 

mine in the area. OHV usage has become the dominant use from the 1970’s (page 205) to the present. 

Add that the customary uses since 

the mid 1800’s have been mining, 

and from the 1960’s have also 

included dirt bike riding. Since 

the mid-1970’s motorized vehicle 

recreation has been the dominant 

public use within the area. It 

should also be noted that the area 

was previously known as the 

Clear 

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Page 74 states: “SOCEC-Al. Protect and conserve natural values while allowing for tourism and commodity Creek Recreation Area. 

use of natural resources.” 

Change the paragraph to read: 

Since the closure of CCMA area the commodity use of the area has increased tenfold with the illegal SOCEC-Al. Protect and conserve 

cultivation of marijuana which is higher in customary usage than tourism has ever been. natural values while allowing for 

continued use for its historic use 

Why this section talks about tourism is not understood since tourism is not a major part of its customary as a recreational area for dirt 

usage. Tourism historically is a minor customary use of the area at best. Unless there referring to page 273 bikes, 4-wheeling, rock and 

which states: Discussions with area residents, public land users, and BLM staff indicate that, in fact, mineral collecting, tourism, and 

recreationists come from all over California and the U.S. to recreate in CCMA. commodity use of natural 

resources. 

Page 205 states: “Since the mid-1970’s motorized vehicle recreation has been the dominant public use within 

the area.” 

3.15.4.4 BLM Contribution to the Local Economy 

This whole section is not relevant to CCMA because it tries to generalize too much by adding other public 

lands administered by the BLM, Forest Service, the National Park Service, and California State Parks into the 

discussion. It is all meaningless assumptions or unrelated facts just bulk that is outside the scope of this 

document, the whole thing should be deleted. 

BLM Response: Refer to Common Response Section 4B and 4D. 

Comment: Soil Erosion Recommendation 

Pg. 2; Human disturbance to the soils and plants in the serpentine ACEC is a special management concern, 

because throughout the ACEC, soil formation tends to be slow and the topsoil shallow. Plant regeneration is 

also slow, and accelerated erosion from human activities has negatively impacted soil and vegetative 

resources over the years. 

There is no evidence of data supporting the assertion that there is accelerated erosion from human activities 

within the CCMA. There is also no supporting data indicating there is accelerated erosion of any kind. BLM 

photographs of the area from the 1930’s show the area to look nearly identical to what it currently looks like 

now, not to bad for 80 years of use. 

Delete the following from the 

paragraph: “, and accelerated 

erosion from human activities has 

negatively impacted soil and 

vegetative resources over the 

years” 

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BLM Response: Section 3.8.4.2 of the CCMA Draft RMP/EIS and this PRMP/FEIS describe soils and two soil erosion studies conducted by PTI 

Environmental Services (1993) and Dynamac Corporation Environmental Services (1998) in the CCMA. As noted in this section, “PTI’s best 

management practice recommendations for erosion and sediment control included limiting OHV access to soils having high erosion risk.” Section 

4.8.10.2 of this PRMP/FEIS provides additonal information on BLM funded research and field studies during the mid-90’s on the roads and trails 

network in the CCMA to evaluate road related erosion and sediment problems for over 100 miles of roads and trails in the CCMA and to 

determine which barrens are at most risk due to accelerated erosion which delivers increased sediment to surface water. 

Comment: Special Status Species Recommendation 

Pg. 53; Conflicting statements, and an omission error: 

SSS-A1. Establish appropriate levels of surface disturbance to protect special status species and their 

associated habitats. 

SSS-A11. Rehabilitate (by ripping and/or pitting) potential habitat areas for the San Benito evening primrose 

in Clear Creek Canyon. 

SSS-A12. Initiate an ecological study of the San Benito evening primrose to determine habitat requirements. 

The first statement is correct in that it is known that the San Benito Evening Primrose needs disturbed soils to 

thrive. There are already many areas of San Benito evening primrose in Clear Creek Canyon to replace the 

other inhabitants without a proper study is wrong. 

Supply the missing data, or delete 

the SSS-All and SSS-A12 

statement and just delete SSS-Al. 

BLM Response: Refer to Common Response Section 1G. 

Comment: Transportation Management Actions Recommendation 

DEIS page 47, states: TRANS-FG3. Decommission Clear Creek Road (Ri), and reclaim closed roads to 

protect sensitive resources, reduce sediment transport, and control erosion. 

Clear Creek Road (R1) is a county road, which the BLM does not have the authority or legal right to destroy. 

Remove this statement from the 

DEIS 

BLM Response: Refer to Common Response Section 1E and 3D. The Proposed Action considered in this PRMP/FEIS would designate Clear 

Creek Road (i.e. R1) as “open” to highway-licensed vehicles. 

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Comment: Affected Environment Recommendation 

CEQ regulation 1502.15 requires that the DEIS shall describe the affected environment. Supply maps and tables 

Nowhere in the document is CCMA described. The executive summary, page 1, states the HFO manages describing these lands, along with 

approximately 63,000 acres of public land within the 75,000 acre CCMA. The 30,000 acres within the Area identifying non-BLM lands and 

of Critical Environmental Concern (ACEC), which is highlighted on many of the maps, so is well understood. whether they are private, state, or 

What is not understood is exactly where the remaining 45,000 acres are. The DEIS also doesn’t describe other government owned lands. 

where the 12,000 acres of non-BLM land is located, and exactly who owns this land. 

This is a serious omission error since it can’t be determined exactly what areas are being affected by the Add a statement on page 1 that 

document if they are not accurately described. this DEIS only affects the 

approximately 63,000 acres of 

CCMA, as known to users only includes the 30,000 acres within the Area of Critical Environmental Concern. public land, with no affect to the 

The term CCMA doesn’t apply to the remaining area in the public’s eye or understanding. I believe that is remaining non-BLM managed 

why the DEIS refers to these other areas as Condon Peak, Tucker Mountain, and the Cantua zones, since they land. 

are not part of what the public knows as CCMA. 

BLM Response: The CCMA RMP/EIS describes the 'planning area' and the 'decision area' in Section 1.2 of the CCMA Draft RMP/EIS and this 

PRMP/FEIS to help define the term "Clear Creek Management Area". The affected environment is described in Chapter 3, including all the public 

lands in the Serpentine ACEC and four (4) non-ACEC management zones that are introduced in Section 1.2.1. Maps of the public lands and the 

private lands that are in the planning area are also included in Appendix 1 of the CCMA Draft RMP/EIS and this PRMP/FEIS. 

Comment: Alternative D Recommendation 

This alternative promotes developing trails where the BLM admits there is no public access, nor do they see 

any access in the foreseeable future. CEQ regulation 1500.2(e) requires the alternatives to be reasonable. It is 

not reasonable to propose an alternative that requires access, but the agency acknowledges there is no access, 

nor do they see any public access in the foreseeable future. 

The DEIS should have provided details on how access will be obtained, the timeframe for this to occur, and 

other details to determine if this is feasible or cost effective. 

Developing 60 miles of trail in the Cantua, Tucker, and Condon areas isn’t reasonable, nor acceptable, thus 

violates NEPA. Condon is south of CCMA, Tucker is north, and Cantua is south of Idria. None of these areas 

connect, so the trail network couldn’t be connected, making the proposed trail network worthless. In addition, 

Since Alternate D is impossible to 

analyze, and doesn’t appear to be 

reasonable nor feasible, Alternate 

D must be deleted from the DEIS. 

Correct Alternative D to show its 

predicted vegetation loss is 

greater than Alternatives A-C. 

This same or similar error is 

repeated in most of the Tables in 

this section and all need to be 

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the BLM acknowledges on page 127, table 2.6-14 that there is no public access to the Tucker Mountain area, corrected. This includes table 4.4­

and there is no foreseeable public access. 8 for noxious weeds. 

Building 60 miles of disconnected trail is not an equivalent replacement for CCMA which has over 200 miles 

of existing trails that all connect. Replacing over 200 miles of trail with 60 is not a viable trade. Alternative D 

must increase the mileage of trail to be considerably closer to the existing mileage to be considered even 

remotely equivalent to the existing recreational opportunities present in CCMA. 

DEIS Table 4.4-2 

This table lists major detrimental effects for Alternative D for nonserpentine areas, yet predicts that 

vegetation loss is less than Alternative A. Alternative A would continue usage on existing trails, thus would 

be no change for Alternative A, which the table reflects. Building 60 miles of new trails, which would require 

vegetation loss over the entire 60 miles of new trails absolutely has to be more than using the existing trails in 

Alternative A, which would result in no vegetation loss. 

The table is wrong, and needs to be corrected to reflect actual results. These tables indicate a strong anti-OHV 

bias, as their conclusions are obviously wrong, with the intent for them to give the result desired, not the 

scientific facts. 

Table 4.4-8 on page 379 again shows a strong anti-OHV bias with the results of predicted vegetation 

disturbance levels at the bottom of the table being obviously incorrect. Since most of the noxious weeds can’t 

live in the serpentine area due to its harshness or toxicity, then the noxious weed problem will be a much 

bigger problem in Alternate D, where trails are created in the non-serpentine soils where the noxious weeds 

can thrive. 

DEIS page 426, movement of Noxious weeds. Since noxious weeds can’t grow in the serpentine region, and 

they thrive in the non-serpentine regions, then alternate A would have less impact than D since alternate D 

would and is shown to have major increases of movement of noxious weeds. This again shows the lack of 

scientific thought and reason, along with bias against OHV in the DEIS. 

Alternative D reads “Emphasis would be on developing 0HV recreation opportunities on public lands near 

‘Tuicker Mt., Condon Peak, or San Carlos Bolsa (Cantua Zone), where appropriate,” but fails to describe 

what is “appropriate”. Alt. D also fails to adequately discuss what environmental consequences would occur 

with construction of trails, roads, and campgrounds. 

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Response: Refer to Common Responses Section 3C. 

Comment: Range of Alternatives Recommendation 

Not considering designation of CCMA as an ‘Open’ area in the range of alternatives 

unless posted limited or closed use (2.2.3.). as the no action alternative is clearly a 

violation CEQ 401502.14 (d) and NEPA (6.6.1.1) Using the EPA’s risk assessment as 

reason not to consider this alternative is not relevant. 

DEIS page 150, Table 3.3-1 lists the estimated costs for dust mitigation for unpaved roads. 

While the technologies are viable, they are not reasonable from a financial point of view. 

Every alternative specifies dust suppression, reference page 32, Table 2.4-1. 

Since the addition of dust suppressants isn’t financially reasonable, its inclusion on every 

alternative violates NEPA policy. 

Leave table 3.3-1 in the document to show the costs 

and technologies available, but state that costs are 

prohibitively not cost effective, and delete the dust 

suppression from every alternative. 

BLM Response: The Draft RMP/EIS explains on page 20 that the alternative to designate CCMA an ‘open’ area for OHV use was considered, but 

not analyzed because “this type of designation would not meet the purpose and need for this RMP/EIS to minimize human health risks from 

exposure to asbestos and reducing airborne asbestos emissions from BLM management activities. The Federal government has concluded that all 

forms of asbestos are hazardous to humans, and that all can cause cancer; although the chrysotile form may be less potent than the amphibole 

family in causing mesothelioma (U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and 

Disease Registry, Toxicological Profile for Asbestos)”. 

Comment: Traditional Cultural Property Recommendation 

While it does appear that the BLM and the DEIS have recognized CCMA for the value the 

public places on the area, and have acknowledged its cultural value to the OHV 

community, they have failed to protect our traditional cultural use and value in any of the 

alternatives presented. 

Not only is the area of high cultural value, with almost religious value for many of the 

local users, it is well known within the OHV community. 

While the outside users may not be coming for its cultural value, they are attracted to the 

Add to the purpose and need on page III and page 4 

the following statement: 

Maintain the traditional cultural usage ofthe area, and 

to get CCMA listed in the NRHP for the three groups 

that consider this area a TCP, the California native 

community, the OHV community, and the Gem and 

Mineralogical Society. 

The purpose of getting the area listed is to ensure its 

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area due to its unique and challenging recreational experience. continued viability to the affected groups. 

BLM Response: Refer to Common Responses Sections 2A , 2B, 2C, 3A and 3D. The purpose and need statement contained in Chapter 1 (Section 

1.1) of the CCMA Draft RMP/EIS and this PRMP/FEIS includes designation of areas in CCMA for motorized and non-motorized recreation 

opportunities. Listing a traditional cultural property (TCP) to the National register of Historic Places (NRHP) does not afford automatic protection 

of the TCP for the use of the group that values the TCP, nor does it provide for exclusive use of the TCP. 

Section 4.2.1.1 of the CCMA Draft RMP/EIS and this PRMP/FEIS identify assumptions incorporated into the analysis of human helath risks 

associated with allowable uses in the Serpentine ACEC. Based on the assumption that “Risk calculations for hiking and hunting would be 

representative of all non-motorized use (i.e. rockhounding)”, the traditional use activities practiced by the Native American community and the 

rockhounding community would continue to be allowable uses in the Serpentine ACEC undet the BLM’s proposed resource management plan. 

Comment: Risk Assessment – Uncertainty Recommendation 

The e-mail “...from Rick Cooper to Arnold Den and Jere Johnson of the EPA casts serious doubts about the 

scientific accuracy of the EPA report. Rick Cooper writes that the EPA has been consistent in mentioning that 

the risks could be much lower and perhaps zero. When the final EPA risk assessment was released, the words 

“and perhaps zero”, were omitted.” 

-noneBLM Response: All risk assessments contain a discussion of the uncertainties inherent in the risk estimation and the effect that those uncertainties 

may have on overestimating or underestimating the actual risk. Theoretically, at the extreme end of the spectrum, the uncertainties related to the 

factors which go into an assessment of risk could be such that the assessment predicts a risk where an actual risk does not exist. This was 

recognized, for example, in the EPA Guidelines for Carcinogen Risk Assessment (Federal Register Vol.51, No. 185, September 24, 1986, pages 

33992-34003), which states in the discussion of the use of a particular procedure to predict cancer: “Such an estimate, however, does not 

necessarily give a realistic prediction of the risk. The true value of the risk is unknown, and may be as low as zero. The range of risks, defined by 

the upper limit given by the chosen model and the lower limit which may be as low as zero, should be explicitly stated.” So the terms “as low as 

zero” or “perhaps zero” are used to describe the far end of the risk range for assessments with large uncertainties. 

In the case of the CCMA Risk Assessment, the phrase “perhaps zero” was carried over as a standard expression of the uncertainty inherent in risk 

assessment. When Rick Cooper pointed out its inclusion, EPA realized that the phrase was not applicable to the assessment of the risk posed by 

the asbestos exposure at CCMA, and the phrase was removed. In fact, EPA believes that the risk detailed in the CCMA Assessment is significant 

and of concern. 

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The exposure and risk information used in the CCMA Assessment has less uncertainty than the information used in many assessments. The 

exposure data was comprised of asbestos concentrations in the breathing zone during actual CCMA activities, not hypothetical exposures 

extrapolated from general sampling of environmental media. Further, the EPA Integrated Risk Information System (IRIS) toxicity value for 

asbestos is derived from epidemiological studies of human fatalities and health effects, not from studies of test animals in the laboratory. Of the 14 

epidemiological studies used to derive the asbestos toxicity value, 7 involve 100% chrysotile or predominately chrysotile exposures. While the risk 

assessment does not predict individual outcomes, there is more confidence that adverse health effects in humans is associated with increased 

exposure to asbestos. 

In addition, the Superfund National Contingency Plan states that “For known and suspected carcinogens, acceptable exposure levels are generally 

concentration levels that represent an excess upper bound lifetime cancer risk to an individual of between 10-4 and 10-6 using information on the 

relationship between dose and response.” The EPA IRIS toxicity value for asbestos is actually a mid-line lifetime cancer risk value, not an upper 

bound value, so it already leans to an uncertainty that underestimates risk, making the “perhaps zero” statement even less applicable. The upper 

bound risk would more closely match the risk estimations of the California Office of Environmental Health Hazard Assessment (OEHHA). 

It is also important to note the following language from the Risk Assessment: 

“This risk evaluation assesses only the excess cancer risk from exposure to asbestos at the CCMA. It is known that asbestos causes diseases other 

than cancer, such as respiratory and pleural disease. The non-cancer effects are not quantitatively taken into account in this assessment, but could 

actually be more significant to total disease outcome from CCMA asbestos exposure. Therefore, the general probability of developing disease 

from exposure related to activities at Clear Creek may be significantly underestimated in this report. “ 

This information additionally supports the inappropriateness of including the “perhaps zero” statement of uncertainty in the CCMA assessment 

report. 

Comment: Risk Assessment - Recreation Use Scenarios Recommendation 

The EPA tests were run at too high a speed, and reducing the speeds to what an average 

rider actually rides at would have resulted in considerable less fibers/cc in the test results, 

thus resulting in reduced risk assessment numbers. Thus, the DEIS violates CEQ 

requirement 1500.1(b) on accurate scientific analysis. The EPA analysis must be modified 

to reflect accurate information, or the BLM must discard the inaccurate EPA report, or at a 

minimum recognize that it overestimates the risk and compensate for its known 

overstatement of the risk due to overestimates of an average user. This was not done. 

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BLM Response: The estimated speeds were derived by approximating the area covered and dividing by the time the sampler was on the trails. 

The concentration of asbestos found in the breathing zone during the rides is the important information. 

Comment: Impacts to Vegetation Recommendation 

DEIS table 4.4-3, page 376 states [under Alt. A] there will be continued intensive 

motorized recreation within both riparian and upland serpentine plant communities. 

Just about all trails near creeks have been closed, except for limited creek crossings at 

hardened locations, so there is no intensive motorized use in riparian areas. 

Change this statement to: 

Limited motorized recreation within both riparian and 

upland serpentine plant communities. Limited 

motorized recreation within both riparian and upland 

nonserpentine plant communities. 

BLM Response: The table referenced in the DEIS describes the impacts to vegetation from motorized recreation, which occur frequently under 

the current land use plan. 

Comment: Impacts to Social and Economic Conditions Recommendation 

Page 520, table 4.15-2 

This table again shows the lack of care shown in the remainder of the DEIS. The percent change for 2000-30 

are incorrect for the Diablo Range and Central Coast. They simply added the percent change above, instead of 

recalculating, so the percent change is considerably higher than actual. 

Diablo Range should be 70.4 percent increase, not 226.7 Central Coast should be 27.8 percent, not 80.0 

DEIS page 522; There is something wrong with the $4 million figure. If you calculate the cost per visit, then 

$4 million divided by the 90,000 visits comes to $44 per visit. This is way under the actual costs of recreating 

at CCMA... The economic benefit to the community is at least $6-8 million per year for 43,000 visits per 

year, which would increase to over $14 million for 90,000 visits. 

Correct the table to show correct 

percent changes. 

Correct the paragraph on page 

522 in section 4.15.2.4 to reflect 

actual economic benefits to the 

community, ie change the $4 

million number to $14 million. 

BLM Response: Page 520, Table 4.15-2. As identified by the commenter, this table contained calculation errors that have been fixed. The new 

table has also been re-named “Tabe 4.15-1” in this PRMP/FEIS. 

Comment: Impacts to VRM Recommendation 

[Ref. DEIS page 531, section 4.16.3.1] 

Nothing is specified that would have any effects on the visual resources, so delete this statement. It appears to 

have been made only to justify closing the area with no information on what activities could affect the visual 

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resources. 

BLM Response: DEIS explains on page 531, “Alternative A would have minor to moderate impacts on visual resources because current 

management practices do not afford visual protection standards for acquired lands, which would leave these areas in danger of potential 

deterioration of visual quality.” 

Comment: Benefits Based Management Recommendation 

The BLM Manual 1601, Planning, requires the agency to perform and disclose Benefits-Based Management. 

In the case ofCCMA, this would require the agency to disclose the benefits of the activities supported by 

CCMA, which include rock and gem collecting, 4 wheeling, and dirt bike riding. 

This is a major omission that was not performed, or at least is not included in the DEIS. 

The risks and benefits need to be compared and analyze and balanced to determine if one outweighs the other, 

or if the risk is acceptable. All activities have some degree of risk, and if the benefits outweigh the risks, they 

are socially acceptable. These include activities that are far more dangerous than recreating at CCMA, such as 

sky diving, scuba diving, horseback riding, etc. 

Include benefits for dirt bike 

riding [like] family activity 

allowing families to spend quality 

time recreating together, and keep 

in shape. Learning new skills, etc. 

BLM Response: Refer to Common Response Section 2A, 4B, and 4D.
 

ORG-3ROCKS: Three Rocks Research
 

Comment: Public Highways (R.S. 2477) Recommendation 

All of the main arterial highways passing over the subject public lands were clearly established before 

Congressional passage to the Federal Land Policy Management Act of 1976, which repealed Federal Revised 

Statute 2477. Several of these public highways support trade and commerce in southern San Benito County 

and western Fresno County. Many of these highways are clearly visible and passable as graded roads and they 

are delineated on early historic maps. These public highways provide public roads and right-of-way access to 

private lands within the subject area. Many of these highways connect between the paved Coalinga Road in 

Hernandez Valley and the paved New Idria Road in Vallencitos. Closing Clear Creek Road, for example, 

increases the travel distance between Hernandez Valley and Vallencitos by nearly 100 miles, thus adding 

significant burden to the public with by increasing their travel time and cost. 

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[BLM] propose to decommission or vacate public highways and to otherwise impair public use of historically 

established road and ways within the subject area. Schemes put forth by the Agency include charging private 

property owners fees for right-of-way access to their property, prohibiting access of their property to limited 

days, and dictating terms of use. 

BLM Response: BLM's Proposed Plan and Final EIS does not include proposals to decommission or vacate these public highways, and the 

proposed restrictions on public use of designated routes within the subject area would allow for continued historical uses except for OHV 

recreation due to the human health risk identified in Chapter 4 and the EPA Asbestos Exposure and Human Health Risk Assessment (2008).. 

Under the Proposed Action, BLM would provide rights of ways over the public lands to and from the private properties within the subject area. 

Under the Proposed Plan and Final EIS, BLM would require private property owners to acquire rights-of-ways (ROWs) for use of routes off the 

public highways administered by the County of San Benito. The BLM's authority for administering rights-of ways across public lands was 

established in Article V of FLPMA, which allows Field Office managers discretion to waive charges and fees for ROWs. These ROWs would not 

dictate terms of use for private property or public highways which supersede their jurisdiction and BLM would honor valid existing rights for 

access to private property. 

The issues related to R.S. 2477 are outside the scope of BLM’s land used decisions for transportation and travel management on CCMA public 

lands because the U.S. Ninth Circuit Court of Appeals ruled that the validity of R.S 2477 claims can only be determined through the courts. 

The following roads; Clear Creek (R1), Mexican Lake (R11), Wildass (R15), and Sawmill Creek (T158) have been informally identified as 

“County Roads” for a number of years. However, no record exists that San Benito County has a right of way or any legal right to these roads. The 

BLM has no record that the County established a right-of-way on the 26.1 miles of roads. The County has provided no information to the BLM to 

assert any rights-of-way and takes no responsibility for the roads, so by default these are Federal roads. 

Furthermore, San Benito County abandoned road maintenance on these roads in 1994 and has not conducted maintenance on them for 16 years. 

Lack of maintenance has resulted in impacts to natural resources, including water quality, habitat for Federally listed species, and public health 

and safety. Public health and safety are being adversely affected by the lack of appropriate road maintenance, and in fact this has resulted in death 

and injury to the public. Unlimited use of these roads exposes the public to airborne asbestos and poses a health hazard. 

Nevertheless, BLM, existing rights-of-way holders, and private property owners with in-holdings still need reliable access to the area for resource 

management and other purposes, but are frequently impeded due to the unmanaged condition of the roads. Improper road maintenance can also 

lead to excessive sedimentation and transport of toxic materials from the CCMA into various watersheds. This is affecting BLM’s ability to 

comply with water quality standards for mercury and sediment within the CCMA. Stream crossings and riparian areas are being affected by the 

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lack of maintenance. A 1995 study by a BLM contractor identified roads within the CCMA as the primary contributor of sediment into 

watersheds within the area. Maintenance proposed by BLM in the PRMP/FEIS would reduce sedimentation from these roads. 

The County’s failure to maintain these roads conflicts with resource management goals and the overarching laws and regulations governing BLM. 

Therefore BLM acknowledges its’ right and sole jurisdiction over the aforementioned roads. BLM has the appropriate equipment and staff to 

perform maintenance and repairs and will maintain a through route from the Coalinga-Los Gatos Road to Idria. BLM will continue to provide 

access for valid existing rights of way, mining claims, leases, and private landowners. Refer to section 2.3.3 for other management actions related 

to travel and transportation management. 

Comment: Planning Area Recommendation 

Usage of the term “Clear Creek Management Area” is erroneous and confusing because The Agency must produce a published descriptive 

the term lacks legal definition or meaning. Some BLM maps attempt to exhibit arbitrary documentation that describes the “Clear Creek 

boundaries enclosing an alleged “Clear Creek Management Area,” but fail to cite official Management Area” and clearly delineates its 

source documentation, and always include large portions of private property that are boundaries. 

clearly not subject to federal jurisdiction. Without defining documentation, it is impossible 

to show on a map, or mark on the soil any specific point where with a single human step a 

person might enter or exit the “Clear Creek Management Area.” The term “Clear Creek 

Management Area” is mute and without legal merit in the absence of descriptive 

documentation that describes the property or delineates its boundary. 

Pg. 629; The statement, “The population in the Planning Area is overwhelmingly urban, 

and rural areas are becoming increasingly less common as urbanization expands, 

especially in the San Francisco Bay Area, Central Coast communities, and in the San 

Joaquin Valley” is erroneous because it conflicts with the “Planning Area” defined on 

Page 1. The “the San Francisco Bay Area, Central Coast communities” and most of the 

“San Joaquin Valley” are outside of the Planning Area. 

BLM Response: The CCMA RMP/EIS describes the 'planning area' and the 'decision area' in Section 1.2 of the CCMA Draft RMP/EIS and this 

PRMP/FEIS to help define the term "Clear Creek Management Area". The CCMA RMP/EIS also includes published maps that clearly delineate 

its boundaries, and other documentation to further describe the “Clear Creek Management Area”. 

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The boundaries published on maps in the CCMA RMP/EIS (2009) are the same boundaires that were used to define the Clear Creek Management 

Area in the EPA's CCMA Asbestos Exposure and Human Health Risk aassesmment (2008) and the Record of Decisoion for CCMA Route 

Designation and RMP Amendment (2006). 

Furthermore, the term "Clear Creek Management Area" has been used by Three Rocks Research for many years, as evidenced on the non-profit 

organiuzaiton's website (http://www.3rocks.org) as well as other previously published documents, including Figure 1 on page 4 of the "Geological 

and Historical Archaeology Phase 1 Reconnaissance of Routes R1 and R2 within the Clear Creek Management Area,San Benito County, 

California" by Fowkes & Iddings, June 20, 2008. 

Comment: Purpose and Need Recommendation 

The Agency has very failed to articulate the purpose and need of the proposed action. This section of the 

document, which should address the purpose and need for the action, instead describes the “Purpose and Need 

for the CCMA Resource Management Plan” (see section heading). As this section clearly states, the “Purpose 

and Need for the CCMA Resource Management Plan” is to initiate a “planning effort” for which the BLM 

“needs to develop the CCMA RMP.” This purpose and need section has absolutely nothing to do with any 

initiating NEPA action, which remains absent from the document. 

Although the EPA report provides more detailed charts and more tabulated data, the essential conclusion is 

generally the same as produced from an earlier report published in 1992 by PTI Environmental Services, 

titled Human Health Risk Assessment for the Clear Creek Management Area. Essentially the conclusions 

from the two independent studies are identical is that they both concluded that risk estimates may be over 

estimated, or under estimated. 

The Agency erroneously asserts that EPA’s report titled, Clear Creek Management Area Asbestos Exposure 

and Human Health Risk Assessment (EPA 2008) mandates “significant new information that must be 

incorporated into a land use plan.” The Agency’s assumption of such mandate is arbitrary and capricious in 

that it asserts a willful and unreasonable action that disregards the facts. 

The Agency’s assertion is erroneous because it does address this issue in the 2005 - Clear Creek Management 

Area Proposed Resource Management Plan Amendment and Final Environmental Impact Statement. This 

issue has also been addressed in many previous planning documents and planning documents associated with 

adjacent and nearby public lands. Additionally, it is well documented that neither the Red-Legged Frog or 

Tiger Salamander exist within the subject area environs. 

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The Agency is attempting to assert that because changes in “social and economic conditions ... have led to 

increased demand for use of public lands for recreation” that this also translates into increased recreation 

demand for the public lands within the subject area, specifically CCMA. However, that thesis is erroneous 

based upon the Agency's own evidence as present on page 135 of the subject report, which as reproduced 

below clearly prove that CCMA visitor recreation is decreasing each year, hence proving that the Agency's 

assertion is false. 

BLM Response: Preparation of the Draft RMP/EIS is not the proposed action. Pursuant to CEQ regulations for implementing NEPA at 40 CFR 

1502.1, "the primary purpose of an environmental impact statement is to serve as an action-forcing device". Therefore, the purpose and need for 

action described in the Draft RMP/EIS in Chapter 1 (pp. 3-4) applies to the range of alternatives, including the preferred alternative, which were 

evaluated in the Draft RMP/EIS, rather than preparation of the document itself. The purpose and need stated in the Draft RMP/EIS is consistent 

with 40 C.F.R. § 1502.13 because it clearly identifies numerous changes in circumstances "to which the agency is responding by proposing the 

alternatives including the proposed action". The purpose and need statement is also consistent with the guidance provided in the BLM's National 

Environmental Policy Act Handbook (H-1790-1) because it explains why the BLM needs to establish goals, objectives, and management actions 

for BLM-administered lands in CCMA that address current issues, knowledge, and conditions. 

The portion of the Draft RMP/EIS referenced in the comment says that the EPA study "provides significant new information". However, the Draft 

RMP/EIS does not say that the EPA report mandates that this information be considered in an EIS. As the lead agency, BLM maintains the 

authority to determine when new information or changes in circumstances require preparation of an EIS, pursuant to 40 CFR 1502.4 (a) and (b). 

This guidance explains that environmental impact statements are often required to evaluate broad Federal actions "such as the adoption of new 

agency programs or regulations (Sec. 1508.18)". Accordingly, BLM and EPA are have been working together as cooperatng agencies to complete 

and RMP/EIS that describes broad actions relevant to land use policy that is timed to coincide with agency planning and decisionmaking for BLM 

public lands in CCMA. 

The purpose and need for the 2005 Proposed RMP and Final EIS was limited to route designation. Similarly, other BLM planning documents 

referenced in the comment were prepared to address specific land use decisions based on oil and gas leasing or concerns for human health and 

safety from exposure to asbestos in CCMA. Although these documents make reference to the special status species identified in the purpose and 

need statement for the 2009 Draft RMP/EIS, BLM maintains the authority to determine when new information or changes in circumstances require 

preparation of an EIS. Additionally, the 2007 RMP for the Southern Diablo Mountain Range specifically excluded any decision for public lands 

administered by BLM in CCMA. As a result, Section 1.1 of the Draft RMP/EIS says "this planning effort is intended to be comprehensive, 

evaluating existing management plans and identifying regional issues, and resolving those issues through public, interagency, and intra-agency 

scoping efforts." Based on public scoping efforts, management of special status species is appropriate to consider while determining BLM's longrange management goals, intermediate objectives, and actions and options for meeting those objectives. 

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BLM's rationale for increased social awareness and demand for access to public lands is attributed to population growth and other demographic 

changes described in Chapter 3 (Section 3.15), rather than CCMA visitor use statistics. Furthermore, on page 135 of the Draft RMP/EIS, BLM 

explains that recreation use in the Planning Area was estimated at 35,000 visitor days in 2007/2008, and that these estimates have not changed 

drastically over the years, even with the increasing popularity of OHV recreation in California. 

Comment: Major Planning Issues Recommendation 

[DEIS Pg. 7] 

The Agency promotes the above as being “Based upon the discussions held during three public scoping 

workshops and responses to the NOI to prepare the CCMA RMP/EIS” creating an image that these represent 

a fresh view of the major planning issues confronting the Bureau of Land Management. However, a review of 

previous planning actions undertaken by the Agency within the defined planning area illustrate that most of 

these issue been extensively studied several times. 

The Major Planning Issues, except for recreational age restriction and days-per-year recreation limits, have 

been extensively researched and well documented during pervious planning sessions and in previous resource 

management plans, environmental impact statements, and records of decision, thus showing that the majority 

of these issues have been well settled and do not need to be reassessed here. 

The Agency must delete such 

erroneous assertions from the 

major planning issues statement. 

In the absence of realistic issues, 

the major planning issues 

statement is erroneous, the entire 

document is mute, without legal 

merit, and the initiating action is 

void ab initio. 

BLM Response: The purpose and need statement for the CCMA RMP/EIS explains that during the revision of the Hollister RMP prior to 2007, 

BLM determined the unique resources issues and the complexity of CCMA land use decisions should be addressed in a “stand alone” land use 

plan. Concerns expressed by EPA regarding the adequacy of the human health risk information available at the time to make land use decisions for 

CCMA, and their plans to conduct a new health risk assessment for CCMA public land visitors were cited as the primary reason for exclusion of 

the CCMA from the broad scope of the issues addressed in the Hollister RMP (2007). 

In accordance with 40 CFR 1502, BLM developed the Hollister RMP and its’ associated environmental impact statement to address resources 

issues throughout the entire Hollister Field Office, and agreed to work with EPA as a Cooperating Agency to address concerns regarding human 

health risks associated with recreational use on CCMA public lands in the CCMA RMP/EIS in order to narrow the scope of the analysis and 

eliminate repetitive discussions of the issues addressed in the Hollister RMP (2007). 

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The CCMA Draft RMP/EIS (and Proposed RMP and Final EIS) includes a brief discussion of these issues in Section 2.1 to explain why the range 

of alternative management actions is similar for biological resources, cultural and paleontological resources, special designations, visual resources, 

fire management, energy and minerals, livestock grazing, social and economic conditions, and lands and realty. 

Pursuant to the regulation cited above, BLM states (DEIS, pg. 300) “the depth and breadth of the impact analyses presented in this chapter is 

commensurate with the level of detail of the management actions presented in Chapter 2, and the availability and/or quality of data necessary to 

assess impacts. The baseline used for reasonably foreseeable effects is the current conditions in the Planning Area, as described in Chapter 3. Each 

resource program section in Chapter 4 further explains why the and whether the proposed land use decision for these resources programs would 

have a significant effect on the human environment in comparison to the current conditions under the no action alternative analyzed in the Draft 

RMP/EIS. 

Comment: EPA Risk Assessment Recommendation 

Throughout the document, the Agency relies heavily upon the EPA's 2008 report titled, Clear Creek 

Management Area Asbestos Exposure and Human Health Risk Assessment, to the exclusion of any opposing 

or diverse scientific opinion. Although the Agency may exercise liberty in selecting which scientific authority 

or opinion upon which they wish to base their final determination, the Agency is obligated to exhibit 

professional and scientific integrity during the discussion and analysis in the environmental impact statement. 

However, the Agency has ignored any and all scientific research and opinion contrary to the EPA's 2008 

report, thus creating an illusion of scientific consensus regarding human health risk associated with asbestos, 

and specifically with the chrysotile mineral natural to the serpentine deposit found within the subject area. 

There is a diversity of scientific opinion regarding the lack chrysotile etiology to which the public in entitled 

to know about, and which should be consider by the Deciding Officer. Omission of diverse and credible 

scientific opinion sways, and even biases, the scope of alternative presented to the Deciding Officer, and 

thereby impairs the Deciding Officer's ability to fairly, reasonable and objectively select an appropriate 

alternative. 

However, the Agency has purposely chosen to conceal the diversity of scientific opinion by excluding if from 

the draft resource management plan and the draft environmental impact statement. This accusation is directed 

because this author provided such references and copy during the public scoping comment period and the 

Agency chose to exclude or otherwise ignore that information. Therefore, the Agency's continued omission is 

arbitrary and capricious in that it asserts a willful and unreasonable action that disregards the facts. 

-noneBLM Response: Refer to Common Response Section 1C – 1F. 

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Comment: Terminology and Formatting Recommendation 

Using the word “asbestos” is confusing because it implies that the subject Serpentine ACEC The Bureau of Land Management must 

contains a large volume of all of the asbestos mineral, which is erroneous. The subject Serpentine explain any special meaning intended by 

ACEC is known for its naturally occurring chrysotile deposit, and is known to be free of natural unusual formatting, or confess that it is a 

amphibole asbestos fiber. The word “asbestos” is being misused as a substitute term when the reflection on poor document management, 

reference to a specific mineral is more appropriate and technically correct. the lack writing skill or the lack of 

competent editing and correct such 

According to the United States Geological Survey, “Asbestos is a generic name given to six fibrous deficiencies. The Agency must rewrite the 

minerals that have been used in commercial products.” The definition is expanded further in the subject document to remove the discrepant 

USGS Open-File Report 02-149 as, “These fibers belong to two mineral groups: serpentines and issue from the document. The original 

amphiboles. The serpentine group contains a single asbestiform variety: chrysotile. There are five discrepancy must not be included or 

asbestiform varieties of amphiboles: anthophyllite asbestos, grunerite asbestos (amosite), riebeckite propagated in the final resource 

asbestos (crocidolite), tremolite asbestos, and actinolite asbestos.” (Virta 2002:5). The EPA management plan, the final environmental 

asbestos risk assessment is based on 1986 data (EPA 1986) and fails to consider the current EPA impact study, or the record of decision. The 

opinion which admits that chrysotile is much less potent (EPA 2008), and may, in fact, not be a final documentation should include 

human health risk. corrected recommendations. 

The paragraph is misleading because it assumes that all gem and mineral collection, and 

rockhounding is a recreational activity. Merriam-Webster Dictionary defines “Rock Hound” as 

“1) a specialist in geology, 2) an amateur rock and mineral collector,” which is not necessarily 

recreational. Some mineralogical collecting and prospecting conducted in the area is 

occupationally related and hence not recreational. 

The paragraph is erroneous because there is no “Spanish Lake Road” within the subject area. Since 

“agencies should employ writers of clear prose or editors to write, review or edit statements” (40 

C.F.R. 1502.8), the public is left to assume that such unusual words, terminology or formatting 

might convey special meaning. Perhaps the author meant to refer to San Benito County's “Mexican 

Lake Road,” which is a California public highway. The public depends on author’s accuracy and is 

therefore not at liberty to interpret variant meanings, therefore the Agency must write clear prose 

that is comprehensible and unambiguous. 

The misuse of quote marks, single or double, and sometime combined with italic emphasis 

351
 
 

 

 

 

 

 

 

 

Clear Creek Management Area Appendix X 

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is very confusing. Since “agencies should employ writers of clear prose or editors to write, 

review or edit statements” (40 C.F.R. 1502.8), the general public is left to assume that such 

unusual formatting might convey special meaning. The public depends on author’s accuracy 

and is therefore not at liberty to interpret variant meanings, therefore the Agency must write 

clear prose that is comprehensible and unambiguous. 

BLM Response: In the absence of an active mining claim, rock-hounding is managed as a recreational activity at CCMA. The definition of the 

term ‘asbestos’ includes both chrysotile and amphibole mineral types, both of which occur in the CCMA and were detected in the activity based 

sampling conducted in preparation of the EPA’s 2008 human health risk assessment. 

Other comments related to the existence of typos and quotation marks used to place emphasis on specific terms used in the CCMA Draft RMP/EIS 

are non-substantive and do not inhibit meaningful analysis because the document provides the purpose and need for the Draft RMP/EIS, includes a 

reasonable range of alternatives, and describes the affected environment and the environmental consequences of alternative management actions 

for the CCMA. 

Comment: Regulatory Framework Recommendation 

Pg. 568; The statement, “Vehicle use in the Planning Area is managed under the direction and 

authority in 43 CFR Part 8340 'Off-Road Vehicles,' and Subpart 8342, 'Designation of Roads and 

Trails'” is erroneous because it conflicts with the “Planning Area” defined on Page 1 the same 

report. Since the “Planning Area” is defined “regardless of jurisdiction,” then authority is not restricted to “43 

CFR 8340,” but would also include various State laws as applicable to jurisdictional authority. 

Pg. 623; The statement, “All public lands are required to be designated as open, limited, or closed to 

motorized vehicle access (43 CFR 8342.1)” is false because it incorrectly quotes 43 CFR 8342.1, 

which correctly states: “The authorized officer shall designate all public lands as either open, limited, or 

closed to off-road vehicles.” 

Pg. 624; The statement, “On lands designated as “limited”, cross-country travel is prohibited and travel is 

limited to designated “open” routes” is false because 43 CFR 8342.1 does not pertains to all “travel,” but 

rather specifically to off road vehicle use. 

Pg. 627; 

-none352
 
 

 

 

 

 

Clear Creek Management Area Appendix X 

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The statement, “The off-highway vehicle (OHV) regulations apply to use of routes by the general public” is 

inaccurate and misleading because 43 CFR Part 8340 is more accurately a subpart of 43 CFR Subchapter H 

—Recreation Programs. Thus implying that the regulation applies to the “general public” is false. The 

regulation applies to “recreation programs.” 

BLM Response: Pg. 623; 43 CFR 8340.0-5 Definitions. (a) Off-road vehicle means any motorized vehicle capable of, or designed for travel on or 

immediately over land, water or other natural terrain. 

Pg. 624; The sentence referenced by the commenter maintains validity within context of paragraph. 

Comment: Visitor Use Data Recommendation 

Pg. 636; The statement, “The OHV-related environmental impacts from increasing OHV use on the 

CCMA route network ...” conflicts with the data presented in Table 3.8-1 on page 135, which 

shows that OHV use is decreasing rather than increasing. 

Pg. 793; “If recreation use were to grow at a rate proportional to projected population growth in the Central 

Coast and Diablo Range areas, over 50,000 annual visits would be expected, compared to the 43,000 visitor 

use days recorded in 2006.” [This statement] is erroneous because it is contrary to the Agency's statistic 

showing a significant reduction in CCMA visitor use (see page 135 of subject report). 

-noneBLM Response: The statement on pg. 636 is based upon overall projected population growth and the likely increase in OHV use as a whole. 

Recreational use of public lands can be expected to increase as population grows, not only in the Central Coast and Diablo Range areas that 

support local use but also throughout the HFO and California. 

Comment: Overview of Impacts Recommendation 

Pg. 307; [The energy and mineral development] paragraph states “... inactive mine sites have negative impact 

on the viewshed of the area for recreation users ...” which is false because many visitor enjoy historic mining 

sites. 

This paragraph [also] states “Increased traffic associated with active mine operations would increase asbestos 

emissions and pose an additional health risk to recreation users” which is false because possible mining claim 

might also include nonserpentine geology. 

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This paragraph contains an erroneous because is states “Existing hard rock mining claims and newly 

established claims will prohibit access to public lands by amateur rockhounding enthusiasts” which is false 

because such mining claim might also invite visitation by “amateur rockhounding enthusiasts.” 

Pg. 309; The statement, “Lode claims in the area conflict with recreation opportunities” is erroneous. 

BLM Response: [DEIS, Pg. 307] Impacts to visual resources occur when the naturalness of the landscape is altered by land use activities, such as 

mining, road building, and construction of pipelines and other utilities. The statement regarding potential increases of asbestos emissions 

associated with energy and mineral development is based on reasonably foreseeable increase in traffic to and from these active mine operations 

through the Serpentine ACEC and the potential emissions from that associated ingress/egress. The DEIS properly asserts that establishment of 

mining claims would have adverse effects on rockhounding because the general public could be excluded from rockhounding opportunities on 

mining claims. 

[DEIS, Pg. 309] As noted by the commenter. “while the claim holder cannot prevent others from crossing his or her claim for uses recognized 

under the Multiple Surface Use Act of 1955, or engaging in lawful recreational activities provided that they do not interfere with the claim 

holder’s operations ... , a claim holder does have the right to prevent others from prospecting and mining on the claim, except by invitation.” 

Comment: Special Designations Recommendation 

The San Benito Mountain Research Natural Area is located within the ACEC and development of trails and 

other visitor facilities would be contrary it being designated a “natural area.” 

-noneBLM Response: The regulatory framework for management of the SBMRNA is discussed on in Section 3.10.2.2. 

Comment: Route Designation Methodology Recommendation 

The statement, “Redundant routes are routes that no longer serve their intended purpose and/or exceed State 

soil loss standards” is erroneous because it fails to recognize the proper and accepted definition for the word 

“redundant.” 

-noneBLM Response: Statement incorrectly includes environmental issues related to erosion and soil loss, not excessive or unnecessary routes serving 

the same destination. Therefore, the wording has been changed in section 4.3.2.1 of this PRMP/FEIS. 

Comment: Transportation and Travel Management Recommendation 

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Clear Creek Management Area Appendix X 

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The statement, “There is no production-grade application device available for a single track trail situation, -noneespecially when dealing with the narrow, off-camber and steep grade trails endemic to CCMA” is inaccurate 

because ROKON, Inc. does manufacture single-track equipment that could accommodate or facilitate various 

applications. However, it remains probable that extreme variation in trail camber, incline, soil compaction and 

many other factors may impair the efficacy of such applications. 

[DEIS, 4.3.11: Cumulative Effects] This entire section contains extraneous background data that creates 

unnecessary bulk which would be better served by reference to the source document. 

BLM Response: ROKON agricultural application devices are two-wheeled, tow-behind units and would likely require extensive modifications to 

apply soil amendments, as stated in the final sentence of quoted paragraph: "...and would likely be unfeasible from a cost/benefit perspective, 

especially when labor is considered." 

Pursuant to NEPA, Section 4.3.11 describes the cumulative effects of BLM’s transportation and travel management alternatives analyzed in the 

CCMA Draft RMP/EIS. The document makes reference to a study prepared by the U.S. Forest Service and summarizes the relevant information to 

avoid presenting needless bulk. 

ORG-TGMC: Tule Gems and Mineral Club 

Comment: Comments submitted by individual members. Recommendation 

Refer to individual comments. -noneBLM Response: Thank you.
 

ORG-VWA: Ventana Wilderness Alliance
 

Comment: Preferred Alternative Recommendation 

CCMA and surrounding management zones are too vast, rugged and remote to be managed for off road 

vehicle recreation. Furthermore, the diverse soils that support rare and sensitive biological resources are 

unsuitable for intensive and newly developed OHV recreation activities. 

-none355
 
 

 

 

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Given the past problems with OHV adherence to trail systems we feel that the protection of the biological 

resources is best achieved by ALT E, however, we recognize the pressure to allow OHV recreation and 

therefore find elements of Alternative C and E potentially acceptable. 

Limitation to the Idria - Spanish Lake road does not provide adequate access to Clear Creek where both rock 

hounds and botanists find highly desirable. We believe that the public should be allowed to drive (“tour”) 

through the CCMA on all of the county roads and access this beautiful area for passive recreational uses (such 

as hiking, birding, photography, scientific research, rock hounding), including within the Serpentine ACEC. 

We strongly encourage BLM to work with San Benito and Fresno counties to resolve the access and 

maintenance issues of the county roads for non-consumptive uses. 

The Idria Road is impassable to standard vehicles which would unfairly limit access to the CCMA. We 

request that the Clear Creek Road and entrance be kept open. ALT E should be modified to include the all of 

the County Road Network. 

The VWA strongly supports the Closure of Open Play Barren areas in ALT. C. 

Closure of CCMA — April 15th closure is much too early for botanical and birding usage of CCMA. We 

suggest that the county road network be open year round to highway (touring) vehicles with permits required 

in the dry season. 

BLM Response: Refer to Common Response Section 3D. 

Comment: General Recommendation 

The DRMP/DEIS document is unnecessarily complicated and too long for the general public to assimilate 

and begin to provide germane comments. This is very unfortunate because we believe it excludes many 

individuals who appreciate the CCMA AND the surrounding ‘management zones’ and would otherwise be 

able to provide comments. 

Equally as unfortunate are the numerous (7) alternatives. Not one alternative, A G, is entirely acceptable and 

therefore, we are requesting a combination of one or more Alternatives in order to capture the interests of our 

organization. We therefore object to each individual alternative as they are presented in the DRMP/DEIS. 

-none356
 
 

 

 

 

 

 

 

 

 

 

Clear Creek Management Area Appendix X 

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The description of the planning area (1.2) neglects to include “high number of sensitive plant and animal 

species”, and also omits Incense cedar from the “unique forest assemblage”. 

BLM Response: Refer to Common Response Section 1G and 3A. 

Comment: Land Tenure Adjustments and New OHV Areas Recommendation 

All of the surrounding ‘management zones’ that the Hollister BLM interdisciplinary staff Retain the lands identified in the DRMP/DEIS in the 

designated for this document have many sensitive, rare plant and animal species and Tucker, Condon and San Benito River management 

communities. Decisions to “dispose” and/or develop trail networks/roads on these public zones. 

lands is incongruous with conserving and protecting the sensitive natural resources that 

occur therein. In all cases with OHV usage we insist that the BLM 

strictly monitor for compliance using the State Soil 

We strongly oppose development of any new OHV recreation areas by the Hollister BLM Loss Standards and unauthorized trail expansion. 

Field Office for energy consumptive, destructive recreation for the following reasons: 1. Violations need to result in trail closure and 

Inadequate funding for additional law enforcement, ranger patrols, restoration and rare restoration. Additional mitigation for OHV use in the 

species monitoring at the CCMA or any of the proposed ‘new areas’; 2. The southern fragile area is that there must be a steady committed 

Diablo Mountains are geologically and biologically diverse. These Public lands are highly source of money to support personnel to monitor and 

sensitive and should be protected, not exploited. enforce and to effectively close off the open play 

barren areas. 

BLM Response: Refer to Common Response Section 3D. 

ORG-WOHVA: Wisconsin Off-Highway Vehicle Association 

Comment: General Recommendation 

WOHVA does not support any land management plan which does not list as an alternative the expansion of 

motorized recreational riding opportunities. 

WOHVA encourages the Bureau of Land Management (BLM) to work with motorized recreational groups to 

develop a partnership with these groups. It is our belief that by working with motorized recreational volunteer 

groups the BLM can find solutions to some of their financial and budgetary restrictions. 

-noneBLM Response: Refer to Common Response Section 3A. 

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Clear Creek Management Area Appendix X 

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III. PUBLIC COMMENTS AND FORM LETTERS 

Tables X-3 and X-5 list the names of authors of individual comment letters and form letters 

received by the Hollister Field Office, respectively. 

Tables X-3 and X-5 also identify the affiliation of commenters, and a “Comment Code” to direct 

the reader to the location of the comment summary and responses to comments in Tables X-4 and 

X-6. 

The summary of the public comments on the CCMA Draft RMP/EIS and the individual or 

common responses to those comments were prepared by BLM in accordance with 40 CFR 

1504.3. 

Many comment received by BLM were beyond the scope of the CCMA Proposed RMP and Final 

EIS. These comments and other comments that represent opinions are acknowledged by BLM 

with the following response: “Comment noted. No response necessary” or “NA” (Not 

Applicable). 

Table X-3; Individual Comment Author List (Written and e-mail) 

Comment 

Code Commenter 

IND-COM-01 Aaron lindy 

IND-COM-02 Alex Wagner-Jauregg 

IND-COM-03 Alex Wagner-Jauregg 

IND-COM-04 Andy Bajka 

IND-COM-05 Anthony Colon 

IND-COM-06 Art Thompson 

IND-COM-07 Bryan Vaughn 

IND-COM-08 BAMBAMB43 

IND-COM-09 Ben Ellis 

IND-COM-10 Frank Smith 

IND-COM-11 Bill Zeber 

IND-COM-12 Billy Petrushkin 

IND-COM-13 Robert C. Wilson 

IND-COM-14 Bob Bishop 

IND-COM-15 Bob Rowlands 

IND-COM-16 bobbyg 

IND-COM-17 bondobob2 

IND-COM-18 Brian Centeno 

IND-COM-19 Burych, Donna (CIV) 

IND-COM-20 Caleb Ashby 

IND-COM-21 Carolyn Downey 

IND-COM-22 Chris Will 

IND-COM-23 CHARLIE MAZZELLA 

IND-COM-24 Chris Beecroft 

IND-COM-25 Chris Carbonel 

IND-COM-26 Chris Hiatt 

IND-COM-27 chris lesso 

IND-COM-28 Chris Napolitano 

IND-COM-29 Joe Sprenger 

IND-COM-30 Claudia Mitchell 

IND-COM-31 Curt McDowell 

IND-COM-32 Dan R. Azar 

IND-COM-33 Darell Kroeker 

IND-COM-34 David Olson 

IND-COM-35 Dave Wheeler 

IND-COM-36 David & Lori Tharp 

IND-COM-37 David Doudna 

IND-COM-38 David Furrer 

IND-COM-39 Name withheld by request 

IND-COM-40 David Sundholm 

IND-COM-41 Michael Damaso 

IND-COM-42 James L. Ward 

IND-COM-43 Dee Murphy 

IND-COM-44 Dennis Scroggins 

IND-COM-45 Ed Ferner 

IND-COM-46 ED SANTIN 

358
 
 

Clear Creek Management Area Appendix X 

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IND-COM-47 Joh Davis 

IND-COM-48 Eric Olsen 

IND-COM-49 Favia, Paul 

IND-COM-50 Frank Mullaney 

IND-COM-51 Frank Nye 

IND-COM-52 Frausto, Richard 

IND-COM-53 GARY LA HUE 

IND-COM-54 George Alderson 

IND-COM-55 Gerhard Donner 

IND-COM-56 Glen Chambers 

IND-COM-57 Glenn Wegner 

IND-COM-58 Tom Keith 

IND-COM-59 Greg J Meade 

IND-COM-60 Greg Mirassou 

IND-COM-61 Gus Meyner 

IND-COM-62 Heather Kilby 

IND-COM-63 Michael Lee Evans 

IND-COM-64 Justin Hensley 

IND-COM-65 ian plaine 

IND-COM-66 Peter Giusti 

IND-COM-67 Jim Vreeke 

IND-COM-68 J. Braun 

IND-COM-69 John Grinager 

IND-COM-70 J.L Mangono 

IND-COM-71 JAKE MEYER 

IND-COM-72 JEAN SCHRUM 

IND-COM-73 Jeff & Kathleen Jacobsen 

IND-COM-74 Jeff Holmbeck 

IND-COM-75 Jeffrey R 

IND-COM-76 Joe Ferrante 

IND-COM-77 John Culver 

IND-COM-78 John Wilkinson 

IND-COM-79 Jon Aichele 

IND-COM-80 Joseph Rooney 

IND-COM-81 jrhill 

IND-COM-82 Judy Burson 

IND-COM-83 Justin Hunter 

IND-COM-84 Joe Sprenger 

IND-COM-85 Karen Murphy 

IND-COM-86 Kathi Peverini 

IND-COM-87 Kathleen Joyce 

IND-COM-88 Kathleen McGann 

IND-COM-89 Dave Seghi 

IND-COM-90 Kathy Woveris 

IND-COM-91 Keith, Tori 

IND-COM-92 ken arrington 

IND-COM-93 Ken Stillwagon 

IND-COM-94 Kenney Glaspie 

IND-COM-95 Ken Deeg 

IND-COM-96 KENT SUNDGREN 

IND-COM-97 Kevin and Cindy 

IND-COM-98 Steve Ritchie 

IND-COM-99 Withheld by Request 

IND-COM-100 kristin kearns 

IND-COM-101 Ladd Johnson 

IND-COM-102 Laura Okeson 

IND-COM-103 lee bates 

IND-COM-104 Leza Rodriguez 

IND-COM-105 Linda Anderson 

IND-COM-106 Jack Sontag 

IND-COM-107 Mark L. Ward 

IND-COM-108 Maloney, Marty 

IND-COM-109 Marcia Gibbs 

IND-COM-110 Mark Isaacs 

IND-COM-111 Mark Gigas 

IND-COM-112 Mary Hicks 

IND-COM-113 Meyner, Gus 

IND-COM-114 Withheld by Request 

IND-COM-115 Mike Omodt 

IND-COM-116 Mike Tanner 

IND-COM-117 Wally Boggess Jr 

IND-COM-118 Natasha Hunt 

IND-COM-119 Nate 

IND-COM-120 Nate Delaney 

IND-COM-121 nathan mccreary 

IND-COM-122 Nick Vleisides 

IND-COM-123 Sherry Stortroen 

IND-COM-124 David Dills 

IND-COM-125 P Tehaney 

IND-COM-126 Pat Rebich 

IND-COM-127 Phil & Debbie 

IND-COM-128 Paul Winslow 

359
 
 

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IND-COM-129 Przykucki, Robert 

IND-COM-130 R. Leathers 

IND-COM-131 Robert E. Crabill 

IND-COM-132 Randall R. H. Adams 

IND-COM-133 Randy Johnson 

IND-COM-134 Ronald Hobbs 

IND-COM-135 Rebecca Rosas 

IND-COM-136 Richard Spotts 

IND-COM-137 Rick Adan 

IND-COM-138 Rick Kennedy 

IND-COM-139 robbie_3146 

IND-COM-140 Robert Henry 

IND-COM-141 Rocky Hill 

IND-COM-142 Robert Piper 

IND-COM-143 Rob Porcella 

IND-COM-144 Ryburn Family 

IND-COM-145 Sam Baxter 

IND-COM-146 Sebastian Ubillos 

IND-COM-147 Sepnufer 

IND-COM-148 SLVcougar19 

IND-COM-149 Withheld by Request 

IND-COM-150 Brent Snyder 

IND-COM-151 J. McDaniel 

IND-COM-152 Steve Craig 

IND-COM-153 Steve Greenwood 

IND-COM-154 Steve Schroeder 

IND-COM-155 Ralph Higbee 

IND-COM-156 

Gina & Lawrence 

Peverini 

IND-COM-157 Thomas F. King 

IND-COM-158 The Hummels 

IND-COM-159 Robert Jump 

IND-COM-160 Tristan Mcvay 

IND-COM-161 Troy Collins 

IND-COM-162 Jeri Heiser 

IND-COM-163 Wayne Michelsen 

IND-COM-164 Wesley Paik 

IND-COM-165 Michael J. Pereira 

IND-COM-166 White, Mary 

IND-COM-167 Brian Winn 

IND-COM-168 Wayne Schrimp 

IND-COM-169 Steve Knecht 

IND-COM-170 Steve Hlebo 

IND-COM-171 Patrick Angelo 

IND-COM-172 John Barnewitz 

IND-COM-173 Jay E. Bates 

IND-COM-174 Danny Bawdon 

IND-COM-175 David Bonvicin 

IND-COM-176 Mark Hartsell 

IND-COM-177 Neil Schmidt 

IND-COM-178 Jim Bean 

IND-COM-179 Mary Lou Froese 

IND-COM-180 Nick Rizzi 

IND-COM-181 Leslie Marquette 

IND-COM-182 pismo1327 

IND-COM-183 Howard L Hughes 

IND-COM-184 Jeff Robinson 

IND-COM-185 Hans Thern 

IND-COM-186 Michael W Bouder 

IND-COM-187 Dirk Paintedman 

IND-COM-188 George Libby 

IND-COM-189 Jon Taylor 

IND-COM-190 Steve Brown 

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Table X-4; Individual Comment Summary & Responses
 

Comment Code Summary Response 

IND-COM-01 

When i was 11 years old my father brought me to 

clear creak several times in our old jeep and 

taught me how to drive it. i really feel that trips 

like those taught me alot about being responsable 

and i learned to care for the outdoors. My father 

is no longer around, but I have a 13 year old 

brother who i would love to be able to take out 

there and teach him some of the things my father 

taught me. 

from what i've read this area was mainly closed 

becouse of "health risks" but then read "The BLM 

admitted at the recent CA OHMVR Commission 

meeting in San Jose that to date they are aware of 

no cases of asbestos-related illnesses noted in the 

recreation community that has been using Clear 

Creek since the 1940s." i understand that to mean 

there really isn't a health risk. i also understand 

that monitering the area and having the resources 

to maintain the area can be costly but i would be 

willing to bet the people who want to use the area 

would be willing to help cover the costs, i know i 

would. 

Refer to Common 

Responses Section 4A, 

4B, and 4D. 

IND-COM-02 

Refer to Comments from Organizations: ORGTMC See BLM response to 

ORG-TMC 

IND-COM-03 

Refer to Comments from Organizations: ORGTMC See BLM response to 

ORG-TMC 

IND-COM-04 

The BLM Draft EIS/RMP fails to mention that 

smoking has decreased and risk calculations may 

overestimate risks for CCMA users based on 

current population smoking patterns. The BLM 

needs to include information that identifies that 

risk calculations may overestimate risks for 

CCMA users based on current population 

smoking patterns. 

The EPA report did not use typical recreational 

activities. The average rider does not ride at 

CCMA for 30 years. There is no evidence that 

any recreation by individuals is being done every 

year for 30 years straight. 

The test methodology used did not simulate how 

a human breaths. The test procedure used by EPA 

simulated how a machine would breath, that is on 

Refer to Common 

Responses Section 1F(i), 

1F(ii) 3A, 3C, and 3D. 

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Comment Code Summary Response 

a timed bases. Humans on the other hand 

instinctively hold their breath under heavy dust 

conditions. Most motorcycle riders spend the 

majority of the day on single track. The EPA test 

therefore does not reflect reality and is flawed. 

Change the report to show "the EPA has a 

concern regarding the risks but there are 

uncertainties inherent in risk assessment". The 

BLM needs to correct the report and replace the 

the words "The result of the study concluded" to 

"The EPA report indicates the risks are 

uncertain". 

The EPA’s CCMA Asbestos Exposure and 

Human Health Risk Assessment (2008) provides 

insignificant new information. 

BLM is using the 2008 EPA Asbestos Risk 

Assessment as evidence when the document is 

only an assessment. BLM fails to identify there is 

lacking information that shows scientifically 

there is an asbestos risk at CCMA. The EPA 

report fails to show there are any health risks by 

not providing an Epidemiology report which 

would back up their data. The BLM EIS must 

indicate there is no epidemiological information 

available from the EPA because the EPA finds it 

too difficult to obtain a valid epidemiological 

report. 

BLM has failed to provide a No Action 

alternative but instead has added conditions to the 

No Action Alternative. 

The EPA testing did not simulate recreational 

riders. If they had followed the same information 

provided by the BLM Hollister Field Office they 

would have know to avoid the lead riders dust. 

BLM failed to mention the PTI study done in 

1992. This report clearly indicates the EPA study 

which uses the IRIS toxicity values will have an 

overestimate of 7 times. 

On page 135 of the DEIS, visitor use shows a 

decline. BLM does not provide data to show an 

increased demand for recreation in the [Planning 

Area] Table 3.8-1; It is critical to know the 

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Comment Code Summary Response 

number of unique visitors because the health 

assessment risk is based on individual exposure. 

The report needs to indicate that the BLM doesn't 

have information regarding the number of unique 

visitors to the CCMA area. 

BLM Land Use Planning Handbook“BLM 

recognizes that influential information should be 

subject to a high degree of transparency about 

data and methods to facilitate the reproducibility 

of such information by qualified third parties, to 

an acceptable degree of precision.” BLM has 

failed to follow the Land Use Planning Handbook 

in that it mandates important data like asbestos 

risks to have a acceptable degree of precision. 

. 

EPA used as guidance procedures from a 

Superfund site. This has nothing to do with 

recreational use at CCMA. BLM used the EPA 

document incorrectly by claiming the EPA 

document relates to asbestos risks relating to 

recreational use, which it is not. 

IND-COM-05 

Please approve option A to reopen Clear Creek 

for OHV usage. I enjoyed exploring this area on 

my motorcycle. I never visited during any dry or 

dusty periods. Comment noted. 

IND-COM-06 

I am expressing my desire to have access to Goat 

Mtn via R001-T104, as well as access to San 

Carlos Mine Area via R011. My desire is to have 

access for the expressed purpose of flying Hang 

gliders off of areas accessed by these trails. I 

understand the nature of the naturally occurring 

minerals in this area and would limit my speeds 

on these routes to minimize the raising of dust, 

and would support the enforcement of any speed 

limit deemed necessary. Access would be 

required by a limited number of 4 wheel drive 

vehicles usually less than 4; and typically only 

on weekends during the few months a year that 

the weather conditions would be promising for 

cross country flights from these areas. Thanks for 

allowing me to input this request and I hope you 

keep this access open for our use. 

Refer to Common 

Responses Section 3D. 

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Comment Code Summary Response 

IND-COM-07 

Clear Creek is my favorite riding area in the 

United States and I have been to most of the ORV 

areas on the West coast over the last 20+ years. 

The sheer size and beauty of riding in such a 

place made it worth the 17 hour drive. The 

challenge of the terrain also made the trails 

rewarding as well. 

I urge you to re-consider the closure and it's 

negative impact not only on those that live close 

by (like my cousins in Paso Robles), but also that 

it is a treasure for ALL of us in the ORV 

community and AMERICANS the world over to 

keep this place open for our generations and 

future generations to be able to enjoy. 

Refer to Common 

Responses Section 2C 

and 3A. 

IND-COM-08 

I have been to many asbestos classes through my 

work which is for the state of california and this 

type of asbestos in its natural state does not pose 

the same health risk. Proper signage to make 

people aware of asbestos so they can make their 

own judgement should be all you need to 

do!!!!!!!!! this is just another enviromental attack 

against offroad usage and public access to public 

lands. this hurts not only offroaders but campers, 

hikers, hunters, and anyone elese who likes the 

outdoors-----KEEP CLEAR CREEK OPEN LET 

THE PEOPLE MAKE THERE OWN 

DECISION 

Refer to Common 

Responses Section 2A. 

IND-COM-09 

 Loss of Recreation Areas – Clear Creek 

offers unique challenging trails that are 

not available elsewhere. It would be an 

unacceptable loss of access for the 

thousands of visitors who regularly visit 

Clear Creek from the Bay Area, 

Monterey, and San Joaquin Valley. 

 To lower exposure asbestos, harden trails 

can be implemented. Roads also could 

be covered with different soil or road 

base to create corridors of hardened trails 

to allow access to non-asbestos areas. 

 Open more trails in non-asbestos areas of 

Clear Creek to offset closure in other 

parts of the management plan. 

 Limit the number of days people can visit 

Clear Creek in order to maintain a lower 

Refer to Common 

Responses Section 4F 

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level of exposure to asbestos. 

IND-COM-10 

For far too long the government has been creating 

new wilderness areas, that don't even qualify as 

"Wilderness" areas, areas of critical concern and 

using so called endangered species to limit and or 

close off public land to the people who use it 

most. We public land users have agreed to pay 

special fees and assessments to the government 

for the privilege to use our own lands. Our fees 

and love for the outdoors supply more money to 

the government. 

Refer to Common 

Responses Section 1G. 

IND-COM-11 

My two sons, friends, and I have been enjoying 

Clear Creek since the early 1970's and it would 

be sad to see the restrictions imposed by the other 

alternatives which would deprive future families 

the great memories we now share. We have 

enjoyed motorcycle riding, camping, and four 

wheel drive activities throughout these years and 

have appreciated BLM's capable management of 

the area and the staff's always friendly and 

helpful attitude. Of the dozens of family and 

friends I know from children to adults, no one has 

experienced negative health effects from their 

activities at Clear Creek. 

Refer to Common 

Responses Section1G. 

IND-COM-12 

I am an avid OHV user and so is my wife and our 

three daughters. We LOVE riding on BLM land 

in California and spend many weekends a year 

doing so. The Clear Creek Management Area has 

always been a favorite for my family and I and 

we really miss it. I personally have been visiting 

the area for fifteen years and think that closing it 

permenantly would be a terrible decision, if the 

users are aware of the potiential hazards then it 

should be their choice whether to proceed or not. 

I support the no action alternative and look 

foward to being allowed acess to CCMA again. Comment noted. 

IND-COM-13 

When I am lying on my death bed, whether or 

not it is from "asbestos exposure" , I will think of 

the GREAT times I had at Clear Creek. Why 

can't you people understand, that no one will live 

forever, and that we knowingly accepted both the 

risk from the motor vehicles AND the asbestos, 

every time we recreated there? When we first 

started going there in 1975, there were still many 

Refer to Common 

Responses Section 1A, 

1B, 1D, and 4A. 

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"lifers" hanging around there, and to a person 

they said NO ONE THEY EVER KNEW died of 

asbestos exposure. Now we know the Clear Creek 

asbestos is of the non-hooked variety, and is 

either completely inert or relatively benign. 

IND-COM-14 

Resources should be set aside to insure this park 

stay open to the public for OHV use. 

Refer to Common 

Responses Section 3D. 

IND-COM-15 

I can understand closing the area during the 

summer months due to asbestos dust, but winter 

too! So my question is how many deaths can be 

attributed to asbestos poisoning from Clear 

creek? I’m sure the Clear Creek asbestos has a 

unique chemical/mineral tag allowing 

identification if there were any questionable 

deaths! 

Refer to Common 

Responses Section 1F(1). 

IND-COM-16 

i have ridden for many years in the clear creek 

area and i believe that closing it to ohv use is a 

great loss it is public land and should be kept 

open it was well set up and a fantastic experience 

for myself and my sons riding pleasure to close it 

will be agreat injustice to the ohv community 

public land is for public use 

Refer to Common 

Responses Section 2A 

and 4B. 

IND-COM-17 

I do not think that the BLM or anyone else has 

the wright to stop any one from using the land, 

lakes, rivers or streams! Do not close Clearcreek 

or any other public lands. 

Refer to Common 

Responses Section 1G. 

IND-COM-18 

As a former resident of Hollister, and a frequent 

camper, hunter, and off road user of the clear 

creek area I want to weigh in on the impending 

closure of this area to off road use. Stop it. You 

would lock our youth into cities exposing them to 

the life threatening pathology of urban 

delinquency- rather than have them face the 

imagined dangers of asbestos at Clear Creek. 

Refer to Common 

Responses Section 1G. 

IND-COM-19 

1) Access should be allowed on all the county 

roads. The Idria entry is not passable to regular 

passenger vehicles. 

2) I oppose the proposed closure from April 15th 

to December 1st since most of the flowering 

season is in May and the creek areas have flowers 

until late summer. Some sort of access by permit 

should be allowed year round. 

3) I oppose new roads/routes in the Condon peak 

area. The area is impassable in the rainy season 

due to the clay soils. This area has extensive 

wildflower displays. The ridge up to the peak is 

quite steep in areas and building a road would 

have significant impacts. The ridge is an 

excellent hiking route and I feel it should remain 

Refer to Common 

Responses Section 3A, 

3B, and 3D. 

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that way. 

4) I oppose expansion of recreational vehicle 

usage into the surrounding Cantua, Condon and 

Tucker areas. These remote areas would be hard 

to monitor and since they border private lands 

would likely lead to conflicts with private 

property owners. The draft provides very little 

information about biological resources in the 

expansion areas. It would be improper to adopt 

this in a plan without further study. Continuing 

and regulated use in the current areas would be 

preferable to expanding usage into new more 

pristine areas. 

5) I do support aspects of Alternative C, though 

my preference would be to limit usage in the 

CCMA to county roads and passive hiking. It is 

very important that Alternative C eliminate open 

barren use areas and limit the route network to a 

more manageable 150 miles. By limiting travel 

to marked open routes and banning open barren 

usage, motorcycle and OHV usage could be more 

constrained and further damage to the fragile 

resources could be minimized. The barrens of 

Larious Canyon are particularly important to be 

left closed so they can recover. 

6) For OHV usage to continue in the CCMA, the 

RMP must clearly identify sufficient levels of 

funding and staff to monitor and ensure usage is 

limited to the route network. 

IND-COM-20 

Reasons why the Clear Creek area should be open 

to the public: public land funded with tax dollars, 

loss of OHV areas, family recreation and social 

values, [and also because of negative] fiscal 

impact it will have on surrounding communities. 

The OHV populations spends a lot of money in 

local economies for gas, food etc. every year. 

With California already being in a major 

recession this will only help to make things 

worse. 

Clear Creek area serves as access for pig hunters. 

Hunting pigs is one of the hardest things to do in 

California legally. If the BLM keeps Clear Creek 

closed it forces pig hunters on the wrong side of 

the law. A side of the law they didn’t ask to be 

on. Also wild pigs in California do more harm to 

the environment than any OHV. With pigs having 

one of the fasted population growths in California 

Refer to Common 

Responses Section 3D, 

4B, and 4D. The 

Proposed Action analyzed 

in this PRMP/FEIS would 

allow hunting on all the 

CCMA public lands. 

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this decision would only make things worse on 

the environment and surrounding properties 

owners. 

Currently there is plenty of land for people to go 

to that want to get away from OHV’s and hunters. 

Refer to Comments BRC-FORM-LTR 

IND-COM-21 

I am a member of the Mariposa Gem and Mineral 

Club, and our field trips to Clearcreek have been 

suspended pursuant to closing of Clearcreek. We 

are very interested in visiting this area with much 

geological phenomena. Please enter my 

comments that these public lands should indeed 

remain "PUBLIC". 

Refer to Common 

Responses Section 3D. 

IND-COM-22 

PLEASE RESTORE CLEAR CREEK RIDING 

NOW. AS A VETERAN, THIS IS WRONG. Comment noted. 

IND-COM-23 

I am an avid off roader and have heard from 

freinds & family how great the Clear Creek area 

used to be for challenging trails. I don't see why 

after all these years we have to concede & not use 

this area. Please reopen this recreation area I 

would like the chance to make my own memories 

at Clear Creek. Comment noted. 

IND-COM-24 

The 35,000 visitors that recreated at the CCMA 

have been over whelming other use areas and 

creating detrimental effects on these other areas 

from the increased use. There are other areas that 

had been closed to legal OHV use that are now 

getting used again because there is very limited 

areas open for legal OHV use in Central 

California Area. Mariposa County and others are 

getting more complaints of private land trespass 

in the last two years because of the closure of the 

CCMA and the loss of miles of routes on the 

National Forests, along with seasonal closures 

during prime riding time. The BLM instead of 

planning for increased needs of more OHV 

vehicles is doing the opposite and trying to the 

close more areas and routes that are already 

designated for that use. 

Many of the asbestos exposure calculations used 

a very high amount of “dry” samples despite 

known visitor use of the Clear Creek 

Management Area being at its lowest level during 

“dry” conditions. Subsequently, due to the 

inordinate amount of “dry” samples used in the 

EPA calculations the amount of “wet” samples 

Refer to Common 

Responses Section 1C, 

4B. 4D, and 4E. 

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was dramatically reduced despite known visitor 

use of the Clear Creek Management Area being at 

its highest during “wet” conditions, OHV use is 

restricted to October 15 to June 1. This 

methodology guaranteed very high asbestos 

exposure levels. Or in other words, the 

methods used by the EPA guaranteed failure. 

Refer to Comments BRC-FORM-LTR 

IND-COM-25 

I have been hunting the BLM land (Tucker Mtn) 

for close to 30 years. It has always been my 

understanding that BLM had an easement from 

clear creek through Baker canyon. In fact years 

ago their was a sign up sheet for those traveling 

this easement thru privet land to BLM. 

Now, I own land which borders the BLM through 

Baker canyon, (Tucker Zone). I am a firm 

believer that BLM belongs to the people and 

should not be sold to privet individuals. 

PLEASE BE ADVISED, IF BLM FEELS THEY 

DO NOT HAVE AN EASEMENT FROM 

CLEAR CREEK TO BAKER CANYON I WILL 

DEED BLM A EASEMENT THROUGH MY 

PROPERTY FOR PUBLIC ACCESS. 

Refer to Common 

Responses Section 3D. 

IND-COM-26 

Why can't Clear Creek be like other California 

buildings, by putting up a sign that says this area 

is known to have things that "might" cause 

cancer. Then they would be not legally-liable. 

All the winters I have road there, it is almost 

never dusty. When it is dusty in the spring or late 

fall you could close it, and most riders would still 

be riding the Sierras or other areas anyways. Let 

us use this beautiful remote area that no one else 

will use anyways due to all the mines. I live in 

North Dakota during the summers due to my 

work, and they are opening places to ride, 

because they know its a growing industry, the 

public demands it and want the tourist and 

weekend dollars. I'll pay to ride there, just open 

it. 

Refer to Common 

Responses Section 3A. 

IND-COM-27 

The actual danger to health from naturally 

occurring asbestos is low. I feel our public lands 

should stay open and available to the people they 

belong to namely the public. 

Refer to Common 

Responses Section 2A 

and 4A. 

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IND-COM-28 

We have been riding the Clear Creek area since 

the late sixties and in that time I have seen the 

OHV areas decrease and demand explode. We 

need more areas like Clear Creek not less. What 

ever happened to ride or enter at your own risk? 

Speaking of risk of the over 200 people I know 

who rode Clear Creek not one as came down with 

an asbestos related problem and I am talking 

about family members who started riding the area 

in the sixties. 

Refer to Common 

Responses Section 2A 

and 4A. 

IND-COM-29 

I have been riding there since 1969 with no health 

issues. Does that fact account for anything? 

Refer to Common 

Responses Section 2A 

and 4A. 

IND-COM-30 

I am a rock collector who has had the opportunity 

to camp and collect prior to the current closure of 

Clearcreek. I have always wanted to go back to 

collect some other minerals. 

Please don't close all access to the Clearcreek 

area. Despite the dune buggies and motorcycles, 

there are other groups of us who enjoy this 

unique area for the opportunity to collect 

specimens found nowhere else in the world as 

well as just enjoying the scenery. I was well 

aware of the asbestos before I went in and was 

careful to keep the windows up and even wore a 

mask while going thru the area used for off 

roading. Given the health information, let us 

passive users make the choice and allow the 

Clearcreek area to be used by the public. 

Refer to Common 

Responses Section 3D. 

IND-COM-31 

Refer to Comments from Organizations: ORGSCC See BLM responses to 

ORG-SCC. 

IND-COM-32 

Please allow the citizens of California and the 

United States to decide for themselves the risk of 

illness or injury to which they will expose 

themselves. 

Please allow me to take personal responsibility 

for my own life and that of my family. The EPA 

conclusions regarding the risk of asbestos 

exposure from riding at Clear Creek are based on 

excessively conservative assumptions of tolerable 

risk. Mmost people only ride several days per 

year. 

I can accept signing a release of liability or an 

entrance fee to help with management. But the 

complete exclusion of motorcycle trail riding is 

an extreme and unnecessary decision. Please 

Refer to Common 

Responses Section 1C, 

1D, and 4B. 

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inform the public- do not try to unnecessarily 

restrict our recreation opportunities at Clear 

Creek. Please re-open all the Clear Creek trails. 

IND-COM-33 

I and my family have visited Clear Creek on 

several occasion throughout the past 30 years. 

Not one of us has had any health issues because 

of it. My understanding is the the esbestos that is 

found there is not of the industrial type that 

causes any type of health issues. This is an area 

that has been and should still be available to the 

public for recreation. 

Refer to Common 

Responses Section 1A 

and 1B. 

IND-COM-34 Refer to Comments BRC-FORM-LTR 

See BLM responses to 

BRC-FORM-LTR. 

IND-COM-35 Refer to Comments BRC-FORM-LTR 

See BLM responses to 

BRC-FORM-LTR. 

Comment Code Summary Response 

IND-COM-36 

Refer to Comments from 

Organizations: ORGFOCCMA 

Appendix IV - Camissonia 

benitensis Compliance 

Monitoring & Adaptive 

Management Plan of the 

DEIS 

Issue 1: (pg. 628): The use 

of the term “potential” 

habitat is ambiguous and 

can be misleading it should 

be clearly described and 

clearly listed as a lesser 

priority. If Ecology and 

Life History of the San 

Benito Evening Primrose, 

Taylor (1990) and The 

Recovery Plan for 

Camissonia benitensis U.S. 

Fish and Wildlife Service 

(2006) are out of date or the 

BLM feels these documents 

are incorrect a new study 

needs to be conducted and 

reviewed with the findings 

made public. 

Issue 2: At the time of 

obscuring tracks there needs 

RESPONSE 1: It has been clearly documented 

that much of occupied Camissonia benitensis 

habitat consists of serpentine soils on relatively 

level terraces, within close proximity to 

perennial streams. These are the “serpentine 

alluvial terraces” described by Taylor (1990). 

While much of the occupied habitat is located 

within the Serpentine ACEC proper, naturallyhigh sediment loads originating from the 

extensive barrens of the Serpentine ACEC have 

resulted in localized deposits of serpentine 

alluvium in drainages outside of the Serpentine 

ACEC including lower Clear Creek, lower 

White Creek, and lower San Benito River. This 

has resulted in areas of both occupied and 

potential habitat located well outside of the 

Serpentine ACEC. Until recently (April 2010), 

it was believed that the primary habitat for 

Camissonia benitensis consisted of serpentine 

alluvial stream terraces. It is now known that 

Camissonia benitensis also grows in uplands on 

serpentine soils in the geologic transition zone 

between serpentine and nonserpentine rock 

types (see 2010 annual report for Camissonia 

benitensis to the USFWS). Some of this habitat 

consists of serpentine landslides located up to 1 

mile outside of the Serpentine ACEC. There 

are also now a few known examples of the 

species growing on shale outcrops at the 

geologic boundary. The discovery of this new 

type of upland serpentine and shale outcrop 

habitat has more than doubled the number of 

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to be adequate 

documentation i.e. photo 

points, date, time, person 

submitting the 

documentation, OHV or 

other as the cause, and if it 

is a known occurrence or 

potential habitat. Again 

potential habitat should be 

considered a lesser priority. 

Issue 3: There needs to be a 

mechanism in place that 

determines and documents 

other types of activity that 

cause “Disturbance” 

OHV operation is not the 

only possible cause of 

disturbance so the 

description Low, Moderate, 

and High incident of OHV 

non-compliance should be 

further refined. Once again 

potential habitat is a lesser 

priority. 

Issue 4: Why was there no 

mention as to the frequency 

of proposed monitoring for 

Alternative A, B, or C? 

Issue 5: “Introduced suboccurrences” Does this 

mean the BLM is engaged it 

the cultivation, propagation, 

and distribution of a 

federally listed species? 

There is no mention of a 

reintroduction or 

introduction program for 

CABE in the DEIS. This 

program needs to be clearly 

defined in the DEIS. What 

are the goal’s of 

reintroduction / introduction 

by the BLM? 

Issue 6: I have not been 

able to find public listing in 

known suboccurrences of the species, as well as 

more than doubled the total area of known 

occupied and potential habitat. 

Due to additional new types of habitat where 

Camissonia benitensis is found, the following 

disclaimer regarding a strict potential habitat 

definition is warranted: “Therefore, while the 

criteria above are a general guide, the 

consideration of a site as potential habitat 

should not automatically be rejected if it fails to 

match the criteria in every way”. 

Potential habitat is important to recovery of 

Camissonia benitensis. The USFWS indicates 

equal importance of both occupied and 

potential habitat by almost always describing 

actions to both within the same sentence within 

the Recovery Plan. Due to the importance of 

both occupied and potential habitat integrity in 

recovery of the species, equal priority is given 

to both occupied and potential habitat OHV 

compliance monitoring. 

RESPONSE 2: Documentation of OHV tracks 

within both occupied and potential habitat 

always occurs prior to obscuring tracks and 

repairing fence breaks, as needed. Site 

condition documentation parameters are 

described in detail on page 630. Due to the 

importance of both occupied and potential 

habitat integrity in recovery of the species, 

equal priority is given to both occupied and 

potential habitat OHV compliance monitoring. 

RESPONSE 3: In recent decades, OHV 

disturbance has been the primary disturbance. 

This is the reason cited by the USFWS for 

Federallylisting Camissonia benitensis as 

Threatened. The Camissonia benitensis habitat 

monitoring plan was developed with the 

direction of the USFWS. Although the plan 

calls for monitoring of OHV disturbance, we do 

note other incidents of significant disturbance 

that occur on rare occasion, such as recovery of 

large rocks or logs by the public, dragged 

across habitat. The vast majority of 

disturbances observed within occupied and 

potential Camissonia benitensis habitat, 

however, are due to OHV trespass. Due to the 

importance of both occupied and potential 

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Comment Code Summary Response 

the Code of Federal 

Regulation or the Federal 

Register that shows the 

BLM HFO has the 

necessary permitting for a 

reintroduction / introduction 

plan. This needs to be 

addressed in this DEIS 

along with the protocol that 

outlines the BLM’s plans 

concerning the C. benitensis 

re-introduction / 

introduction program. 

Issue 7: Is this GIS data 

based on soil composition, 

vegetation type, slope 

aspect.... or a combination 

of criteria? A project of this 

magnitude will also require 

field time of highly skilled 

staff to supplement GIS 

data and allow for the best 

possible outcome. GIS data 

is a tool, a starting point for 

actual field time to assess 

an area of potential habitat. 

GIS data should not be use 

exclusively to define 

potential habitat. These 

protocols need to be 

understood and clearly 

defined. 

Once again potential 

habitat is used ambiguously 

and needs to be clearly 

defined and if Ecology and 

Life History of the San 

Benito Evening Primrose, 

Taylor (1990) and The 

Recovery Plan for 

Camissonia benitensis U.S. 

Fish and Wildlife Service 

(2006) are out of date or the 

BLM feels these documents 

are incorrect a new study 

needs to be conducted and 

reviewed with the findings 

made public. 

habitat integrity in recovery of the species, 

equal priority is given to both occupied and 

potential habitat OHV compliance monitoring. 

Response 4: Alternatives A – C still allow for 

OHV use within the Serpentine ACEC at or 

similar to those prior to the emergency closure, 

therefore, monitoring would continue at current 

levels. 

RESPONSE 5 and 6: Ryan O’Dell, the BLM 

Hollister Field Office Natural Resources 

Specialist (Botany, Soils, and Paleontology), 

holds a collection permit (TE163671-1) for 

Camissonia benitensis issued by the USFWS to 

collect seed and tissue of species, conduct 

research studies involving the species, 

propagate seed of the species within a 

horticultural setting, and make introductions of 

the species into potential habitat at specific 

locations as approved by the USFWS. The 

purpose of the program is recovery and 

eventual delisting of Camissonia benitensis. 

Introductions are specifically identified as a 

recovery action for the species in the Recovery 

Plan (page 69): “3.3.2 Continue population 

introduction research.” The USFWS has stated 

under that recovery action that “the current 

number of occurrences may be too few for 

recovery of the species,” suggesting that 

without introductions to bolster population and 

plant numbers, the species may not be a 

candidate for delisting. All introduction sites 

approved by the USFWS are located within 

previously identified potential habitat which 

was closed to OHV use prior to the emergency 

closure. All USFWS documents including 

collection permits and reports are public record 

and can be requested from the Ventura FWS 

Office. 

The specific action of “manage potential habitat 

for introductions” (See column “Management 

action: Maintain habitat integrity and diversity” 

in Tables 4.6-1 through 4.6-12) was analyzed in 

Chapter 4.6. Likewise, impacts of the 

introductions on recreation are analyzed on 

page 306 (Impacts from Other Management 

Actions): “Management actions under 

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Issue 8: If there is habitual 

trespass into closed areas 

the BLM need to address 

the individuals whom are 

trespassing and causing the 

damage to the habitat. This 

will require the BLM to 

actively patrol the known 

sixty-four suboccurrences 

during high use times. It 

also is important to educate 

the users of the CCMA 

through signage and 

personal contact through LE 

and responsible OHV user 

groups. Other OHV land 

managers have used these 

methods with outstanding 

results. Closure of the entire 

CCMA because of trespass 

in a select few areas is 

unacceptable. If the BLM is 

not capable of managing the 

resources in the CCMA or 

any lands they are directed 

to maintain there needs to 

be an overhaul of the 

agency with the pubic fully 

involved or the CCMA 

needs to have an agency 

that is capable of 

sustainable management of 

the CCMA. 

Biological resources may preclude recreational 

activities at certain times and locations. This 

includes restricting recreational activities . . . 

near newly re-established vegetation. These 

restrictions are generally limited to very small 

areas, and may or may not be limited to a 

certain time frame, depending on the 

Alternative. While restricting recreation to a 

reduced area, even temporarily, would create 

additional burden on the surrounding recreation 

areas, the intent of these restrictions is to 

enhance the biological or ecological resources 

in the area.” 

The program is being conducted by Ryan 

O’Dell, the USFWS collection permit holder. 

Ryan holds a BS degree in Plant Biology and 

an MS degree in Soils and Biogeochemistry, 

both from University of California, Davis. He 

has conducted extensive studies focused on 

plant adaptation to- and revegetation of 

serpentine soils since 2002. 

RESPONSE 7: Potential habitat mapping is 

based upon the complex interaction of 

topographic position (as related to stability in 

fluvial system), slope, soil development, and 

vegetative cover. Ryan O’Dell maps the 

habitat while on site and then draws it in GIS. 

See Response 1 above with respect to definition 

of potential habitat. 

RESPONSE 8: It is exceedingly difficult to 

catch the individuals responsible for trespass 

into closed areas. In order to cite them for 

trespass, they must be caught “in the act.” 

BLM LE does their best to patrol CCMA, but 

they cannot patrol the entire 75,000 acre area 

24 hours a day, 7 days a week. It is the OHV 

recreationist’s responsibility to know the rules 

of the area they are riding in. 

Non-compliance Closure Levels and 

Thresholds were established in coordination 

with the USFWS. The BLM has the authority 

to close areas due to considerable adverse 

affects to natural resources from off-road 

vehicle damage under federal regulations 43 

CFR 8364.1 and 43 CFR 8364.2 as stated on 

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pages 633 and 634. Notification of the closure 

to the public is stated under regulation 43 CFR 

8364.1 on page 634 and includes closure 

posting at or near the area the closure applies, 

the local BLM office, and publication in the 

Federal Register. 

Comment Code Summary Response 

IND-COM-37 

It is my hope that the BLM will respond to the public 

wishes, and completely reopen the entire CCMA roads 

and trails to all recreational users. If not, I hope some 

compromise may be reached that at least will keep Clear 

Creek Road open to all vehicles traveling between New 

Idria and Coalinga Roads, including street-legal 

motorcycles. 

Some of the draft RMP's alternatives refer to allowing 

road access "limited to full-sized vehicles," however the 

term "full-sized vehicle" is never defined. My touring 

vehicle of choice is a BMW R100GS, a full-size highwaylegal touring motorcycle. I fear that limiting access to 

"full-sized vehicles" may be implemented in practice as 

prohibiting all motorcycles. Discussion with BLM staff 

has indicated that "full-sized vehicles allowed" is BLMspeak for "all motorcycles prohibited." 

Refer to Common 

Responses 

Section 3D. 

IND-COM-38 

My family has ridden off-road motorcycles for over 40 

years and would like to continue to do so. The riding 

areas I grew up with are being closed one by one and it is 

making it difficult for me to pass on this family tradition 

with my children. 

Off Road riding is a great family sport and it keeps my 

children away from Play Stations, Wii’s and other couchpotato activities. A great weekend of riding builds 

confidence, brings our family closer and gives my 

children a healthy outdoor experience. Comment noted. 

IND-COM-39 

COMMENT #1 

Nothing presented so far in the Health Risk Assessment 

demonstrates a severe risk for anyone other than 

motorcycle riders and other ATV riders who spend a lot 

of time ripping up the hillsides at high speeds. The 

"Weekend hunter scenario" (which includes campers, 

hikers, rock 

collectors) can make 5 visits per year under No Action 

conditions, and the mean risk is still within the 

acceptable risk level of 1x10-4 excess cancers. If the 

outlier data points (two points were anomalously 5 and 10 

times the value of all the rest of the data) are excluded 

Refer to Common 

Responses 

Section 1C, 1D, 

2A, and 3A. 

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from the calculations (per EPA Guidelines), the risk 

would be even less! 

CONCLUSION: That means BLM's own Health Risk 

Assessment does not support any reason to exclude 

anyone other than the motorcyclists/off road riders 

("motorized sports"). 

COMMENT #2 

The proposed alternatives offered to the public were 

extremely limited in number and scope. With the number 

of components which go into a single alternative listed in 

the draft management plan, the universe of potential 

alternatives could number in the dozens using the various 

combinations of individual components. The alternatives 

were clearly "cherry picked" by BLM to give FALSE 

OPTIONS to the public, in order to justify BLM's 

preferred alternative of severely restricting public access. 

OBVIOUS SAFE ALTERNATIVES WERE 

EXCLUDED FROM PUBLIC CONSIDERATION. 

COMMENT #3 

One such obvious Safe alternative excluded from public 

consideration by BLM includes: 1) move the 

motorcyclists out of the serpentine area to new designated 

area in the Clear Creek Management Area 2) surface the 

access roads with inexpensive Chipseal to reduce 

airborne asbestos by 98%** 3) Place speed limits on 

unpaved/untreated roads 4) Pave/treat campground roads 

and import clean fill dirt for the campground pads. 5) 

allow unrestricted non-motorized sports access. 6) 

Keep all Roads open. 

My alternative will reduce the SUV risk from driving in 

on access roads by 98%, and the Camping risk by 98% 

(thus reduce the total risk in the "Weekend Hunter 

Scenario" by 98%). 1x10-4 / 98 = 1.02x10-6 risk = 

approximately 1 in a million excess cancers = 

unrestricted land use per Federal EPA guidelines (as 

referenced in the BLM's Clear Creek Health Risk 

Assessment). 

**per studies performed by Cal/EPA Department of 

Toxic Substances Control 

COMMENT #4 

Public access on existing roads must be preserved. 

Therefore alternatives E, F, G are not acceptable. 

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COMMENT #5 

As usual, BLM in typical government fashion, is going 

from the most destructive land use (a motorcycle park) to 

the most protective (closing roads and restricting public 

access), with absolutely no consideration to a moderate 

and safe middle ground. (Therefore alternatives E, F, G 

are not acceptable). 

COMMENT #6 

I want to review the "Responsiveness Summary" to see 

what BLM has to say regarding each of the public 

comments submitted. 

IND-COM-40 

Everything has a risk. Post your findings on a sign but do 

not close the area. 

Refer to Common 

Responses 

Section 3A and 

3D. 

IND-COM-41 Refer to Comments BRC-FORM-LTR 

See BLM 

responses to 

BRC-FORMLTR. 

IND-COM-42 

After reading the proposed Alternative’s A-G of the 

CCMA RMP/EIS I strongly urge the adoption of 

Alternative A (Current Management/No Action 

Alternative). This is the only Alternative I feel 

appropriately balances recreational needs and environmental protection resulting in responsible land 

management. 

I was raised in New Idria and spent decades 

hiking, riding, hunting and exploring the vast backcountry 

surrounding it. As a small boy I swam in handmade 

swimming holes in San Carlos Creek, Clear Creek and 

Sawmill Creek on hot summer days with my family and 

friends. As a young man I spent every spare minute 

riding my motorcycle around the unlimited trails and 

roads in Clear Creek and the surrounding backcountry, 

year round. I still have a vested interest within the San 

Carlos Bolsa drainage, as my family owns land in that 

area. 

Although I no longer have time to explore the 

surrounding areas as I once had, I’m very familiar with 

traversing the various terrain characteristics on foot as 

well as by vehicle, under all weather conditions. I’ve 

experienced firsthand the effects of vehicular scarring of 

pastures and hillsides by motorcycle’s, ATV’s, and 4 

wheel drive’s. My family and I have spent thousands of 

man hours over the past 40 years repairing and preventing 

erosion damage caused by these vehicles that stray off of 

Refer to Common 

Responses 

Section 3D and 

4C. 

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the managed riding areas and end up in the San Carlos 

Bolsa. 

In reading the CCMA RMP/EIS, it is obvious that 

a reason-able amount of consideration has been given to 

protecting the environment and ecosystems scattered 

about the ACEC zone. It also identifies the various 

naturally occurring health hazards within its boundaries 

and references studies conducted by various authorities 

closing with the 2008 EPA study. That study concluded 

that the asbestos exposure exceeds the “PEL” under all 

but foot travel. Taken at face value, the EPA study would 

be alarming to most of the misinformed public. 

Disappointingly though, I found only generalized 

environmental or public health statements pertaining to 

the Cantua zone. This zone, under the BLM”s preferred 

alternative E, is proposed to be opened to year round 

vehicular access as well as under alternatives D & F to 

varying degrees. These alternatives are not only 

inconsistent with the growing emphasis on environmental 

conservation but a complete reversal of status for the 

majority of the zone. The San Carlos Bolsa drainage has 

had restricted vehicular access for almost 100 years. This 

limited access has successfully preserved its fragile native 

environment from irreparable public abuse and misuse. 

As mentioned previously, I’ve explored most of 

the area now known as the CCMA under all surface 

conditions. The Serpentine areas along Clear Creek and 

San Benito Mountain were some of the best riding areas 

in the state, under all conditions. The shale and clay areas 

around Samson Peak, Santa Rita, Lion’s canyon and the 

San Carlos Bolsa were avoided during the wet weather, 

especially the Bolsa and Cantua areas. Those two areas 

are difficult to traverse (even on foot) during wet 

conditions. Over the years numerous vehicles have been 

stranded, damaged or lost in the back country, with the 

occupants having to walk out to safety. There may still be 

two new 1974 Bultaco motorcycles somewhere in the 

bottom of Lion’s canyon. The riders were found after two 

days of walking out towards I-5 and never returned to 

retrieve their bikes. 

During the dry months the threat of wildfires are 

of high concern due to the tall grasses and extreme dry 

conditions typical of the Bolsa and Cantua areas. 

Currently managed grazing by the Martin ranch help 

reduce the fire danger annually. But with the reduction or 

elimination of grazing leases that will end. In addition to 

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that a large part of those areas are choked heavily with 

brush making the open grassy pastures even more 

tempting to venture upon. 

The adoption of any Alternative that opens up 

outlying areas currently having no public vehicular 

access is ill advised and irresponsible land 

management. Therefore, I strongly support Alternative 

A (Current Management/No Action Alternative) and will 

vigorously oppose any other proposed Alternative that 

jeopardizes almost 100 years of preservation and 

ecological protection provided to the San Carlos Bolsa 

and Cantua areas. 

IND-COM-43 

Clear Creek is one of the finest riding areas in California. 

I work in several buildings that contain asbestos and no 

one seems to worry about this asbestos as an issue. 

I want to ride at my own risk. Currently, with Clear Creek 

closed this causes Hollister Hills to be overly packed. 

Hollister Hills must turn away riders and close down 

when it reaches capacity. 

Clear Creek should be maintained as all open. The barren 

hills have been barren for over 100 years before bikes and 

quads were ever invented. 

With Clear Creek closed, my children are unable to 

further their riding skills. We have lost the National Hare 

Scrambles that were held at Clear Creek which is a major 

monetary loss for San Benito County. 

I have not had proof given to me that any rider at Clear 

Creek has gtten asbestos poisoining or cancer. 

The other problem is that the drug growers will take over 

Clear Creek. I am more worried about these criminals 

causing more damage. If riders are allowed then BLM 

will have many more honest pairs of eyes. 

The BLM never sought out any business comments on 

this closure until February 22, 2010, and BLM only 

invited 21 “important” businesses to the economic impact 

meeting. The cimment time for a business was only a total 

of 8 working days. 

Since May 1, 2008 sales at Zoom Cycle Accessories in 

Santa Clarta CA have dropped by 35-40%. The economic 

impacts is huge. We have been in business since 1971, but 

our store chance of closing is very high. 

Refer to Common 

Responses 

Section 1F(i), 4B, 

and 4D. 

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Businesses here in San Benito County have suffered 

greatly. All sales are down, purchases of gas, food, 

supplies, and lodging are down, taxes taken in are less and 

that just because a few to the take CCMA from all the 

people. 

The BLM does not know the actual impact of sales and 

sales tax revenue losses. [By commenters estimate, 

approximately] $1,080,000 in lost sales tax revenue/year 

is occurring now. 

IND-COM-44 Refer to Comments BRC-FORM-LTR 

See BLM 

responses to 

BRC-FORMLTR. 

IND-COM-45 

I am a recreational rock collector and I am quite 

disappointed with the recent direction access to Clear 

Creek has been going. 

Insofar as the possibility of asbestos exposure in the area: 

we smoke cigarettes with a label on the packet, we drink 

alcohol with a warning label, we enter public areas and 

use suspected cancer causing products that are labeled so 

- why can't we use Clear Creek by putting up a 

notification sign or having us sign a disclaimer upon 

entry? 

Refer to Common 

Responses 

Section 2A and 

3A. 

IND-COM-46 

Please reverse your direction as your intended closure of 

the clear creek riding area. Using the natural Asbestos that 

is the same as in Eldorado's County. Placer ville and 

Eldorado's hills area to close this area to ohv is a cop out 

on doing your job to manage the area for the public not 

against them..Ohv has invested lots of our money over the 

years to support the area... If you intend to close it be 

prepared to pay back the money you have used or open an 

equally sized area in Northern California to Ohv... Your 

choice... Ed Santin AMA/d36 offroad congressman 

Refer to Common 

Responses 

Section 2A, 3A, 

and 3D. 

IND-COM-47 

Refer to Comments from Organizations: ORG-TMC 

Numerous pages and page numbers are missing. Missing 

Pages are #17 and # 584. Missing Page Numbers on the 

page are #'s 129, 218, 222, 284, 294, 303, 321. and 475. 

Numbers missing from back facing side of the page are 

(changes page number sequence) #'s 32, 33, 637, 659, and 

691. 

Correct page numbering for a more professional looking 

document. Put any information that might of been on 

missing pages back into the document. 

Refer to BLM 

responses to 

ORG-TMC. 

Refer to Common 

Responses 

Section 1G. 

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IND-COM-48 

Recreation areas are closing with no regard to the social 

costs of the kids. Instead of going out riding and camping 

they are stuck hanging around the local skate parks or 

worse sitting in front of the tv. I want my kids to have the 

same or better recreation access as I have enjoyed in the 

CCMA. 

To kick us out you should have to show us the trail of 

dead bodies. 

Refer to Common 

Responses 

Section 1F(i) and 

4D. 

IND-COM-49 

1. Every American citizen, and visitor, deserves the 

right to enjoy PUBLIC LAND to the fullest, without 

being herded by overzealous government agencies into 

narrow, limited pathways as in Alternative E 

2. Alternative A is the only option that is consistent 

with BLM’s stated mission to sustain the health, diversity 

and productivity of the public lands for the use and 

enjoyment of present and future generations. Please do 

not try to define or limit the ways in which I can enjoy my 

public lands. 

3. How does the asbestos risk translate into a closure of 

Public Land??? Warning labels on alcohol and tobacco 

are deemed sufficient by our society to address the risk 

posed – these products are not banned. Safe sex is 

promoted by our society, yet the practice is not banned. 

California buildings that contain various carcinogenic 

materials bear warning labels – but continue to be open to 

the public. I dare say that more death and disease can be 

attributed to such things, but they are permitted with only 

a label or sign to explain to the public – proceed at your 

own risk and responsibility. 

Refer to Common 

Responses 

Section 2A, 3A, 

3D, and 4A. 

IND-COM-50 

Refer to Table X-6: HGMC-FORM Summary & 

Response. 

Refer to 

Table X-6: 

HGMC-FORM 

Summary & 

Response. 

IND-COM-51 

The NEPA 1502.14 (d) requires BLM to provide a No 

Action alternative. BLM has failed to provide a No 

Action alternative but instead has added conditions to the 

No Action Alternative. 

Refer to Common 

Responses 

Section 3B. 

IND-COM-52 

I am [concerned] about the future of the Clear Creek 

Management Area, and in particular, public access of 

Clear Creek Road. 

Since 1970 I have enjoyed my weekends and vacations 

spent at Clear Creek. Over these many years I have 

brought my family, as it grew to experience the primitive 

camping and teaching my children to ride. I remember the 

camp fires having with my friends and family enjoying 

just one facet of this great state of California. 

Refer to Common 

Responses 

Section 3D. 

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The complete closure of Clear Creek has prevented any 

future plans of this type of recreation. It's all the more 

frustrating to hear that this is supposedly being done in 

my best interest, for a risk that is negligible considering 

the limited exposure, if it indeed exists at all. My risk 

from a collision with a vehicle on highway 25 exceeds 

any risk of exposure to the air at CCMA. 

I hope that the BLM respond to the publics wishes 

to reopen the CCMA roads and trails in their entirety to 

all recreational users. If not, to at least keep Clear Creek 

Road open to all vehicles traveling between New Idria 

and Coalinga Roads, including street legal motorcycles as 

a suggested compromise. It is my sincere hope that all 

parties charged with this important decision base their 

findings in good scientific processes and truthfully apply 

the laws and regulations by which we live by. 

IND-COM-53 

I would like to urge you to keep Clear Creek open . It is a 

source of entertainment as well as a place to just hike 

picnic or go rock hounding. As a concerned citizen of the 

area, I would implore you to reverse the decision you 

have made, concerning this wonderful recreation area. Comment noted. 

IND-COM-54 

My mother’s family settled in this region of California 

before 1910, and several of my relatives live there still. 

Please convey our thanks to the authors of the draft for 

the cogent analysis of the resources of CCMA and the 

public uses of them, for the realistic series of alternatives 

presented, and for the thoughtful analysis of the 

environmental impacts of each alternative. We feel that 

the 90-day period allowed for comments has been 

adequate. Hollister Field Office made it easy to get the 

documents. You mailed us the CD version because we 

were on an earlier mailing list, and you responded 

promptly when we asked for a paper copy. 

Bar OHVs from the Asbestos ACEC 

The analysis in the draft EIS demonstrates that the lands 

in the asbestos ACEC simply are not suitable for OHV 

recreation. The US EPA risk assessment shows that 

asbestos exposure exceeds acceptable levels. EPA found 

that dirt bikes and ATVs are the greatest problem because 

they raise a cloud of dust containing asbestos fibers, 

which are inhaled by riders and by other visitors. The 

most effective way to reduce asbestos exposure is to bar 

those vehicles. 

Refer to Common 

Responses 

Section 3D. 

Thank you. 

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EPA’s sampling method correctly reflects the way OHVs 

are used in CCMA. Although OHV groups have objected 

to sampling from a vehicle following in the dust cloud 

behind another vehicle, it reflects what many riders do, as 

can be seen from photos posted by Clear Creek riders on 

their own web sites. 

Even full-size OHVs such as Jeeps and ordinary 

automobiles can raise a dust cloud. In my travels on back 

roads all over the West, I’ve inhaled quite a bit of dust 

from cars ahead of me. (Thank goodness asbestos soils 

are rare.) On one popular Jeep route we saw dust a halfinch deep after a “Jeep jamboree” event had passed 

through. If full-size vehicles are to be allowed within the 

ACEC, they should be restricted to routes equipped with 

surfacing or dust-palliatives to prevent a dust cloud. 

Benefits of excluding OHVs 

The exclusion of dirt bikes and ATVs from the ACEC 

will have several important benefits for the public 

interest. The asbestos hazard will be reduced to a 

minimum because vehicles will not be raising asbestos 

fibers into the atmosphere. The closure of obsolete OHV 

routes will lead to restoration of natural conditions, 

healing of eroded surfaces, and re-uniting fragmented 

blocks of wildlife and plant habitat. Without OHVs 

roaring everywhere, Clear Creek will become more 

attractive to visitors seeking a quiet place to enjoy nature, 

see the spring wildflowers, have a picnic, go bird 

watching, go rockhounding, or go hunting. All these 

potential public uses have been discouraged by the 

dominance of OHVs in Clear Creek. 

We believe the highest value of lands in the ACEC is as 

natural wild lands, to serve the public as wildlife habitat, 

as watershed, and as a place for quiet forms of outdoor 

recreation. The serpentine area, which is also the asbestos 

hazard area, supports plant life specially adapted to the 

nutrient-poor serpentine substrate. 

The area could also be valuable for the endangered 

California Condor. The condor was reintroduced in 2003 

at Pinnacles National Monument to the north of CCMA, 

and a pair of condors were observed nesting in 2009 at a 

high rocky cliff on a private ranch outside PNM. We urge 

BLM to identify potential condor roosting and nesting 

habitat in the asbestos ACEC and seek advice from the 

Fish and Wildlife Service and other specialists as to the 

best management for this purpose. 

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Future access routes 

While we favor closure of the ACEC to all dirt bikes and 

ATVs, we suggest that a few routes for cars should be 

kept open for access to trailheads for bird watchers, 

rockhounds, botanists, and all who wish to enjoy the 

natural environment of this area on foot. We understand 

that California bird watchers may be submitting 

recommendations to BLM about specific access routes. 

Only vehicles suitable for highway travel should be 

allowed, used for transportation to the trailheads – not any 

form of OHVs driven for the sake of adventurous driving. 

We do not favor the “scenic route” described in 

Alternative E, involving new construction of the Spanish 

Lake road to Wright Mountain. Instead, we favor 

recreation access routes leading in from the periphery of 

the ACEC to trailheads where visitors can enter foot trails 

into the wildland areas. Some of the former OHV routes 

could be suitable for conversion to foot trails, where they 

comply with Best Management Practices. 

For wildlife and plants, it is desirable to have blocks of 

habitat where the center of the block is farther than 1 mile 

from the nearest route. For restoration of native wildlife 

habitat and potential habitat for the California Condor, 

BLM should provide uninterrupted larger blocks where 

passing OHVs will not disturb condors or other wildlife. 

The route networks in Alternative A, B and C are far in 

excess of any need for access to enjoy the natural features 

of CCMA – many OHV routes would be less than a halfmile from the next route, and few places would be farther 

than 1 mile from the nearest route. Alternatives D and E 

are better for wildlife and plant habitat, but they may not 

provide enough access to trailheads for visitors entering 

the area on foot. 

We encourage BLM to discuss reasonable trailhead 

access roads with groups representing nature watchers 

(birds, native plants, etc.) hikers, hunters, and 

rockhounds. In our view, the goal should be to maintain 

blocks of habitat larger than 1 mile across, to benefit the 

habitat and to escape the noise of passing vehicles. If 

there is a vehicle route every half mile, they are too close 

together. 

Offroaders have other places to ride 

OHV riders have complained that if the ACEC is closed, 

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too many riders would be concentrated on a smaller 

system of trails in other places. BLM should disregard 

this factor, because OHV riders have no inherent right to 

ride on publicly owned lands without crowding. If they 

have bought a vehicle for which there are few places to 

ride, they must accept the consequences. 

The State of California operates eight state vehicular 

recreation areas. The counties run other sites as OHV 

parks. BLM operates the Jawbone area and several areas 

in the California Desert. Senator Dianne Feinstein 

recently introduced legislation (S. 2921) to give statutory 

sanction to five OHV recreation areas in the desert, 

namely El Mirage, Johnson Valley, Rasor, Spangler Hills, 

and Stoddard Valley. 

If necessary, crowding can be managed by adopting a 

reservation/permit system, like those used by the National 

Park Service to manage river trips in the Grand Canyon 

and backcountry visitors in high-demand sites such as the 

canyons of Zion National Park and the high country of 

Yosemite National Park. The Forest Service sets 

“trailhead quotas” to prevent crowding in a number of 

sites in the High Sierra. (See Inyo National Forest’s 

trailhead quotas page at: 

http://www.fs.fed.us/r5/inyo/recreation/wild/quotas.shtml) 

Crowding on OHV trails is no excuse for keeping an 

unsuitable area such as Clear Creek ACEC open to 

vehicles. 

Budget considerations 

Others commenting on the draft plan and EIS have 

advocated many miles of routes for OHVs, without 

mentioning the budget implications. BLM has an 

obligation to conduct maintenance on every mile of 

vehicle route to comply with Best Management Practices 

(EIS, pages 643-647) to prevent erosion and prevent 

degradation of vegetative cover and wildlife habitat. In 

the ACEC there are extra costs because workers may be 

required to wear personal protective equipment and 

undergo decontamination after the work day. We should 

not ask any BLM employees to jeopardize their health by 

working on asbestos soils without full protective 

measures. 

A network of 227 miles of OHV routes is described in 

Alternatives A and B, 185 miles in Alternative C. We 

doubt that BLM would have the budget to keep those 

large mileages up to BMP standards. A more modest 

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system of access routes to trailheads would cost much 

less. The final decision should explain how BLM expects 

to pay for maintenance of the routes approved in that 

decision. 

Federal Tort Claims Act 

BLM may be exposed to litigation under the Federal Tort 

Claims Act and other pertinent laws if the final plan 

allows OHV riders to enter the asbestos ACEC. We did 

not see this issue mentioned in CCMA documents we 

have read. 

OHV groups have urged BLM to reopen routes within the 

asbestos ACEC under Alternative A. If BLM does that, 

the agency would be encouraging visitors to enter lands 

where BLM knows they will be exposed to airborne 

asbestos fibers. 

The risk assessment by US EPA establishes that excessive 

asbestos exposure may occur when ATV or dirt bike 

riders enter the area repeatedly and inhale dust raised by 

vehicles ahead of them. If a rider dies of asbestos-related 

illness 10 or 20 years later, will the survivors sue BLM 

for damages? 

A failure to protect the public against the known asbestos 

hazard in the ACEC could expose BLM and the 

Department of the Interior to costly claims. 

IND-COM-55 

I’m very disappointed with the closing of Clear Creek. 

Instead of a two hour (one way) drive to Clear Creek, I’m 

now driving five and one half hours to Jawbone Canyon. 

Day trips are out of the question. Hollister Hills SVRA is 

far too congested. Metcalf is too small and is often closed. 

Stonyford and Cow Mountain are also too far away for 

day trips. I don’t enjoy the terrain at Carnegie either. 

After reviewing the BLM Draft RMP/EIS proposals, I 

think Proposal A is the most desirable. I’ve been going 

to Clear Creek since the late ‘70s and know many others 

who have done the same. Nobody, including the BLM or 

EPA, has been able to find anyone who has ever gotten 

sick from asbestos exposure at Clear Creek. I’d bet a 

million dollars that more people have gotten hurt traveling 

to and from Clear Creek than from any asbestos exposure 

there. Perhaps it would make more sense closing 

Coalinga/Los Gatos Rd. 

This wouldn’t be an issue if a suitable, immediate 

replacement of like size and terrain could be substituted 

Refer to Common 

Responses 

Section 1F(i), 3E, 

and 4B.. 

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for Clear Creek within a two hour driving radius. Fort Ord 

comes readily to mind. Isn’t it being decommissioned 

from military use? They already have a race track and 

suitable infrastructure there. 

IND-COM-56 

The land should be reopened as a OHV area with the 

continued policy of some dry season restrictions. To 

provide a potential safer riding area option, the 

development of the Cantue Zone for additional OHV use 

would be a desirable. 

The Clear Creek area has been know to be an Asbestos 

area well before it became a very popular OHV area. 

Automobile club maps I have seen from the 1960's and 

1970's have the Clear Creek road labeled as an Asbestos 

Hazard. The use of back country areas always have some 

risk. Americans enjoy using their public lands for a 

variety of recreational uses that often put them in risk of 

life and limb. The function of government is to provide 

some basic services and protect our freedom. 

Government should provide information and let the 

people decide on what risk is acceptable to them. The idea 

that shutting down public land to protect the citizens 

makes as much sense as shutting down Yosemite 

National Park to protect us from rock falls, floods, 

lighting and falling from El Capitan etc. Far more lives 

are at risk in our National Parks than I found in any of the 

data found in the Draft Plan. 

If government starts to measure every risk that the 

public could face in public lands I am afraid that this is 

the beginning of the end of outdoor recreation. WE 

WILL ALL HAVE TO STAY HOME AND WATCH 

NATURE SHOWS ON CABLE TV. PLEASE KEEP 

OUR PUBLIC LANDS OPEN TO THE PUBLIC! 

Refer to Common 

Responses 

Section 3A and 

3D. 

IND-COM-57 

I do not believe we, the public, should be arbitrarily 

locked out of our public land because of a supposed but 

unproven health hazard. We, the public, should not have 

to prove that no hazard exists to get that area reopened. It 

should never have been closed in the first place unless 

you, the BLM, can unarguably and scientifically PROVE 

beyond any reasonable doubt that my health is 

significantly affected if I voluntarily choose to spend a 

couple of days there per year. 

Refer to Common 

Responses 

Section 1A, 2A, 

and 4A 

IND-COM-58 

i think all will agree with me when i say that i feel that the 

option the blm has chosen is not fair at all. it seems that 

the focus of the decision is on the ccma only and fails to 

account for the bigger picture. for clarity i think it is 

important to distinguish between 'ohv' that encompasses 

Refer to Common 

Responses 

Section 1F(ii), 

1F(iii), 2A, 3A, 

3D, and 4B. 

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all off road vehicles, and 'dirtbike' that is specific, like atv, 

utv, or suv. 

ccma is dirtbike riders's graceland, we dirtbike riders 

enjoy the scenery just as much as anyone else, but ccma is 

not yosemite. all non-bike users of the ccma could go 

elsewhere for their recreation of choice, or continue to use 

the ccma seemingly without conflict. we 'bike' users have 

no alternative to the ccma and to close us out while 

allowing atv/utv/suv traffic that creates considerably more 

of the poisonous dust you are using to do so is 

discrimanatory, and reinforces the opinion that the closure 

is not really asbestos related. human life in every way is 

detrimental to the ideals of a 'natural' state. by letting 

bikes ride at ccma and thereby concentrating our 'damage' 

to an area already damaged, and not well suited for any 

other purpose not already enjoyed at ccma, the greater 

good is served by preventing that 'damage' elsewhere. 

please consider changing the outlook of the blm closer to 

the other end of the options scale. 

by refusing to have a peer group review any of the 

science, by refusing any information that does not suit the 

closure, by spending two years on this process without 

considering any source other than the epa, the blm has 

continually shown complete disregard for taxpayer money 

or green sticker money, the public opinion, desire for 

accuracy, public trust in a govenment agency, or logic and 

facts concerning the ccma closure and risk. 

IND-COM-59 

In California, our recreation areas get smaller and smaller, 

but the amount of riders just keeps increasing. Funneling 

these tax and fee paying recreation enthusiasts into 

smaller riding areas creates more danger from head ons 

and over usage of the trail systems. We all know that this 

“reducing airborne asbestos emissions” is a cooked up 

LIE from some non-rider. If you are so worried about 

asbestos, put up a sign and let us ride, we all know one 

big windy day does more damage then a thousand riders 

can do in a year. If a person is worried about asbestos, 

they can wear a respirator 

Refer to Common 

Responses 

Section 4A and 

4B. 

IND-COM-60 

1. There are many types of activities that could cause 

health hazards such as drinking alcohol and smoking 

cigarettes, yet those activities are not banned because it is 

not possible to determine what the specific health 

consequences would be for any-one individual. Like 

riding a motorcycle at CCMA, smoking and alcohol 

consumption pose a possible health risk but an informed, 

mature person may do so at their own risk. 

Refer to Common 

Responses 

Section 1C, 1D, 

1F(i), 3A, 3D, 

and 4A. 

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Comment Code Summary Response 

2. Asbestos is a hazardous substance, no one would 

dispute that, but how much do you have to be exposed to, 

to cause a measurable health risk? The CCMA RMP and 

EIS say that although asbestos hazards can be measured 

in other controlled settings, the setting at CCMA is 

intermittent and sporadic and therefore the health risk is 

uncertain. 

3. There are no clear modes of action for asbestos induced 

disease and no threshold for cancer health effects, 

therefore the IRIS cannot be considered. 4: We are not 

able to measure the “non-cancer” health risks. 5: There 

are no available health reports on asbestos related 

illnesses from CCMA. 

If activity options A - F were put to a vote, I couldn’t 

reasonably choose since I don’t know what the reduced 

risk would be between them. How much safer would I be 

choosing between B and C instead of A? Or would I be 

out of my mind to choose any of the options. What would 

a reasonable man, considering this data, choose A or F? 

The problem is that no one can quantify the increase or 

decrease in risk between the two extremes. Is it a lot or a 

little? I think a reasonable man, would try to protect 

public land for the public, and not try to protect the public 

from the land without cause. 

It is important to reduce potential risk by reducing 

exposure, but should done so by being proactive not 

restrictive. For example, dust abatement on heavy traffic 

roads such as R1 and overnight camping areas. Better, 

more informative signage throughout CCMA to allow 

individuals and opportunity to decide the exposure level 

that is right for them, with their use patterns. Vehicle / 

equipment / riding gear wash facilities with showers and 

even vacuums. Provide and encourage overnight camping 

in areas of low or no asbestos to prevent / reduce asbestos 

exposure outside CCMA, 

Finally, I believe CCMA can be reopened for frequent use 

by a wide variety of interests without any more health risk 

that smoking cigarettes or drinking alcohol. 

IND-COM-61 

Throughout the document the material of concern is 

defined as "asbestos". Asbestos is a manufactured 

product and does not occur naturally. There is no 

'asbestos" in the CCMA. In the Executive summary 

alone, the word "asbestos" is used sixteen (16) times. The 

material related to asbestos that is present in CCMA is 

Refer to Common 

Responses 

Section 1A. 

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Comment Code Summary Response 

chrysotile, which has different properties and effects on 

human health than asbestos. Not only is this erroneous 

subject of investigation inapplicable, the use of the word 

"asbestos" is politically misused to create hysteria and an 

invalid description of the conditions that exist at CCMA. 

IND-COM-62 

My [husband] and I wish to express our adamant 

opposition to the closure of Clear Creek. We support 

Alternative A. We feel that if cost is an issue, the Bureau 

of Land Management should charge entrance fees. If 

asbestos is an issue, those same individuals should be 

required to sign waivers upon paid admission. We 

respectfully urge you to support Alternative A, and thank 

you for your leadership. 

Refer to Common 

Responses 

Section 3A and 

3D. 

IND-COM-63 

The CCMA was once a fun beautiful fully sustainable 

trail system for all recreationist. It had access for all, 

including disabled. I think that rock hounding, mountain 

biking, dirt biking, hunting, hoarse backing, and hiking 

are all excellent ways to see this land and I know they can 

all do so on the existing trail system. There has never 

been a single case of cancer attributed to CCMA 

recreation caused by chrysotile, Or from the actuall mine 

workers or families and they saw exposures that no 

recreationists would see. We support the environment but 

also feel that a park such as CCMA can and has been 

sustainably used for generations. 

Refer to Common 

Responses 

Section 1F(i). 

IND-COM-64 

The BLM has omitted a critical piece of 

information from the Clear Creek Management 

Area DRMP/DEIS: The Clear Creek 

Management Area Asbestos Exposure and Human 

Health Assessment did not achieve the goal of 

providing BLM with information on asbestos 

exposures from typical CCMA recreational 

activities. Instead, the Clear Creek Management 

Area Asbestos Exposure and Human Health 

Assessment provided the BLM with information of 

atypical CCMA recreational activities due to the 

recreational activity exposure calculations being 

skewed towards dry (summer like) conditions. 

In calculating asbestos exposures levels for 

recreational activities (motorcycles jeeps, hunting, 

etc) within the Clear Creek Management Area the 

EPA used several samples gathered over four 

different testing periods. The four different 

testing periods were designated by three different 

conditions, “dry” (two dry testing periods), 

“moist” and “wet”. 

Refer to Comments from 

Organiztions: FOCCMAORG 

The EPA risk assessment 

indicates that the exposure 

levels that exist during the 

summer dry season also 

exist during moist 

conditions. While the soil 

moisture content during 

the September, 2004, 

sampling event was zero 

percent, soil moisture 

content during the 

November, 2004, 

sampling event ranged 

from 1.8 to 22.4 percent, 

with a mean of 8.7 

percent. The November 

(i.e. “wet”) sampling 

occurred within a week of 

the CCMA receiving 

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Many of asbestos exposure calculations used an nearly one inch of rainfall. 

inordinate amount of “dry” samples despite known However, the November 

visitor use of the Clear Creek Management Area asbestos exposure 

being at its lowest level during “dry” conditions. concentrations were of a 

Subsequently, due to the inordinate amount of similar magnitude to 

“dry” samples used in the EPA calculations the asbestos exposure 

amount of “wet” samples was dramatically concentrations found 

reduced despite known visitor use of the Clear during the September, 

Creek Management Area being at its highest 2004, sampling event. 

during “wet” conditions. 

IND-COM-65 

Subject: 2008 EPA Document References 

Referring to the Following Paragraphs: 

EPA released the CCMA Asbestos Exposure and 

Human Health Risk Assessment on May 1, 2008. The 

result of the study concluded that visiting CCMA 

more than once per year can put adults and children 

above EPA's acceptable risk range for exposure to 

carcinogens and found increased long-term cancer 

risk from engaging in many of the typical 

recreational activities at CCMA. 

Discussion: 

The 2008 EPA report concluded that only under 

specific activities and conditions did the exposure to 

carcinogens exceed the lifetime cancer risk. Many 

"Typical" recreational activities allowed adults and 

children multiple yearly visits before exceeding the 

threshold for lifetime cancer risk. 

Referring to the Following Paragraphs: 

The EPA's CCMA Asbestos Exposure and Human 

Health Risk Assessment (2008) provides significant 

new information that must be incorporated into a land 

use plan to evaluate the public health risk associated 

with BLM land use authorizations. 

Discussion: 

The Code of Federal Regulations does not state that all 

new information "must" be included in an RMP/EIS. 

Referring to the Following Paragraphs: 

The Federal government has concluded that all forms of 

asbestos are hazardous to humans, and that all can 

cause cancer; although the chrysotile form may be 

less potent than amphibole family in causing 

mesothelioma. 

Thus, in 2004, as part of the process of evaluating the 

Refer to Common 

Responses Section 

1C, 1D, and 2A. 

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Atlas Mine cleanup for possible delisting of the site 

from the federal Superfund list, EPA Region 9 initiated 

an asbestos exposure and human health risk assessment 

for the CCMA to measure the amount of NOA fibers in 

the personal air space by conducting typical 

recreational activities in the CCMA using up-to-date 

equipment and methodology. 

While chrysotile asbestos was the predominant asbestos 

mineral type found in the EPA air samples, almost 8% 

of the PCME fibers were identifies as tremolite, 

actinolite, or another amphibole asbestos mineral. 

There is an emerging consensus in the scientific 

community that amphibole asbestos may present and 

even greater health risk. 

Discussion: 

In above paragraphs specifically bolded statements, the 

federal government including the EPA and BLM admit 

to the need for the most "up-to-date" methods for 

asbestos risk assessment. The 2008 EPA document 

referenced throughout the CCMA DRMP/EIS did not 

use bin specific analysis of asbestos fibers which would 

separately account chrysotile from other asbestos fibers. 

Thus the admitted lower risk chrysotile which makes up 

94% of the serpentine ACEC asbestos fibers was not 

correctly accounted for and the human health risks 

would actually be much lower. 

Recommendaitons: 

The Draft EIS needs to be edited to remove the bold 

statement references as it is false. 

The DRMP/EIS needs to be edited such the bold "must" 

mentioned above is replaced by a non mandatory term 

such as "should" or "can". 

Remove all statements in the CCMA DRMP/EIS which 

refer to the 2008 EPA CCMA document with regard to 

asbestos concentrations including human inhalation 

amounts. 

IND-COM-66 

I am writing to voice my support in reopening Clear 

Creek to OHV use. OHV land is shrinking everyday 

while it's popularity grows. This makes the areas that 

remain over crowded leading to dangerous situations 

and more difficult maintenance challenges. 

Instead of closing OHV land we should be working on 

creating more opportunity for mixed use so that 

Refer to Common 

Responses Section 

4B. 

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famillies can enjoy this together. 

IND-COM-67 

I am in support of opening up the entire clear creek area 

for offroad vehical enjoyment as it was. There are many 

dangers in this world and the excuse of asbestos is a 

sham and an effort to take away land from the public. 

Refer to Common 

Responses Section 

1G. 

IND-COM-68 

Once again I am writing in response to a proposed land 

closure that will prevent family recreation on public 

lands. 

The Clear Creek land closure seems to be based on bad 

science and short sighted management. Even the BLM 

admits that no known case of health injury has occurred 

in the years of OHV use in the Clear Creek area. What 

is the greater risk, families riding motorcycles and atv's 

together, or kids sitting home playing Grand Theft Auto 

or World of Warcraft in front of a computer screen? 

I won't belabor the point with a form letter, rather I will 

just say this: 

I support the No Action Alternative that restores 

historic OHV use on up to 270 miles of routes and 

approximately 450 acres of barrens. Permitted OHV 

events should be allowed. 

If some small health risk is identified by a new risk 

assessment or a review of the EPA's 2008 report, the 

BLM should use signs and educational outreach as a 

way to inform the public rather than closing this 

important OHV area on a permanent basis. 

Refer to Common 

Responses Section 

1F(i), 3A, and 3D.. 

IND-COM-69 

Please apply massive doses of common sense to the 

issue of closing Clear Creek to OHV enthusiasts. I’ve 

been attending these and similar meetings regarding 

this subject for about 20 years now. It is very 

disheartening to go through this over and over.. 

realistically, what are the compelling reasons for the 

closure? Asbestos poisoning? Where are the thousands 

who have dropped dead after all of these decades? 

Protecting the environment? Clear Creek looks the 

same to me as it has for 25 years that I’ve been 

enjoying it, hasn’t really been destroyed much. 

Preserving resources? Please specify which resources 

we have depleted by enjoying this wonderful recreation 

area. Protecting wildlife? Please specify which species 

have been endangered and provide the empirical 

evidence. Seriously, this is a great, big, wonderful 

playground that has been enjoyed by countless 

thousands for many decades. 

Refer to Common 

Responses Section 

2A, 2B, and 3A.. 

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IND-COM-70 

I am a firefighter/emt in San Juan Bautista where i 

currently live and I have been riding @ Clear Creek 

since I was born. My father has been riding there since 

he was a child and his father use to hunt there as well. 

The closure of the area has made a huge negitive impact 

at other ohv parks due to overcrowding and has made a 

huge negitive economic impact. There was NO 

PUBLIC DUE PROCESS in the closure. The EPA has 

said they did not close the area the BLM did. If there is 

a deadly amount of asbestos then show us the # of 

people with cancer directly from Clear Creek. People 

have known the risk for years and still ride out there so 

why fight it or close it down Make Liability Forms Be 

Signed at the entrance and its a win win situation. 

PLEASE REOPEN THE LAND 

Refer to Common 

Responses Section 

1F(i), 3A, and 4B. 

IND-COM-71 

In regards to the Clear Creek Management Area 

Closure. I as a motorcycle shop owner and family 

motorcycle rider strongly oppose the closing of this 

recreation riding area. We need places such as this for 

our industry along for out young children and youths. 

The jobs lost in the state of California alone is rising 

directly from the fact that Your Organizations are 

striping the desire of new buyers,current owners, of 

sales, service and repairs due to the fact Californians 

have NO local places to enjoy anymore. This is 

WRONG make a stand for the "blue collar" back bone 

of this state!!!!! Keep this open, support our 

communities motorcycle business and our job force. Its 

clean by this state of current depression more harm than 

good is being done. 

Refer to Common 

Responses Section 

3D and 4D. 

IND-COM-72 

I have given this great thought & have a lot of ideas & 

opinions & have studied your A through G 

[Comparison of impacts to Recreation Resources] draft. 

There is the economic impact in these times of 

prolonged economic distress & ensuing stress, the need 

for a place to be able to go in a tank of gas to pursue 

one's choice of recreation & stress reduction for oneself 

& ones family & friends. This area is not only diverse 

but close proximity to the huge population of the San 

Francisco Bay Area.. We have treasures in our National 

Parks in California but they are touristy [ expensive]. & 

crowded. The three gateway cities to get to Clear Creek 

are Coalinga off the I-5 ;Hollister & King City off the 

101. All cities could use the money from visitors in the 

form of gas, food, ice,motels, other services & people 

deciding to explore the area further for more frequent & 

longer stays giving a boost to the economy & provide 

jobs.for the local economy.One only has to look at all 

the news sources national & local to see the escallating 

anger and rebellion against all ' government' now 

Refer to Common 

Responses Section 

3D and 4D. 

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erupting into killings, not just protests. America has 

always been the land where we agree to disagree but 

now violence is not only happening all the time but 

more frightening is the ' accepted way of the times' 

attitude; it is a sickness that need to stop & people need 

a place to heal & seek relief from the horrific stresses of 

our times. The BLM has a unique opportunity to 

provide the citizens & visitors with an outlet of 

diversity for all pursuits of recreation, defuse a big 

segment of society stress with all that Clear Creek 

offers while giving the local economy a boost. I know 

your excuse is asbesiosis but not only is that something 

that has been presented as a warning health hazzard but 

we can & do have the right to say we have been 

informed & therefore it is with informed consent that 

we all chose to go to all areas of Clear Creek knowing 

the risks involved. The risk of being killed by road rage 

or being shot as a drive by is escallating very rapidly & 

the effects are immediate re the 20 to 30 plus yeat wait 

for asbestosis to be a diagnosis . Also precedent has 

been set by the sheriff & police & fire dept, when they 

ask[ tell] people to leave from immediate danger ie 

fire, flood, rock & mud slide & they defy orders they 

sign a waver. 

My opinion is reopen Clear Creek Recreational area to 

Hiking, Hunting, Rockhounding, Firearms & Target 

shooting, Camping & staging in the whole area & some 

areas for the OHV people. This is where I found the 

answer that backs up my response/ request and I quote. 

The BLM is responsible for stewardship of our public 

lands. The BLM is COMMITED to manage, protect & 

IMPROVE these lands in a manner to SERVE THE 

NEEDS OF THE AMERICAN PEOPLE. Management 

is based upon the principles of MULTIBLE USE & 

sustained yield of our nations resources within a 

framework of environmental responsibility and sientific 

technology. These resources include RECREATION, 

RANGELANDS, TIMBER, MINERALS, watershead, 

fish & wildlife habitat, WILDERNESS AIR & 

SCENIC QUALITY AS WELL AS scientific & 

Cultural values [ I capatilized the criteria I feel Clear 

Creek has to offer] 

Hopefully you are all familiar with this;, as it is your 

job description your Mission Statement as government 

employees of , WE, THE PEOPLE of the UNITED 

STATES of AMERICA. 

Thank you as I am anxious to pursue my recreational 

activities of rockhounding & just being on the mountain 

in Clear Creek soon. 

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IND-COM-73 

I have been going to this area since 1965. Since that 

time I have Hill Climbed, Flat Tracked, and 

participated in Moto Cross. This area was chosen by us 

because at that time nobody cared what we did there. It 

was an AMA sanctioned Rack Track. That track kept 

myself and buddies off the street and out of trouble. If 

you people who control the PUBLIC'S LAND keep it 

up there will be no place for kids and their families to 

recreate with ATV'S and Motorcycles. It will become 

the private property of Enviro-Mentalists. Make the 

right decision and at the same time help our economy 

along by allowing Clear Creek to be used as it was 

intended. 

The DEIS does not contain any Economic Effects of the 

huge impact to regional economy like gas stations, 

restaurants, lodging, camping supplies, etc. This must 

be added to the DEIS with supporting documentation. 

Why during the worst economic downturn in California 

History does the government fly off the handle because 

some college student had it brought up in a freshman 

enviro-mental studies class. Between Fed, State, 

County, and city regulations being put into effect by #1 

WQCB, and the AQCB at the State level and now the 

Feds what do you want everybody to do. There aren't 

enough street corners to sell shoes on and even then 

most of the street corners are a haven for Drug sales. 

The Environmental Study for Clear Creek Management 

Area failed to take into account the many studies 

showing Chrysotile should not be grouped in with other 

types of asbestos fibers when looking at potential 

carcinogenic properties. 

Refer to Common 

Responses Section 

1F(ii), 3D and 4D. 

IND-COM-74 

As an OHV enthusiast (and father of 2 kids) - you have 

plenty of comments from many OHV constituencies 

outlining the flaws in your draft RMP for CCMA and I 

don't need to add to them here ( but I support all the 

noted flaws that have been pointed out). 

My only comment is that you omitted one other 

Alternative - and that is to reopen CCMA year-round. 

Comment #1: Please add as Alternative A+ (or however 

you want to designate it) into the draft RMP a statement 

that allows for CCMA to be opened year-round to all 

users. 

Refer to Common 

Responses Section 

3E. 

IND-COM-75 

The report filed by the BLM is based on an EPA study 

originating from mostly theoretical analysis of potential 

asbestos exposure hazards. Yet, despite 50 or more 

years of use, there have been no documented cases of 

Refer to Common 

Responses Section 

1F(i), 2A, 3A, 3C, 

and 3D. 

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any asbestos related health problems, correlated with 

recreational exposure at Clear Creek. The BLM and 

EPA must not reference reports/studies that are clearly 

not supported by actual and verifiable health cases at 

Clear Creek. It is an absolute fact that there are no 

cases of illness associated with the use of the CCMA. 

OHV recreation has clearly been the predominant 

activity by past visitors at the Clear Creek Management 

Area over the last several decades. Sadly, the BLM's 

preferred alternative selection, makes no provisions for 

OHV use at all. This represents a complete reversal of 

the current and historical use in the CCMA. Selection 

of a preferred alternative must include at least SOME 

OHV use provisions. Preferably, selection criteria 

would give emphasis to public travel on trails and roads 

as opposed to eliminating it completely. 

Vast acreages of BLM land directly adjacent to the 

Clear Creek Management Area, suitable for OHV 

recreation, could potentially be opened. Omission of 

such an alternative in the DEIS completely ignores the 

thousands of users who are crying out for a suitable 

place to recreate responsibly in their chosen pastime. 

It is virtually impossible to travel in the CCMA without 

some form of motorized transportation. The terrain is 

rugged and forbidding with numerous elevation 

changes. Due to health issues, many users would 

effectively be locked-out of access, without a provision 

for motorized travel. Public lands administered by the 

BLM, must remain accessible to all users, especially 

those who are unable to hike/walk for hours on end. 

Rock hunting, camping, bird watching, etc., would be 

impossible for disabled or otherwise "less than fit" 

members of the public, without motorized access. 

OHV use, especially quad, jeep or dirt bike, leaves the 

smallest footprint, especially when that use is restricted 

to established trails/roads. Horse back riding is simply 

not practical for most people, considering the cost, 

difficulty and strenuous nature of climbing aboard a 

large animal. Concern for our disabled veterans, 

elderly, obese and chronically ill members of the public 

must be represented in the BLM's choice of preferred 

alternatives. Anything less, is a form of discrimination. 

IND-COM-76 

Recently I just celebrated my 68th birthday. For 35 of 

those years, I have been riding at Clear Creek and to 

this date have not suffered any complications from 

asbestos related diseases/complications. Another friend, 

75 years old, has been riding there over 50 years!! No 

Refer to Common 

Responses Section 

4A and 4B. 

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illness and or symptoms of mesothelioma. 

We have outlived your 30 year predictions of the 

potential hazards and remain living witnesses to the 

erroneous assumptions/conclusions presented by the 

studies conducted by "government Representatives". 

For decades, Clear Creek has been a source of great 

pleasure to tens of thousands of off-road enthusiast 

comprised of all walks of life. These same thousands 

also contributed to the local business community thru 

their purchases of gas, camping equipment, food, 

drinks, etc. 

Also, many of those thousands of riders are now 

restricted to riding in a small park south of Hollister, 

which you know creates additional stress on the park. 

This is a great opportunity for the government to 

display it's claim to be the "servants-of-the-people" and 

re-open Clear Creek. 

IND-COM-77 

I am greatly saddened and angered to learn that the 

Federal government, at the behest of a lawsuit from 

environmentalists, has decided to permanently close 

the Clear Creek area to pretty much anything of value 

including mineral collecting. This flies completely in 

the face of more than 100 hundred years of precedent 

regarding the human use of the entire area! This 

decision is a ridiculous decision, an outrageous 

decision, a decision that is socialist/Green 

Party/Progressive in its agenda! 

This is NOT a park where talking about. It is land that 

has been used by humans for a long time AND NOT 

AS A PARK! THAT IS THE PURPOSE OF THE 

BLM--TO NOT BE A PARK! IT SHOULD STAY 

THAT WAY! As for mineral collecting, which I have 

done from boyhood, what do you think will happen to 

the rocks in the area? Let me clue you in: They will 

disintegrate eventually, due to erosion and flood 

tumbling and become sand. This means all the 

beautiful jade and plasma quartz will NOT be there for 

us to enjoy anymore. As for the endangered species: A 

dry year, common in California, and a single lightning 

strike could render your concerns non-existent from the 

resulting wildfires! At least with OHV use you can 

temporarily close it during the dry season. 

Finally, I am sick and tired of the government trying to 

protect me from things I don't need protecting from. I 

Refer to Common 

Responses Section 

1A, 2A and 3D. 

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am, as an college educated citizen, well aware of the 

potential health impact of asbestos/serpentine soils. 

Does that mean your going to close most of the 

northern coast of California too? Pretty much all 

serpentine has asbestos embedded within it. You guys 

need to back off and let ME decide whether I am 

willing to take the SMALL risk of being in the area, 

during the wet season, for a few hours of collecting 

minerals. 

As for hiking: Few of the yuppie progressives in the 

San Fran area are going to bother coming down to such 

a hard core wilderness area. They'll all be too scared of 

the asbestos not to mention the Valley Fever mold. 

IND-COM-78 

The DEIS is very long and difficult. The rationale for 

the choice of alternatives is not clear to me. I have long 

been interested in the wilderness potential of the 

Joaquin Rocks area, and also in the possibilities for 

quiet recreation that would be available in the 

serpentine ACEC if it were not overrun with dirt bikers, 

and I am glad to see recognition of the value of such 

recreation. But I would hate to see restrictions on 

access to the area on the main roads, as appears to be 

contemplated under all of alternatives D-G. It appears 

that elimination of off-road activity in the serpentine 

area would address most of the health problems from 

asbestos without having to limit the number of visits 

per year by hikers, rock-hounds, birders, botanists, and 

others. 

I am not unalterably opposed to the possibility of 

opening up other OHV routes in the CCMA, but 

alternative D could open up OHV routes closer to the 

Joaquin Rocks than the former road closure at Wright 

Mountain. I am violently opposed to any such new 

routes. Since the possible routes are not defined in the 

DEIS, if this alternative were to be adopted, we might 

be faced with new routes that would be subject 

only to an EA. This is not acceptable. I think it might 

have been possible to formulate other alternatives; it is 

difficult or impossible to tell from the draft document. 

I would therefore request that the comment period on 

the DEIS be extended for another 90 days, which I 

believe is also what some of the organized OHV groups 

are asking for. 

Refer to Common 

Responses Section 

3D. 

IND-COM-79 

I have been visiting the Clear Creek area since 1973, 

and would hate to see it closed. 

1. It is an important area for OHV travel, with the net 

Refer to Common 

Responses Section 

3D, 4A, and 4B. 

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loss of other areas when OHV use is growing 

2. I think the danger of the asbestos in the area is 

overblown out of all the people I know no one has had 

any problems because of this area. 

3. This area has some unique minerals found nowhere 

else. 

4. All the work that volunteers have done over the last 

30 years to keep this area open would be for nothing! 

IND-COM-80 

The drop-in box had been removed to your car by the 

time I made it to the front desk this evening at the Santa 

Clara Convention Center. 

Regretfully, I arrived after the principles said their 

piece, but I surmised from the public comments 

afterwards that they disagreed with the validity, 

accuracy and honesty of the study upon which the 

environmental (draft) statement was crafted. 

I tend to agree that there are motives that may have 

swayed the study judging by the outright pathos and 

hyperbola alluded to off highway vehicle activity. 

There have been, what I call disinterested groups, 

meddling with the Clear Creek Recreational assets and 

public access to those assets. First evidenced by calling 

to fact that the rarity of the milk vetch in the Clear 

Creek area. That milk-vetch is a noxious weed to 

some, more commonly referred to as loco weed. 

Then only having succeeded in closing down a small 

portion, another "disinterested" group identified and 

sued in court over the hazardous naturally occurring 

material asbestos along with identified mercury mines 

in the area and I believe, calling parts a superfund 

cleanup.. 

That type of asbestos, to the best of my knowledge 

occurs throughout California and if hazardous to health, 

would prompt the state to erect "Prop 65" warnings at a 

bewildering density in cities and suburbs and 

countries. I believe other respiratory ailments such as 

silicosis occur at rates far higher than that assigned 

ailments identified with chrysotile inhalation. 

That being said, I believe folks that wish to tour that 

area, down wind of that area, or nearby areas should 

Milk vetch does not 

occur in Clear Creek 

Management Area. 

Refer to Common 

Responses Section 

1A, 1B, 1D and 2A. 

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have to sign lifetime liability releases. But that could 

easily expand into all California residents and visitors 

also having to sign lifetime liability releases due to the 

uncertain nature of all the compounds that are floating 

about in our quite clean air. 

Clear Creek should have never been closed, partially 

closed or sections reserved for plants that are not in 

peril of extinction. 

Please open Clear Creek to off highway vehicles. 

IND-COM-81 

At this conjecture in time I am absolutely dismayed. 

What you are proposing to do in the Clear Creek region 

with road closures affects not only myself but countless 

children, elderly, and infirmed. Many of us feel as 

though our government has "rolled" on us. 

Have you forgotten that many local 

families tried in vain to keep the Union Carbide 

Company out of this area when they announced their 

intention to mine asbestos? They (including members 

of my mothers family who were members of the Fawn 

Lake Deer Hunting Club) petitioned government to 

prevent what they knew would one day destroy the 

Clear Creek Watershed. Those men and women who 

served during WWII were well aware of the dangers 

associated with asbestos witnessing first hand ailments 

suffered by dock workers who handled the material. 

Our govenrment officials pretended to be ignorant of 

these facts and allowed a large mining compnay to 

come in and open up the asbestos deposits near Clear 

Creek. You see, our govenrment desired this mineral 

for military and aerospace applications more than it 

cared for its citizenry. Asbestos clouds wafted over the 

region despite guarentees that this would not occur. 

Now you turn around and try to blame off roaders and 

rock hounds for a problem YOU created! Nice try but I 

am not buying your feigned ignorance nor your 

bullying. 

Here is the bottom line. Your 

recomendations are too restrictive. Only the healthiest 

of Americans would be able to continue the passtime of 

rockhounding in this region. As I eluded to before, 

children, elderly, and infirmed would have no 

reasonable access. Even I would have difficulty (at age 

55) hiking in from New Idria especially if I had to 

return to my vehicle the same day, and I used to run 

marathon! Rock hounding is strenuous and requires a 

great deal of searching- as opposed to a simple "walk 

in" and "walk out." Your bureau is not being realistic! 

Contained within the Clear Creek Unit are 

Refer to Common 

Responses Section 

2A, 3A, 3D, and 4D. 

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WORLD CLASS collecting opportunities 

(Neptunite/Benitoite). Gem and mineral varieties found 

nowhere else in our state also exist here. Plasma agate 

would be an example of what I am refering to and what 

I have seen of the unique Clear Creek jadite found by 

members of the San Luis Obispo and Santa Maria Rock 

and Gem Clubs over the years is truly special! We can't 

simply run over to some place else and find material 

like this. 

Many of us middle aged rockhounds who 

have sat at the feet of of the old timers when we were 

first getting our own feet wet in the hobby believe that 

there still exists plenty of potential for completely new 

discoveries in this region. This will never happen if 

you continue to "lock us out" with suffocating laws, 

rules, and regulations. My Congressman, Wally 

Herger, continues to fight for multiple use 

classifications on Federal lands and he sends me 

updates regularly. Your spirit is not one of cooperation 

with the citizenry to find REAL SOLUTIONS but 

seems to me to be doing whatever it is that you 

intended to do in the first place, regardless! We the 

people, do not seem to matter! Quit playing into the 

hands of the well funded and powerful environmentalist 

lobbys and allow the minority groups like rock hounds 

to have a share in land use. 

Please consider giving us access (even if 

it is seasonal) to our beloved (sacred to many) rock 

collecting areas and permitting overnight use in areas 

deemed safe (there are areas where exposure is less). 

Remember that during the winter and early spring 

months asbestos movement is minimal (because of 

cohesion when the soil is wet). 

Commercial operations for Benitoite need 

to have the least restrictions as possible. I personally 

abhor the practice of "bringing material out to be 

screened." Americans deserve the right to see the actual 

strata material comes from first hand, how it is mined, 

and extract the material THEMSELVES from the 

tailings or fresh ore provided by mine owners! "Knott's 

Berry Farm" off location mining is an insult to rock and 

gem inthusiasts. You are lucky to have a business out 

there. Locally where I live, in this topsy-turvy 

economy, businesses are closing up right and left....not 

that you care about the economy. 

While I cannot attend any of the posted 

meetings due to a minute by minute family medical 

situation up in Oregon requiring me to be able to "drop 

everything and travel north," I really wish that I could. 

Hopefully enough individuals will show up or at least 

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respond by mail or email so that we ALL can reach 

some sort of accord. 

Despite what you might first be tempted 

to believe, rockhounds (and many off road enthusiasts) 

are more environmental than you would think. No, we 

are not going to align ourselves with most of the 

environmental groups due to their extremist views but a 

majority of us are CONSERVATIONISTS at heart. 

Every time I go out in the field I witness 

"environmentalists" enjoying nature but why is it that I 

am almost always the ONLY PERSON PICKING UP 

GARBAGE and PACKING TRASH OUT? What I am 

suggesting here is that you have plenty of room to 

negotiate with us and many strengths to build upon. 

Let's forge an agreement that we all can live with and 

be happy! 

IND-COM-82 

Prior to the Bureau of Land Management (BLM) 

closing this area, they estimated that 78,000 people 

used this land annually for hunting, camping, rock and 

gem collecting, off-road recreation, 

hiking/backpacking, and other recreational activities. 

This area is also home to our State rock, serpentine; and 

our State gem, Benitoite. There are more than 40 other 

gems and minerals in the CCMA that have been 

collected by Rockhounds. The CCMA is the only place 

in the world where gem quality Benitoite and Fresnoite 

can be found. There have also been commercial mining 

operations, including a current Benitoite gem mine, 

within the CCMA. 

After attending the BLM’s public hearing on January 

13, 2010 in Coalinga, more questions were raised than 

answered regarding the rational for closing the 

CCMA. 

I have spent days researching why the CCMA was 

closed and I understand that there MAY be a potential 

health risk, however, now that we have been informed, 

I would like to exercise my right as American citizen to 

make an informed choice to use our public lands. I 

would be agreeable to usage fees and restrictions on 

access depending on weather. At most, access could 

necessitate the signing of waivers which knowledge the 

potential harmful effects; releasing liability of county, 

state, federal agencies. 

The BLM closed this area in May, 2008 in response to 

one (1) EPA asbestos exposure evaluation study. There 

has been no reported study of asbestos related diseases 

of miners who worked in the asbestos mines within the 

Refer to Common 

Responses Section 

1A, 1D, 1F(i), 

1F(ii), 3A, 3D, and 

4D. 

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CCRA prior to their closure in the 1980’s. For decades, 

hundreds of employees worked the various asbestos 

mines within the CCRA. No mention of a case study of 

these employees was made in EPA’s report. Was a 

study completed? If not, why? 

An independent study conducted by Geologist E.J. 

Fowkes, PhD. and Archaeologist Ray Iddings in June 

of 2008 states that “...initial observations, pending 

formal mineralogical analysis, clearly suggest that the 

EPA’s sampling route was highly misrepresentative of 

the vast majority of the New Idria (former mine within 

the CCMA) serentinite, and probably more 

representative of the commercial complex that 

supported 150 years of mining activity and the naturally 

occurring contact zones from which these mineable 

minerals were taken.” The report goes on to state that 

“naturally occurring asbestiform amphibole was not 

found. However, historic ore processing equipment was 

found to contain potential asbestiform amphibole that 

had been imported into the area for commercial 

purposes.” Their study found that the only potentially 

hazardous asbestos found was in the equipment 

imported to the area, i.e. pipe installation. 

The conclusion of another report published by 2004 

Sage Publications, “Coalinga Chrysotile: A short Fibre, 

Amphibole Free, Chrysotile: Part V – Lack of 

Amphibole Asbestos Contamination”, states “Direct 

analytical studies using the most sensitive methods, 

conducted over almost 50 years, have failed to find 

amphibole asbestos in Coalinga chrysotile. Further 

evidence that Coalinga chrysotile does not contain 

amphibole asbestos comes from human observations of 

workforces that mined and milled this material and of 

populations living on and near the ore body. To date, 

there has not been any evidence of an attributable 

excess of pleural plaques or mesothelioma in any of 

these individuals. Since pleural plaques and 

mesothelioma are causally associated with exposure to 

amphibole asbestos, their absence is therefore also 

consistent with the view that Coalinga chrysotile is not 

contaminated by asbestiform 

amphibole.” Www.1800mesothelioma.com/asbestosdetail.htm defines the different types of asbestos and 

defines the chrysotile type found in the CCMA as the 

least harmful. 

So many of the references found regarding the 

chrysotile (aka: white, curly fiber, and short fiber)” 

404
 
 

 

 

 

 

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asbestos, as found in the CCMA, indicates that it poses 

a minimal health risk. As an adult citizen, I have 

experienced warnings from the government on the 

dangers of mercury in the fish, tobacco in cigarettes, 

alcohol use, etc. Yet, with all the studies to show that 

these may be harmful, they have not been banned. The 

government has warned that tobacco causes cancer, 

however they allow us to make the choice to smoke or 

not. Why is this any different? I feel this is a socially 

acceptable risk, and that I should be allowed to decide 

if I want to take it or not. Although we do not have 

lobbyists like the tobacco industry, let us have the right 

to make our own choice when it comes to asbestos 

exposure in the Clear Creek Recreation Area; do not 

take away my right to make an informed decision! 

Also, are society should be encouraging family 

activities more that ever, so limiting access to people 18 

is not acceptable. 

As more and more public land is being closed, more 

and more people are being forced into smaller areas, 

which then negatively impacts those areas. Then those 

areas are closed. This is a lose/lose for everyone. 

IND-COM-83 

Please, I grew up riding there, I know 80 year old men 

who rode all there life's at Clear Creek that are perfectly 

healthy. If it is legal to smoke a cigarette, then it should 

be my choice if Clear Creek is unhealthy to me. 

Obviously somebody just wants this place closed, they 

have tried many times for other reasons without 

success. Now they have finally found one that is 

working for them, so they will go full bore with it. 

Please let us ride motorcycles there, we are truly 

running out of places to ride. I had to buy a bike for the 

street, because the dirt is disappearing. 

Refer to Common 

Responses Section 

1G. 

IND-COM-84 

From what you offer in the BLM Clear Creek Draft 

Plan I would favor Alternative A. 

But I do not think that is the way to go, please start 

over. Let’s go back to the way is was forty years ago. 

Tear down the fences, open the area up; it should be an 

open area not limited to the few trails and roads that 

you have proposed. 

I have been going there for the last forty five years and 

no one I know or have I heard of any has experienced 

negative health effects from their activities at Clear 

Creek. 

Refer to Common 

Responses Section 

1G. 

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IND-COM-85 

Refer to Table X-6: HGMC-FORM Summary & 

Response. 

Refer to Table X-6: 

HGMC-FORM 

Summary & 

Response. 

IND-COM-86 

As a long time rock hound I have frequently visited the 

Clear Creek area without feeling any threat from the 

asbestos. I assume all responsibility when I enter the 

area. The sign age relieves you of any responsibility. 

KEEP THE AREA OPEN!!!!! 

Refer to Common 

Responses Section 

3D. 

IND-COM-87 

I hope rock hunters will still be able to collect minerals 

at the Clear Creek in San Benito County. The danger of 

asbestos is mostly for dirt-bikers, and not mineral 

collectors. 

Refer to Common 

Responses Section 

3D. 

IND-COM-88 

I am writing in favor of re-opening Clear Creek for all 

activities. I have enjoyed 20 plus years rockhounding 

in this park and already miss weekend trips to the area. 

The geology of the area and the many new minerals 

that have been identified in Clear Creek are tremendous 

importance to the scientific community globally. There 

are no cases of mine workers or BLM personnel ever 

having physical difficulties because of the asbestos. 

Please strongly consider re-opening the park for our 

enjoyment again. 

I have attended the meetings and read your documents 

and was not impressed with the EPA study as it was not 

done using data as the park is actually ustilized. For 

this reason and the many more that are constantly 

brought to your attention, please open Clear Creek. 

Refer to Common 

Responses Section 

3D. 

IND-COM-89 

Many people and families have enjoyed this area for 

camping, rock-hounding and OHV recreation for many 

decades, I have been since 1980. 

Today the CCMA is closed off to everyone due to the 

decision by the BLM Hollister, Ca. based on their 

opinion that an EPA study suggests that there exists 

potential harm from natural occurring asbestos found 

there. No single study in and of itself is conclusive. 

Asbestos is a man made product that uses naturally 

occurring minerals such as chrysotile in the process, 

chrysotile is only one of the minerals that can be used . 

The environmental study for Clear Creek Management 

Area failed to take into account the many studies 

showing chrysotile should not be grouped in with other 

types of asbestos fibers when looking at potential 

carcinogenic properties.This study contradicts a study 

performed by Stanford University in the 1970's, which 

essentially concluded that the potential harm to humans 

was extremely remote. Not all forms of minerals used 

to make asbestos have been found to be harmful. These 

Refer to Common 

Responses Section 

1A, 1F(ii), 3D, and 

4A. 

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minerals occur naturally through out the state of 

California. If the potential harm found in CCMA was 

real, then one would expect to find cases related to 

asbestos caused harm in the hospital and medical 

records of people who have recreated, worked and lived 

in the area. You would also expect to find a general 

awareness on the potential harm in the local population. 

People have been living, ranching, mining, and 

recreating in this area for more than 100 years. 

Asbestos exposure becomes a health concern when 

high concentrations of asbestos fibers are inhaled over a 

long time period. People who become ill from inhaling 

asbestos are often those who are exposed on a day-today basis in a job where they worked directly with 

asbestos and/or in the manufacturing of asbestos. 

Actual health risks could be much lower than those 

estimated in the CCMA assessment since the recreation 

area dosen't have the same exposure times as the 

studied occupational examples. The DEIS must 

consider the uncertainty rather than using worst case 

scenarios. 

IND-COM-90 

Refer to Table X-6: HGMC-FORM Summary & 

Response. 

Refer to Table X-6: 

HGMC-FORM 

Summary & 

Response. 

IND-COM-91 

Please do not close the Clear Creek area off from the 

public. It is a beautiful area with a lot to offer the 

public. It has multiple uses for recreation and 

enjoyment for all ages. If the area needs to be managed, 

then manage it. Closing it totally off would be a shame. 

If there is too much dust being created by certain use, 

manage that specific use. Don’t close it off to all use 

just because there is a problem in one or two. My 

husband and I have spent time in the area and enjoyed it 

very much. We are looking forward to spending more 

time in the future. 

Refer to Common 

Responses Section 

3D. 

IND-COM-92 

Hello, My family mostly rides down in Hollister- but I 

have some friends that love to ride at Clear Creek but 

they say they can't ride there due to closure, please try 

to keep it open because riding places are becoming 

harder to find that are convienent and close to our 

houses, my family and I travel all the way from napa to 

hollister which is pretty far, thanks and please provide 

more recreational places for the public. 

Refer to Common 

Responses Section 

3D. 

IND-COM-93 

My friends and I had been hunting deer, pigs and turkey 

at the Clear Creek area for the 15 years before the May 

2008 closure. We are concerned that we might not be 

able to access our favorite hunting spots that we access 

Refer to Common 

Responses Section 

3D. 

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from many points along R002. We access these areas 

by driving our 4-wheel drive vehicle up the R002 with 

our windows closed. If vehicles are no longer allowed 

to drive up that road then we will not be able to hunt 

that area. None of us own ATV vehicles and we are all 

too old to be walking up that road. It is enough of a 

workout to hike from the R002 road to access our 

hunting area. It would not be practical to be carrying 

game that we killed by walking the extra distance up 

and down the R002 road to Jade Mill Campground. 

We would like to see BLM leave the 3 mile section of 

R002 above Jade Mill Campground open to vehicles. 

An alternate access to the BLM land south east of 

Tucker Mountain would be great, although that could 

take years to get a willing landowner to coordinate that 

with BLM. 

IND-COM-94 

Subject: Factors that the agency has completely 

overlooked, but would change the outcome if known 

to the Decision maker, 

No epidemiological studies of recreational exposure to 

asbestos were included in this document, and, 

The large number of mesothelioma cases in the 

California cancer registry provides the opportunity for 

further study, and, 

The USEPA is not the sole expert; in fact they have no 

data for “excess lifetime cancer risk” for recreational 

exposures. All of their data is extrapolated from 

occupational exposure data. 

Discussion: 

BLM has relied solely on the EPA”s report which states 

: "Uncertainty related to the toxicity parameters of the 

risk characterization includes the application of the 

IRIS and OEHHA asbestos toxicity values, which were 

developed from epidemiological studies of 

occupational exposures, to infrequent and episodic 

recreational exposures. This uncertainty could mean 

that the actual risks could be much lower than those 

estimated in the CCMA assessment". 

BLM did not solicit reports from known experts outside 

of the EPA, nor did they include research contradictory 

to the EPA report that is readily accessible to the 

general public through internet search engines. 

Subject: The EPA did not use the most up to date 

protocols for assessing risk and did not differentiate 

risk from different types of asbestos. 

Refer to Common 

Response Section 

1D and 1F(i). The 

overall costs of 

obtaining 

epidemiological 

studies of 

recreational 

exposure to asbestos 

are exorbitant. 

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Clear Creek Management Area Appendix X 

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Discussion: 

In 2003 scientists D. Wayne Berman, Aeolus, Inc. and 

Kenny S. Crump, Environ Corporation prepared a 

document by request of U.S. EPA. The final draft of 

this document is called: “FINAL DRAFT: 

TECHNICAL SUPPORT DOCUMENT FOR A 

PROTOCOL TO ASSESS ASBESTOS-RELATED 

RISK." 

Nowhere in the Draft RMP EIS, nor in the EPA 

CLEAR CREEK MANAGEMENT AREA 

ASBESTOS EXPOSURE ANDHUMAN HEALTH 

RISK ASSESSMENT is there any documentation of 

studies that determine what constitutes “typical CCMA 

recreational activities”. Even in the OHV recreational 

community there is disagreement about what 

constitutes “typical CCMA recreational activities”. 

Without documented studies, “typical CCMA 

recreational activities” can only be anecdotal 

speculation. Different assumptions would almost 

certainly have led to different sampling methods and 

different results or conclusions. As a result the EPA 

report is flawed and results in a DRMP/EIS that 

significantly impacts recreation in the CCMA. 

Conclusion: 

BLM used a report with no evidence of any real 

analysis, which was skewed towards one alternative 

only. This will cause foreseeable significant impacts to 

recreation in the CCMA. BLM must disregard the 

entire EPA report, or commission further balanced 

studies on human exposure to Chrysotile asbestos in the 

CCMA, and incorporate those studies into this planning 

process. 

IND-COM-95 

Alt. "D" is a viable option. The DEIS does not 

adequately analyze this alternative due to "no public 

access" but, New Idria Road goes very close to the 

Tucker area and Los Gatos Rd already provides acess to 

Condon. Developing new staging/camping areas 

inside the CCMA but outside the ACEC is a viable 

option that would cost less money than locating, 

studying and developing another OHV area. 

Refer to Common 

Response Section 

3C. 

IND-COM-96 

We need more access and more miles of trails for 

multiple use, not less for motorized users. It's time to 

realize we all own public lands, not just hikers. 

All decisions must be made for the most common good 

as defined as most use by all in a shared managed area. 

Closing trails to certain type of users is not Comment noted. 

409
 
 

 

 

 

 

 

 

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management, its laziness and giving in to PC. 

IND-COM-97 

Substantive Comment # 1: 

Subject: Errors in Estimation of Usage 

Regarding the following paragraphs found on pages 

referenced 

1.REC-VIS-EF2. Provide a limited number of 

recreation facilities in the Tucker, Condon, and Cantua 

zones to meet increased recreation demand while 

protecting natural and cultural values and providing for 

public safety. (Page 85) 

2. Over the past 20 years, motorized vehicle use has 

been more closely managed as a result of increasing 

demand, (Page 132 3.1.1) 

3. The number of annual recreational visits to CCMA 

public lands continues to increase, primarily because of 

their proximity to urban areas such as San Jose, San 

Francisco, and coastal communities (Page 136 3.1.4.3) 

4. The amount of OHV use would also be sustained at 

35,000 visitor use days, with slight increases over the 

life of this plan. (Page 446 4.7.3.2) 

5. The OHV-related environmental impacts from 

increasing OHV use on the CCMA route network 

would affect soil erosion, damage to vegetation, 

wildlife habitat fragmentation, and the spread of 

invasive species.(Page 149 3.3.5) 

6. However, OHV use has increased over the past thirty 

years, the resulting impacts to scenic qualities are 

highly visible in Clear Creek Canyon, and are expected 

to continue to increase in designated vehicle use areas 

within CCMA. (Page 3.16.4.2) 

7. Current observations are that OHV use at CCMA is 

not increasing at the rate of other OHV areas, although 

publicity and population growth would be expected to 

contribute to slight increases in CCMA visitor use over 

the life of this plan. (Page 305 4.1.2.1) 

8. Current observations are that OHV use at CCMA is 

not increasing at the rate of other OHV areas, although 

publicity and population growth would be expected to 

contribute to slight increases in CCMA visitor use over 

the life of this plan. (Page 308) 

9. Recreation use of public lands is expected to increase 

as population grows not only in the Central Coast and 

Diablo Range areas that support local use but also 

throughout the HFO and California. If recreation use 

were to grow at a rate proportional to population 

Comment # 1: 

Refer to Common 

Responses Section 

1G. 

Comment # 2: 

Refer to Common 

Responses Section 

2B. 

Comment # 3: 

Refer to Common 

Responses Section 

2A. 

Comment # 4: 

Refer to Common 

Responses Section 

3C. 

Comment # 5: 

Refer to Common 

Responses Section 

1F(i). 

Comment # 6: 

Refer to Common 

Responses Section 

1D. 

Comment # 7 & 8: 

Refer to Common 

Responses Section 

1C. 

Comment # 9: 

Refer to Common 

Responses Section 

1E and 3D. 

Comment # 10: 

Refer to Common 

Responses Section 

4A. 

Comment # 11: 

Refer to Common 

Responses Section 

1C and 1D. 

Comment # 12: 

Refer to Common 

Responses Section 

1F(ii). 

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growth in the Central Coast and Diablo Range areas, 

over 50,000 annual visits would be expected, compared 

to the estimated fiscal year 2006 use of 43,000 visits. 

However, a more likely scenario is that the increase in 

recreation visits would far exceed population growth as 

competition for recreation space accelerates and as 

word of the recreation opportunities on BLM lands in 

CCMA spreads. If use were to triple during the life of 

this RMP/EIS, over 

90,000 visits annually would be expected. (Page 522 

4.15.2.4) 

10. OHV recreation users have been riding on the 

barrens with increasingly frequency over the past 40 

years. (Page 598) 

The statement and table below contradicts the 

statements above. 

In 2007/2008, recreation use in the Planning Area was 

estimated at 35,000 visitor days, with about 80% of this 

attributed to OHVs. These estimates have not changed 

drastically over the years, even with the increasing 

popularity of OHV recreation in California. (Page 135 

3.1.4.2) 

Table 3.8-1. CCMA Visitor Use Year Visitors 

2003 50,000 (Estimated) 

2004 50,000 (Estimated) 

2005 43,235 

2006 43,187 

2007 35,267 

2008 28,428 

2005 CCMA closed between June and Oct. 15 

2006 CCMA closed between June and Oct. 15 

2007 CCMA closed between June and Oct. 15 

2008 CCMA closed May 1 

Dialogue 

Visitor use, shown above in table 3.8-1, has been 

declining. CCMA was closed one month early in 2008. 

But we can extrapolate the visitor use that would have 

occurred. The 2007 figures of 35,267 equate to around 

4,700 visitors a month. The EIS attest the highest usage 

is in the wet months. May is not a wet month so adding 

only 2,500 to the 2008 totals, which brings the figure to 

an estimate of 30,928. This represents a drop of around 

39% since 2003. All of the above statements are 

contradictory – these estimates have not changed 

drastically through the years shown in Table 3.8-1, 

even with the increasing popularity of OHV recreation 

in California Page 135 - or in error. Concerning Table 

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3.8-1, It is critical to know the number of unique 

visitors because the health assessment risk is based on 

individual exposure.
 

To bring the EIS into compliance with CEQ regulation
 

15001.1 (b) I request the following changes
 

be made:
 

Requested changes made by statement number:
 

Statement 1: Remove “to meet increased recreation 

demand.”
	

Statement 2: Remove “as a result of increasing
	

demand.”
	

Statement 3: Remove entire statement.
 

Statement 4: Remove entire statement.
 

Statement 5: Remove entire statement.
 

Statement 6: Remove entire statement.
 

Statement 7: Remove entire statement.
 

Statement 8: Remove entire statement.
 

Statement 9: Remove entire statement.
 

Statement 10: Remove entire statement.
 

Concerning Table 3.8-1: The DEIS should indicate the 

BLM does not have information regarding the number
 

of unique visitors to the CCMA area.
 

Also remove the entire dissertation 3.3.5 “Trends and 

Forecast” on page 149. Since CCMA usage has been 

declining, this has no quantitive relationship with
 

CCMA
 

Substantive Comment # 2:
 

Subject: Purpose and Need –California Condor Issue
 

The California Condor’s diet consists of medium and 

large-sized dead mammals like cattle, sheep, deer, and 

horses in any state of decay. Condors may travel 

several hundred miles in search of food. The habitat 

range for condors in central California includes about 

15,000 square miles, of which CCMA provides about 

48 square miles, or .3% of the condor’s habit. 

Therefore, because the condor habitat contribution is 

insignificant, the CCMA management plan cannot 

produce any significantly quantifiable habitat 

contribution for California condor. 

The Bureau of Land Management discussion of 

“Cumulative Effects” on page 442, state the following: 

numbers but continue to suffer from ongoing contacts 

with humans and human artifacts such as power lines, 

which elevates the significance of relatively unoccupied 

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regions such as CCMA to the species. However, the 

Agency’s discussion fails to show how CCMA 

recreation would effect condor habitat because no 

CCMA recreational activities involve utilization or 

installation of “power line.” 

The Bureau of Land Management has failed to show a 

cause for action necessitating inclusion of the 

California Condor in the resource management plan or 

the environmental impact statement. The BLM has also 

failed to show a significant Purpose and Need for this 

discussion in the management plan or environment 

impact study, or how CCMA recreation affects the 

California Condor habitat. Therefore, the California 

condor is not a specific factor requiring update of the 

management plan, and hence such discussion must be 

removed from the Purpose and Needs statement and 

must not be included in the final environmental impact 

statement. Therefore the subject statement should be 

rewritten as follows: 

address listing and/or additional habitat needs for 

species protected under the federal 1973 Endangered 

Species Act (ESA), including the red-legged frog, and 

tiger salamander. 

Substantive Comment # 3:
 

Subject: Erroneous Statement
 

Referring to the Following Paragraph: ES.1,
 

paragraph 5, Page I
 

The EPA report (May 2008) clearly states that the risks 

are uncertain (marked in bold).
 

"Uncertainty related to the toxicity parameters of the 

risk characterization includes the application of the 

IRIS and OEHHA asbestos toxicity values, which were 

developed from epidemiological studies of occupational
 

exposures, to infrequent and episodic recreational
 

exposures. This uncertainty could mean that the 

actual risks could be much lower than those 

estimated in the CCMA assessment"
 

The BLM should correct the report and replace the 

words "The result of the study concluded" to "The EPA
 

report indicates the risks are uncertain".
 

Substantive Comment #4:
 

Subject: Failure to follow NEPA guidelines
 

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BLM has failed to provide a No Action alternative but 

instead has added conditions to the No Action 

Alternative. 

Substantive Comment #5: 

The EPA report fails to show any health risks by not 

providing an Epidemiology report which would back up 

their data. 

For a variety of reasons, it is very difficult to do a valid 

epidemiological of the health outcomes from either 

occupational or recreational exposures at CCMA. 

Discussion 

The EPA failed to disclose this very important 

information in their 2008 CCMA Asbestos Risk 

Assessment even though Jere Johnson knew about this 

information well in advance of the report being 

published. It's required by CEQ (1502.22 Incomplete or 

unavailable information) to disclose these types of 

information when it's critical to the assessment. 

Add to the DEIS a notice that asbestos risks evidence is 

lacking. 

The BLM EIS must indicate there is no epidemiological 

information available from the EPA because the EPA 

finds it too difficult to obtain a valid epidemiological 

report. 

Substantive Comment #6: 

The EPA report indicates the information regarding 

health risk is uncertain. BLM should not consider the 

EPA report as "significant". 

The EPA used as guidance procedures from a 

Superfund site. This has nothing to do with recreational 

use at CCMA. BLM used the EPA document 

incorrectly by claiming the EPA document relates to 

asbestos risks relating to recreational use, which it is 

not. 

Substantive Comment #7: 

The EPA report regarding health risks associated with 

Asbestos at CCMA does not apply to average 

recreational users, rather it was based on 30 year usage. 

Until a study which depicts normal recreational usage 

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study is provided by the EPA, BLM is required to 

remove all references to Asbestos risks to recreation 

users. 

Substantive Comment #8: 

The EPA report did not use typical recreational 

activities. The average rider does not ride at CCMA for 

30 years. 

The test methodology used did not simulate a typical 

day. Most motorcycle riders spend the majority of the 

day on single track trails where dust is less of an issue 

than when travelling down roads. 

The EPA used a more realistic average in the 1991 

ROD and used an incorrect average in the 2008 Risk 

Document. In either case real numbers need to be used 

based on counting the visitors. This has never been 

done so the EPA is guessing. The EPA is required to 

use accurate data. 

Substantive Comment #9: 

43 CFR 9239.2-5 Settlement and free passage over 

public lands not to be obstructed. 

Section 3 of the Act of February 25, 1885 (23 Stat. 322; 

43 U.S.C. 1063), provides that no person by force, 

threats, intimidation, or by any fencing or enclosing or 

any other unlawful means shall prevent or obstruct or 

shall combine or confederate with others to prevent or 

obstruct any person from peaceably entering upon or 

establishing a settlement or residence upon any tract of 

public land subject to settlement or entry under the 

public land laws of the United States or shall prevent or 

obstruct free passage or transit over or through the 

public lands. 

BLM has illegally closed access to CCMA which are 

our public lands. 

Substantive Comment #10: 

The BLM is using the 2008 EPA Asbestos Risk 

Assessment as evidence when the document is only an 

assessment. BLM fails to identify there is lacking 

information that shows scientifically there is an 

asbestos risk at CCMA. 

Substantive Comment #11: 

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One key point from the asbestos toxicity evaluations 

that form the basis for the IRIS slope factor is that 

smoking status is important in evaluating the 

probability or risk of lung cancer. Asbestos exposure 

and smoking appear to be synergistic for lung cancer. 

Smoking increases the risk of disease from asbestos 

exposure, because the risks associated with each 

stressor contribute to total risk. The US EPA’s IRIS 

toxicity value was based on mortality statistics from 

1977 population data, including smokers. Since then, 

the number of smokers in the population has 

decreased. Therefore, the risk calculations may 

overestimate risks for CCMA users based on current 

population smoking patterns but may 

underestimate the risk for the population of users that 

smoke. 

Discussion 

The BLM Draft EIS/RMP fails to mention that smoking 

has decreased and risk calculations may overestimate 

risks for CCMA users based on current population 

smoking patterns. 

The BLM needs to include information that identifies 

that risk calculations may overestimate risks for CCMA 

users based on current population smoking patterns. 

Substantive Comment #12: 

BLM failed to mention the PTI study done in 1992. 

This report clearly indicates the EPA study which uses 

the IRIS toxicity values will have an overestimate of 7 

times. BLM needs to include the PTI information in the 

EIS, or remove all references that are made to the EPA 

risk assessment. 

IND-COM-98 

I would like to make it clear that I oppose closing Clear 

Creek to OHV, specifically off-road motorcycles. I 

have ridden there for years, and the "asbestos" (actually 

serpentine) has never been a health problem. 

I demand that you re-open Clear Creek to OHV 

enthusiasts. It is one of the few motorized recreation 

areas left in CA. 

Comment # 1: 

Refer to Common 

Responses Section 

1B. 

IND-COM-99 

Refer to Table X-6: HGMC-FORM Summary & 

Response. 

Refer to Table X-6: 

HGMC-FORM 

Summary & 

Response. 

IND-COM-100 

For thirty years now my family and close friends have 

used Clear Creek as a gathering spot for 

reunions,birthdays and camping , not to mention the 

Comment # 1: 

Refer to Common 

Responses Section 

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incredible terrain for our hobby of motorcycle 

riding.These times have been interrupted,and are 

terribly missed.Please open Clear Creek,there has to be 

a compromise. 

3D. 

IND-COM-101 

Enough is Enough!!! 

The facts are out there that chrysotile asbestos is 

harmless to humans. Scientific journals such as The 

New England Journal of Medicine, International 

Journal of Health and Research by Taylor and Francis, 

and Review Article: Indoor and Built Environment by 

E.B. Ligren has proved that chrysotile asbestos is 

harmless to humans. The facts about CCMA chrysotile 

asbestos are: 

-No asbestosis or mesothelioma has ever been 

associated with CCMA exposure 

-Scientific studies show that chrysotile asbestos is 

harmless 

-Mesothelioma is an extremely rare diseases 

-There is no natural amphibole asbestos danger in the 

CCMA 

-The EPA study focused on historic sites contaminated 

with imported asbestos 

Need I remind you that the EPA is also responsible for 

environmental disasters like mandating the 

reformulation of gasoline that caused MTBE to poison 

our drinking water and caused millions if not billions of 

dollars to replace gas station storage tanks? The EPA 

was also responsible for the reformulation of diesel fuel 

that destroyed thousands of engines and put the hard hit 

trucking industry under further financial strain a few 

years back. Simply because they did not test the 

reformulated fuels compatibility with fuel injection orings was irresponsible and shows the lack of good 

judgment of the EPA. Further proof is the fiasco of the 

head of CARB Hein T. Tran's phony PhD that shows 

that bad science by fake scientist has caused more harm 

than good to this great country. 

Also, the closure of CCMA (and likely now Carnegie) 

has caused further crowding of Hollister Hills and 

Metcalf. I've seen more accidents caused by crowded 

conditions recently. It is a rare day when you don't see 

an ambulance blaring (or helicopter) away headed to 

some down rider because of a head on with another 

rider, or because of the poor trail conditions caused 

with over use. I personally know of a young rider who 

recently broke his neck and is paralyzed from the neck 

Refer to Common 

Responses Section 

1A, 1B, 1C, 1D, 4B, 

and 4D. 

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down. He wanted to be an astronaut after he graduated 

from college. Now he sentenced to his wheelchair 

where he can't even feed himself. Supposedly the EPA 

is saving us from asbestos by closing CCMA, but 

instead the EPA is making trail conditions more 

dangerous caused by overcrowding. 

IND-COM-102 

Refer to Table X-6: HGMC-FORM Summary & 

Response. 

Refer to Table X-6: 

HGMC-FORM 

Summary & 

Response. 

IND-COM-103 

We are a non-profit organization dedicated to the 

education of the public, specifically: 

"To create, develop and encourage a general interest in 

and appreciation of the earth sciences and all allied 

subjects." (Articles of Incorporation) and to: 

"...disseminate knowledge of mineralogy and the earth 

sciences... and to encourage study in these subjects 

through means of ...field trips for exploration, study and 

collecting of specimens..." (By-Laws) 

We feel we have a very legitimate claim for our 

continued access to the CCMA and would oppose any 

restriction therein as hampering our ability to fulfill our 

mission on behalf of all the people California as 

described above. We consider the CCMA to be one of 

the premier gem and mineral areas in the country. It is 

the only area in the world where gem quality benitoite 

gemstones and specimens may be found, and is the 

locality of discovery of a significant number of unique 

minerals. 

Without access by knowledgeable people to explore 

and study this area, it is very likely that other unknown 

and potentially important minerals will remain 

undiscovered. We have a particular interest in the 

Benitoite Gem Mine and the jade and agate collecting 

areas located along Clear Creek and the Clear Creek 

Road. We have also visited many of the other mines in 

the area including many of the abandoned mines in 

search of gem material and collectable minerals. Areas 

that are available for gem and mineral collecting and 

discovery are drastically shrinking – everywhere. 

The loss of so many collecting and study areas to 

urbanization and set asides for parklands or other use 

make it imperative to do everything reasonable to keep 

important and otherwise remote areas like the CCMA 

open and accessible to responsible and well informed 

individuals and organizations in pursuit of knowledge 

Refer to Common 

Responses Section 

1A, 1B, 1C, 1D, 3A, 

3D, and 4A. 

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that benefits all people for all time. 

We question many of the base assumptions and are very 

much concerned with the approach used in your draft 

environmental statement (DEIS) wherein you consider 

all types of naturally occurring asbestos as being of 

equal health risk, when there is growing evidence that 

such is not the case, and those risks being based on 

occupational health studies involving manufacturing of 

and manufactured asbestos products. We do not think, 

as it has not been demonstrated, that all serpentine soils 

exhibit the same toxicity as assumed in your 

consideration of alternatives, and we do not believe the 

occupational health studies you cite are applicable to 

the very limited exposures that might be encountered 

during our occasional studies within the CCMA. We 

also note the DEIS fails to identify or cite any actual 

case where an individual has contracted any of the 

negative health conditions specified as the cause for 

alarm for which this exercise is undertaken. 

There are at least 20 different serpentine soil types 

within the CCMA with varying amounts of the various 

types of asbestos. A more comprehensive soil survey is 

needed to determine the amount of the various asbestos 

types to be found in the various serpentine soils. 

There are approximately 1,000,000 acres of serpentine 

soil areas throughout California spanning 44 of the 58 

counties. Serpentine soils are known to occur in 19 

states beyond California. A broad brush approach of 

lumping all serpentine soils as presenting an equal 

health hazard when considering alternatives for dealing 

with naturally occurring airborne asbestos, in our view, 

it is not an acceptable approach from a human or 

practicable standpoint when considering management 

alternatives by a land management agency. 

IND-COM-104 

As someone who grew up in the New Idria Mining 

District and has mined gems and minerals from the 

region for over forty years, I feel you are doing a great 

injustice to all the future generations of hikers,bird 

lovers, nature lovers, rock-hounds and outdoor 

enthusiast who cherish and absolutely love that area. If 

liability is the issue, have people sign away their right 

to find the government liable. Geologically the New 

Idria Mining District is a very unique area in fact 

nothing else quite like it exists accept in the Ural 

Mountains. 

Face it guys California is full of Asbestos, there are 

Refer to Common 

Responses Section 

3D. 

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some great sites in the bay area, that has far better long 

fiber than anything found in Clear Creek. 

IND-COM-105 

I was born, raised, and still live on the Birdwell Ranch 

in Los Gatos Canyon. So I am very familiar with the 

Clear Creek area and adjacent BLM lands. I would 

describe them as beautiful, stark, a treasure of minerals, 

rocks, rare and unique flora, and wildlife from lizards to 

chipmunks to the mountain lion. 

The serpentine landscapes are easily abused. On the 

barrens lichens, mosses, and plants that are able to 

tolerate shallow, nutrient poor soils take years to form 

in the harsh climate. They are fragile, easily uprooted. 

Open OHV use on these unique geologic features 

causes devastation that may never be restored. 

If BLM is mandated to provide the OHV recreationists 

a place to ride I would rather see Clear Creek reopened 

with enforced designated use, and stronger restrictions 

on riding areas, than to see BLM open up new lands 

that would surely be used as OHV recreation areas. I 

say this as a person with deep love and respect for the 

land, and someone who enjoys the quite beauty of the 

landscape. 

Clear Creek Management Area (CCMA) was visited by 

hikers, naturalist, rock hounds, and people just looking 

for a unique and beautiful place to visit. Don’t close the 

main Clear Creek Road to the people that use the area 

responsibly. 

As for a recreational staging area at the Condon Peak 

access and new roads including a road to Condon Peak 

I am strongly opposed. We need areas where there are 

no roads only hiking trails. The area is used by hikers, 

hunters, rock hounds, and naturalist including bird 

watchers and botanists. It would be impossible for 

BLM to keep OHV use out of the area, and would 

provide access for traffic to the red zone. Law 

enforcement would need to be upgraded and constant. 

The soil in that area is highly erodible adobe, not suited 

for a staging area. 

Condon Peak access area is also within shouting 

distance of Lee Scazighini’s home. From his house 

vehicles, guns, voices, campground noise in general 

would be heard. Vandalism would very likely be a 

problem. BLM needs to consider this and strive to be a 

considerate neighbor. 

I strongly oppose the loss of any grazing leases to 

Refer to Common 

Responses Section 

3D, 4C, and 4D. 

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recreation. Furthermore, I strongly oppose the opening 

of any new OFIV recreation areas and trails 

(Alternative D is unacceptable). 

IND-COM-106 

As a person that used the area once or twice a year for 

about 3 years. I do not feel my health as been effected. 

But since the BLM seems bent on closing the area 

forever a compromise should be in order. Instead of the 

government givith the government taketh-away. Why 

not open an new area that does not impose a health 

risk? Instead of just saying you can't ride clear creek 

anymore? Oh and it's for your own health concerns. 

So there are air borne asbestos fibers. Instead of closing 

it how about riders using resperator requirement? I saw 

the pictures of the EPA guy where one when he was 

sniffing the area on that ATV. 

Has there been any evidence of anyone having health 

problems that used the area for recreational use? 

Refer to Common 

Responses Section 

1D, 1F(i), 3A, and 

3C. 

IND-COM-107 

As someone who has lived and worked at Idria for over 

60 years, and the last 30 years in the San Carlos Bolsa 

area, I am intimately aware of the re-creational uses in 

the Clear Creek and surrounding areas. 

1. I am strongly in favor of Alternative A. 

(a) Excellent motorcycle riding in the 

Serpentine zone. 

(b) EPA report of asbestos hazard overstated. 

Flawed field work. 

(c) I know of no known lung problems caused 

by using the Clear Creek area from riding 

in the last 60 years. 

2. BLM preferred plan Alternative E 

(a) Opening the road to the Bolsa, Cantua 

area to motorized vehicles will be harmful 

to the surrounding ecology and public 

safety. 

1. This area is wild, beautiful and 

basically undamaged to date. 

2. The road into this area has been 

closed to the general public for more 

than 100 years. Locked gates at Lillis 

(Martin) ranch on the east and Idria 

on the west. 

3. This road over the shale formations 

becomes impassable after modest 

rainfalls. The resulting muds are 

unbelievable and vehicles will 

Comment 1: 

The CCMA Draft 

RMP/EIS and this 

PRMP/FEIS identify 

the recreation 

resources values in 

Section 3.1.4. 

Please refer to 

Common Responses 

Sections 1C, 1D, 

1F(i), and 4A 

regarding the EPA 

risk assessment. 

Comment 2: 

Please refer to 

Common Responses 

Sections 3A, 3C, 

3D, and 4C 

regarding vehicle 

use in the Cantua 

Zone. 

Comment 3: 

Section 3.10.of this 

PRMP/FEIS 

identifies the results 

of a wilderness 

character inventory 

conducted during 

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become trapped. 

4. Due to the open grassland sections, 

controlling vehicle use over the entire 

area is impossible. Much damage 

will occur. 

5. The fire hazard will be greatly 

increased. One to two feet tall oat 

grass is tinder dry in summer. 

6. Numerous archeological occurrences 

(native Indians). 

7. Prolific and varied flora and fauna in 

riparian zones. 

3. The BLM should do everything possible to 

protect this area as a wild and natural zone. 

The country, from Three Rocks to Tumy Gulch 

and be-yond, should be preserved as a semi 

wilderness. There are few comparable areas left 

in California. 

Summary: 

I support alternative A, and strongly oppose any 

alternative proposing to open the Bolsa, Cantua area to 

motorized travel. To do so will endanger the public and 

result in damage to the surrounding country. 

Controlling vehicular use will be impossible. 

this land use 

planning process in 

accordance with 

FLPMA Sec. 201. 

IND-COM-108 

I strongly believe that Clear Creek should be reopened 

for off-road use . The areas that pose a health risk due 

to asbestos should be marked as in the past and users 

beware . Most off road users do not use the area once 

late spring or summer has started due to dust and high 

heat. 

Refer to Common 

Responses Sections 

3A and 3D. 

IND-COM-109 

I strongly advocate that each of you vote to open ALL 

County Roads in the Clear Creek Management Area at 

the meeting on April 6, 2010. These are public roads 

and should be re-opened for use as such. Public lands 

in California are used and enjoyed by a broad crosssection of residents and we appreciate your careful and 

thoughtful consideration in favor of this request. 

Refer to Common 

Responses Sections 

3A and 3D. 

IND-COM-110 

I have been following the controversy regarding the 

proposed BLM closure of the Clear Creek area and 

would like to add my comments. I have been to this 

area several times to visit the Benitoite Gem Mine. I 

understand the desire of the BLM to protect the public 

from dangerous asbestos exposure, but I also feel that 

occasional visits in closed vehicles that are unlikely to 

allow significant exposure to air-born particles should 

not be banned. I also feel that the public should be 

allowed to make decisions for themselves in this matter 

Refer to Common 

Responses Sections 

3A and 3D. 

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after receiving appropriate and accurate warnings 

regarding relative risk. Total closure of the entire area 

for all public use strikes me as an over-reaction to a 

minor health hazard. 

IND-COM-111 

I am both a member of the Ventura County Motorcycle 

Club and an Certified Industrial Hygienist whom 

happens to be credentialed with the State of California 

as an Asbestos Consultant professional. I have 

reviewed the Clear Creek EIS on the impact of the 

naturally occurring asbestos. 

I do not accept complete closure of such a large historic 

area just because asbestos is located in the region. 

Asbestos is common, so common in fact , it is our state 

mineral. With riding occurring in the CC area for over 

60 years, why has there been no evidence of health 

damage if this area and crysotile asbestos is so 

dangerous? 

In my opinion, the 2008 EPA CCMA Asbestos 

Exposure is a flawed study that needs to address 

additional available information. The human risk 

analysis is based on flawed assumptions. This study 

needs more real information utilized to be of any 

verifiable importance. 

Refer to Common 

Responses Sections 

1C, 1D, 1F(i), 3A 

and 3D. 

IND-COM-112 

The area has unique geologic interest and mineral 

collecting should be allowed. 

This area has much to offer for photographers of nature. 

The landscape is fantastic. I have been waiting to have 

access to use my new digital camera. 

There are many ways to mitigate known health risks 

and these can be as simple as paving roads in risk areas. 

Education on how to access the area and minimize dust 

exposure should be done. I have been negatively 

impacted by the current access restriction to the area. I 

look forward to being able to once again, explore and 

enjoy the Clear Creek area. 

Refer to Common 

Responses Sections 

3A and 3D. 

IND-COM-113 

The paragraph entitled “Waivers of Liability and 

Indemnification of Risk” on page 352 says: 

“Therefore, the potential for waivers of liability or 

indemnification of risk as ‘stand-alone’ mitigation 

measures for human health and safety do not satisfy the 

purpose and need for the CCMA RMP/EIS.” 

Discussion: 

“Protection of human health and the environment” is 

not a goal listed in the Purpose and Need required by 40 

C.F.R. § 1502.13, and in accordance is not a mission of 

Refer to BLM 

responses to ORGSCC. 

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the BLM, and it therefore cannot be one of the 

management objectives being addressed in the EIS. 

The “overall protection of human health and the 

environment” is not a valid management objective for 

purposes of the EIS. The BLM's statement “potential 

for waivers of liability or indemnification of risk as 

‘stand-alone’ mitigation measures for human health and 

safety do not satisfy the purpose and need for the 

CCMA RMP/EIS” is invalid. 

Recommendation: 

Remove the invalid statement from the EIS and replace 

it with the following text: 

“Despite this, if implemented with due care, waivers of 

liability or indemnification of risk constitute viable 

means to permit the continuation of existing levels of 

activity within the ACEC while acknowledging that, 

although fraught with uncertainty, studies and reports 

on the postulated health risks of asbestos in CCMA still 

have value.” 

IND-COM-114 

I would like to express my support for Alternative A 

from the Draft RMP/EIS for Clear Creek. This is the 

only sound alternative. There needs to be significantly 

more studying done by the EPA and other 

INDEPENDENT scientists before the closure can be 

final. 

- more tests should be conducted 

- more analysis needs to be completed 

- the public should have a stronger influence in this 

process 

While the above points are getting collected, CCMA 

should be opened and enjoyed in the interim. I don't 

agree with the closure, it was hastily done and poorly 

executed, CCMA should be reopened immediately. 

Refer to Common 

Responses Sections 

1F(iii), 3A and 3D. 

IND-COM-115 

Subject: Erroneous Statement 

Asbestos is an man made product, not a naturally 

occuring substance. Remove all occurances of 

"asbestos", "natually occurrring asbestos", and "NOA" 

with the "chrysotile" which is the technically correct 

term for the mineral of concern. 

Subject: Erroneous Statement 

The EPAs report is at best inconclusive. Also, there are 

other studies that contratict this one in terms chrysotile 

fibers collected. Therefore, additional studies must be 

Refer to Common 

Responses Sections 

1A and 1F. 

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performed until the facts are clearly understood. Since 

there is not yet a real health hazard, CCMA must be 

restored to the preclosure status. 

Subject: Erroneous Statement 

The EPAs data gathering model is erroreous. No off 

road motorcyclist rides directly behind another rider 

when it's dusty. The EPAs model does not reflect real 

world exposesures. There model does reflect a potential 

worst case scenario, which only shows why common 

sense rules should be followed to minimize exposure. 

IND-COM-116 

Although I am on the board of directors of the 

Fluorescent Mineral Society, I am writing to you as an 

individual. This well known and highly respected 

organization is composed of an international 

membership. As you might deduce from our name, we 

specialize in the collection and study of fluorescent 

minerals. As such we are quite interested in the 

retention of access to mineral collecting areas. Clear 

Creek is one such area. It is home to several rare 

fluorescent minerals including fresnoite, benitoite, and 

karpatite. The unique mineral formations there also 

offer an interesting variety of fluorescent minerals in 

the asbestos and mercury families. Fortunately I had 

the opportunity to collect in the area shortly before it 

was closed; some of my prized mineral specimens 

come from the Clear Creek area. 

Opportunities to collect minerals, whether for pleasure 

or scientific pursuits, are becoming increasingly limited 

due actions of both private and government entities. 

Although the western United States is blessed with a 

trove of mineral species, their distribution tends to be 

localized depending upon the local geologic past. One 

must go where the minerals reside. If collection is 

prevented because of arbitrary restrictions, then the 

community as a whole (not just the hobbyist and 

scientist) will be intellectually impoverished. 

The BLM has been entrusted with the control of vast 

tracks of public land. I am sure you agree that this trust 

is to be administered for the public good. It is in your 

power to re-open Clear Creek to the public and I 

respectfully request that you do so that the public may 

once again enjoy the benefits of this unique area 

Refer to Common 

Responses Sections 

3A and 3D. 

IND-COM-117 

If the public is notified as to the potential danger caused 

by asbestos in dust, then it is up to the recreational 

users to make the decision to use Clear Creek or not. 

This information can be made public via on site 

Refer to Common 

Responses Sections 

3A and 3D. 

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signage, notification in local publications, off road 

periodicals, and email sites. 

IND-COM-118 

As a resident of Coalinga, Clear Creek is a very 

important to me as it is the only close opportunity for 

significant recreation on public land. Comment noted. 

IND-COM-119 

Please keep this riding area open for people like me to 

ride with my kids. 

Refer to Common 

Responses Sections 

3A and 3D. 

IND-COM-120 

In a time when more and more of our public land is 

close to us, (the public) I request you re-open the clear 

creek management area to OHV use. The OHV 

community takes great pride in this trail system and are 

the ones who maintain them. You will not see greater 

volunteer involvement, trail maintenance efforts, or 

area clean up as you do from the OHV users. We are 

the one who truly take pride in this area, therefore I 

request an immediate re-opening. 

Refer to Common 

Responses Sections 

1F. 

IND-COM-121 

I have visited this region for camping, hiking, and rock 

hounding for five years. I believe that there is a great 

need for this land to remain public and open for some 

recreations. There are few areas of such an interesting 

geologic make up as Clear Creek. It is this very 

unusual mineral make up that has caused the concern 

over the area. I recognize the concern and the need to 

manage the land to limit exposure to Asbestos. 

It is true that the use of this area as an off-road driving 

area is not a good idea. The off-road riding raises great 

amounts of dust that can then be inhaled. I respect 

individuals desire to ride off-road and wish there were a 

way to protect these riders from the hazards of this dust. 

Short of paving the whole area, there is no way to 

achieve this safety. 

This land is multi-use however, and the other uses of 

this land are not creating dust and disturbing the 

topsoil. The small amount of dust caused by rockhounding is not endangering anyone. Hiking is not 

harming the soil either and does aid visitors in seeing 

the landscape and many features of the area. Upland 

hunting is another activity that is safely not disturbing 

the soil and one that is enjoyed by many as a public 

right. 

As a rock-hound myself I feel there are so few areas 

that allow legal collection that I need this area 

accessable. The paving of the main access roads and 

prohibiting off-road riding seems to be the best solution 

possible. I am sure that many off-road riders will be 

upset by this apparent change of the BLM's use 

Refer to Common 

Responses Sections 

3A and 3D. 

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standards in the area. I would like to say that they 

should be able to take there own risk, but after seeing 

very young children following there parents on dirt 

bikes in a cloud of dust, I have to decline that argument. 

IND-COM-122 

I have been a frequent off road user of Clear Creek for 

over 25 years. I pastor a church in Danville, Ca of 

around 500 people. We have around 10 families who 

frequent Clear Creek to camp and ride off road. I am a 

Sherriff chaplain for the county and a Fire chaplain as 

well. My good friend Rich Burkett owns the Burkett 

Ranch which borders the entrance to Clear Creek. They 

have owned their ranch since the 30's. We love Clear 

Creek and it is the only place like it in close proximity 

to the Bay Area. We were devastated to have it shut 

down to the public. I have never heard of a single case 

of cancer or asbestos related illness stemming from 

occasional use of Clear Creek. My friend Rich has 

never heard of a single case among all the ranchers 

surrounding Clear Creek in their 80 years of owning 

their ranch there. All the years of mining and trucking 

asbestos in its raw form have not had any measurable 

negative health results. Yet, the EPA shut it down. I 

understand the mandate to protect the public from 

health hazards but this has gone too far. The scientific 

thresholds for measuring asbestos seem biased and 

unreasonable. The science regarding the affect of 

minimal contact with particles of unrefined asbestos is 

skewed to accomplish a shut down. Clear Creek could 

hardly be more remote than any other off road riding 

area in the state. A vast majority of off roaders only 

visit a few times a year. Ultra violet rays from the sun 

pose a great threat of skin cancer to the public but the 

EPA does not prohibit people from going out into 

sunlight or getting sunburned. Living on the planet has 

many inherent risks. Just riding a dirt bike poses a 

potential for harm, but we permit people to own and 

ride. The risk of riding in this remote area is very, very 

low as it relates to contracting asbestos related 

mesotheleoma cancer or any other respiratory disease. 

The EPA might have finally produced the 

measurements they needed according to their own 

science. They and other groups have wanted to close 

down Clear Creek for over 20 years. In all those years 

no one has produced any clear link to riding in Clear 

Creek and adverse health affects. This land belongs to 

the public and I have no concerns for taking my family 

to Clear Creek at all. The road to Clear Creek is far 

more dangerous and has actually claimed lives. But the 

government is not going to shut the highway down. 

Allow the public to continue having full access to one 

Refer to Common 

Responses Sections 

1A, 1B, 1C, 1D, 

1F(i), 2A, 3A and 

3D. 

The decision to 

install a vehicle 

wash rack was 

approved in both of 

the BLM’s previous 

Record(s) of 

Decision for the 

1999 and 2006 

CCMA RMP 

Amendments. 

427
 
 

 

 

 

 

 

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of the most beautiful and popular riding areas in the 

state. We all acknowledge the presence of an asbestos 

mine and no one disputes the health risks of refined 

manufactured asbestos. But Clear Creek does not 

present that kind of threat or risk. Has there been one 

single law suit won against the BLM related to an 

actual proven case of asbestos related illness? The 

closing of Clear Creek was an extreme measure and not 

really in the best interest of the public who has 

frequented this place for 50 years. We are just sick 

about this. Now, according to my friend Rich, my 

government is spending millions to truck in (not too 

successfully he reported, i.e., highway not wide 

enough) some special engineered vehicle washing 

stations at Clear Creek. Another example of 

government misusing tax dollars and using the asbestos 

alarm to create an excuse to grow the government 

machine. I am sure there are some sincere folks who 

really believe they are looking out for the public and 

believe they know what is best for us in spite of our 

protests. But this is way too much and not necessary. 

Please reopen our land. Has anyone from the Salinas 

Ramblers, who have owned property at Clear Creek for 

their off road club for decades ever reported health 

issues related to unrefined asbestos exposure? 

INDCOM123 

As a 4-wheelers and Jeep owner I have had the opportunity to 4-wheel 

and camp in the Clear Creek area for several years prior to the closure. 

With 4-wheeling, and many other outdoor activities we are aware of 

the risks involved. 

I would encourage the BLM to re-evaluate the science used to create 

this Draft, and re-open Clear Creek, under Alternative A with 

modifications. 

I am not a scientist, and much of the information included in the Draft 

was intense. Six types of asbestos that occur naturally in the 

environment, two specific types of asbestos, located in the CCMA, 

amphibole and chrysotile (fibrous serpentine). Amphibole fibers are 

brittle, and a rod or needle shape, and are less common in commercial 

use. Chrysotile fibers asbestos has long, flexible fibers. 

Page 333, 4th paragraph: Exposure Assessment – “Most of the 

asbestos found in the EPA air samples was short fiber (< 5 microns in 

length) chrysotile asbestos. However, only the fiber size which has 

been most closely linked to asbestos disease, the longer Phase 

Contrast Microscopy Equivalent or PCME fibers (> microns long, 

0.25 – 3.0 microns wide, > 3:1 aspect ratio) were used in the EPA 

exposure and risk assessment.” 

Refer to 

Common 

Responses 

Sections 1A, 

1B, 1C, 1D, 

1E, 1F(i), 2A, 

3A, 3C, 4A, 

4B, 4C, and 

4D. 

The no action 

alternative 

includes the 

decision to 

install a 

vehicle wash 

rack as 

approved in 

both of the 

BLM’s 

previous 

Record(s) of 

Decision for 

the 1999 and 

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Page 334, 3rd paragraph, last sentence: 4.2.4.3 Results “It is also 2006 CCMA 

important to reiterate that the asbestos concentrations used by EPA in RMP 

the CCMA Asbestos Exposure and Human Health Risk Assessment Amendments. 

are based only on asbestos fibers known as phase contrast microscopy 

equivalent (PCME) fibers because they are the fibers whose shape and 

size have been most closely linked to asbestos disease.” 

Page 340, last paragraph, last sentence: 4.2.5.1 CCMA Asbestos 

Exposure and Human Health Risk The asbestos concentrations 

used by BLM in the CCMA RMP/EIS are based only on asbestos 

fibers known as phase contrast microscopy equivalent (PCME) fibers 

because they are the fibers whose shape and size have been most 

closely linked to asbestos disease.” 

Given the flawed and exaggerated science used for this Draft on 

CCMA all of the Ratios, Scenarios, and Risk Summaries, have 

exaggerated risks. And comparing occupational exposure risks with 

that of occasional motorized recreation use doesn’t make any sense. 

The EPA should work to clean up old mining sites located in and near 

Clear Creek. 

In reading the Rotterdam Convention report of February 2004, it 

seems that all the votes are still out regarding risks from Chrysotile 

asbestos. “To date a total of 39 pesticides and hazardous industrial 

chemicals are included in the PIC (prior informed consent) 

procedure”. 

Chrysotile asbestos is not listed on PIC. “Chrysotile is a natural 

mineral present everywhere in the earth’s crust and does not constitute 

a threat for the environment.” 

The word “asbestos” has become a bastardized word which lumps all 

forms of asbestos into one category, all bad. 

The closure of Clear Creek Management Area, May 2008, is based on 

bias, flawed and deceitful science and is shameful, unreasonable, and 

unacceptable to the OHV public. A majority of the air samples were 

taken under “dry conditions”, and do not represent true OHV use. 

With the many decades of use of Clear Creek Management Area, 

there are no studies showing any health hazard from OHV use and 

camping. The BLMs Alternative E is not acceptable. 

Alternative A, with modifications, and No Vehicle Wash Rack should 

be considered period. 

Page 352, 3rd paragraph, last sentence: Vehicle Wash Rack 

“Furthermore, the construction and operation of vehicle wash rack 

requires reliable sources of water, but it is unclear whether the 

resources would be available to support the visitor use levels under the 

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range of alternatives.” 

A Vehicle Wash Rack would not only require lots of water, as stated 

in the above quoted paragraph, but it would create more waste water 

and material discharge. A vehicle was rack, is more unnecessary 

spending, based on misleading and flawed science. 

BLM should immediately reopen Clear Creek Management Area to 

historic OHV use. 

I am all for safety for all of the employees of Clear Creek, I do 

question a facility, $2.2 million cost to the taxpayers for a 

Decontamination facility built adjacent to the entrance station on 

Clear Creek Road where .020 f/cc fiber counts were recorded during 

air sampling. 

In an economy where California is financially hurting, going 

bankrupt, the BLM approves a $2.2 million Decontamination facility 

that seems to be totally unnecessary, and is based on flawed science. 

Page 302 4.0.5 Assumptions, Bulletin 5 “The level of activity on 

BLM-administered land is expected to increase, based on historical 

trends, population increases, and statements of interest in land use by 

individuals and industry organizations. This includes ongoing 

reasonable access to private land or interests.” 

The Area of Critical Environmental Concern (ACEC) is 

approximately 30,000 acres. The Hollister Hills Field office (HFO) 

manages approximately 63,000 acres of public land within the 75,000 

acres of the Clear Creek Management Area. I understand that in the 

management area there are private lands, and state managed lands. If 

BLM and EPA wants to restrict OHV development inside the ACEC, 

why not develop some of the 30,500 acres outside the ACEC. None 

of the alternatives in the Draft do enough to enhance OHV 

opportunities. 

According to Table 1-2. CCMA Management Zones Ownership 

(acres rounded to nearest hundred) The BLM manages acreage 

located in the Tucker area (5,900 acres), Condon area (9,700 acres) 

and Canua area (14,900 acres) for a total of 30,500 acres. 

To only have one alternative, Alternative D, considering managing 

Tucker, Condon and Canua for motorized, mechanized, nonmotorized and shooting, seems some what fair and equal, multiple 

use. Alternative G, would consider non-motorized use in these areas, 

and eliminate motorized access all together, and continues the total 

closure of Clear Creek Management Area, May 2008. 

If the Tucker, Condon and Canua areas can be considered under 

Alternative D for multiple uses, for an ever growing population, and 

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growing OHV use, then I would urge BLM to consider these areas for 

development for multiple use, in their final decision. 

Need help with managing future increase OHV opportunities at Clear 

Creek, please utilize the thousands of OHV volunteers more then 

willing to step up to help. 

I believe that the Alternative A in this Draft plan is in violation of 

NEPA, as “Install Public Wash Rack” is proposed. 

IND-COM-124 

The Hollister staff are to be commended for the 

numerous elements of the preferred alternative that 

continue the protective administration of area with 

endangered animals and plants, their concern for the 

watershed, and their being open to continue to allow 

hunting in Clear Creek. 

It must be said that asbestos has been overemphasized as a primary concern. Asbestos, 

endangered species, air and water quality, are all 

secondary to the primary concern of recreation. The 

staff in the Hollister office have done a fine job with 

these secondary issues in the past. 

I specifically disagree with the following sections of 

your preferred alternative: 

Trans-E1 and Energ-DEF1 Both these sections 

eliminate access from the Serpentine ACEC, and I find 

this to be unacceptable. The ACEC has numerous 

important sites and needs to remain open to the public, 

even if only on a somewhat limited basis. The ACEC 

should be kept open to mining and rockhounding. 

Trans-E5 and Air-BG2 Both these sections deal 

with access to Clear Creek during weather extremes. 

Weather has had no effect on visitor health or safety in 

the past. Couple this with the fact there remain a 

considerable number of questions as to the veracity of 

the EPA report and there remains no need to close the 

ACEC or Clear Creek as a whole any more than in the 

past. 

Speaking broadly, I am very concerned that collecting 

minerals, gems, and lapidary material continue to be 

allowed in Clear Creek, including the ability to access 

those areas. Clear Creek, besides being the only 

location of the state gem, contains gem quality 

neptunite, melanite and grossular garnet; amazing 

mineral specimens; lapidary material such as 

serpentine, chromite, and plasma agate. Clear Creek 

needs to remain open to mining opportunities for the 

Refer to Common 

Responses Sections 

1D, 2A, 3A, and 3D. 

431
 
 

 

 

 

 

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Proposed RMP and Final EIS – Volume II 

public. 

Numerous areas of the ACEC can be closed to assist 

in public health, such as the main pit, but plenty of 

roads, mining claims and prospects should remain open 

to the public. 

IND-COM-125 

I am writing this letter in regards to keeping as much 

land as possible open, for our families and friends to 

enjoy while enduring one of the true last outdoor 

activities- Off Highway Vehicle Use. Millions of OHV 

users pay a yearly fee in order to enjoy using their 

vehicle and by closing down more areas, all that is 

being accomplished in cramming all of us in a smaller 

area, causing more accidents and severe damage to the 

land. After all, hikers and mountain bikers do not pay 

any type of fee for using these areas. 

By keeping more acreage and areas open, it allows 

trails to be maintained easier, (Allowing access for 

people to work on them while other trails are open) and 

ensures that we are not leaving a harsher impact on a 

smaller amount of land. All too often, we see new 

fences going up and trails being closed down, many for 

no apparent reason. 

Off Highway Vehicles are truly one of the few and last 

outdoor activities that families can still enjoy while still 

spending quality time together and getting the kids off 

the couch and putting the video game controller down. 

Outdoor activities like these also allow our kids and 

families to receive much needed exercise and education 

regarding nature, coordination and most importantly 

responsibility. Families also get the opportunity to 

communicate and share great stories around the truck 

tailgate or campfire at night. 

I truly believe raising our green and red sticker fees is 

one way to help generate funds for proper trail 

maintenance and to ensure staffing levels. I would bet 

that most Off Highway Vehicle owners would support 

this type of action, knowing that their favorite trail 

would remain open and that they would not be 

crammed into a small area with new fences being put 

up along the perimeters. 

Refer to Common 

Responses Sections 

3A, 3D and 4B. 

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IND-COM-126 

Clear creek is one of the most fun area’s probably in the 

world to be able to ride, and I hope that it will soon be 

open for all. Charge @ the gate, whatever, just make it 

accessible so people can enjoy it. Let we the people 

worry about the health logistics, sign waivers, and be 

responsible for our own destiny. The sad state of affairs 

our country is in has a lot to do with the freedoms we 

lose on a daily basis. 

Refer to Common 

Responses Sections 

3A and 3D. 

IND-COM-127 

I strongly oppose all alternatives identified in the 

CCMA RMP/EIS that allow vehicular access in the 

San Carlos Bolsa and Cantua areas. I do support 

Alternative A with the exception that public access 

is allowed year round, not just on a seasonal basis. 

I grew up in the town of New Idria, attended its 

elementary school, rode the bus to Hollister for high 

school and was one of the town’s last residents. My 

father is Mark Ward and our family has property in the 

western region of the San Carlos Bolsa area being 

considered by the BLM for public vehicular access. 

I learned how to ride motorcycles at age 12, 

and spent my youth and early adulthood riding, 

camping and racing in the Clear Creek riding area. I 

was a member of the Mountaineers motorcycle club 

and am a two time winner of the club’s annual New 

Years Race held in the Clear Creek area. 

I am intimately aware of the soils and riding 

conditions in the area including the San Carlos Bolsa. I 

have walked, driven 4-wheel vehicles, and ridden 

motorcycles in this area and can speak from costly 

experience, that under certain wet conditions, the adobe 

clay in this area is impassable by motorized vehicles, 

period! It can even be extremely difficult to traverse by 

foot, and very easy to sprain an ankle as the adobe 

builds up on the bottom of boots. This soil can become 

incredibly sticky under certain conditions, and these 

conditions can happen year round. 

I have not seen the results of an in–depth 

environmental study regarding the adobe soils in the 

Bolsa and find it very irresponsible of the Bureau for 

not investigating and addressing this key feature of the 

region. Opening this region will result in stranded 

public, destroyed roads, and trespasses onto virgin 

range land in an effort to travel in the area when wet. 

Opening this area just won’t work and any attempt to 

The CCMA Draft 

RMP/EIS and this 

PRMP/FEIS identify 

the recreation 

resources values in 

Section 3.1.4. 

Please refer to 

Common Responses 

Sections 1C, 1D, 

1F(i), and 4A 

regarding the EPA 

risk assessment. 

Please refer to 

Common Responses 

Sections 3A, 3C, 

3D, and 4C 

regarding vehicle 

use in the Cantua 

Zone. 

Section 3.10.of this 

PRMP/FEIS 

identifies the results 

of a wilderness 

character inventory 

conducted during 

this land use 

planning process in 

accordance with 

FLPMA Sec. 201. 

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circumvent the adobe soil issue will lead to the same 

result; vehicles can not travel in these wet soils under 

certain conditions! 

I strongly encourage the BLM to reopen the 

Clear Creek area to year round use in response to a 

flawed EPA study and growing evidence of the real 

non-hazards associated with the chrysotile asbestos in 

the area. This area is perhaps some of the best riding 

terrain and soil around, and I have spent many hundreds 

of hours riding the trails, hills and roads in the area. It is 

a great place to take your family, camp and drive, ride 

and hunt. Please revisit the Clear Creek area and open it 

once again to the public. It is a perfect ORV area for 

everyone concerned. 

In closing, I have traveled to my family’s 

property in the San Carlos Bolsa area since I was young 

and have always marveled at the pristine, wild beauty 

of the region. It would be an environmental crime to 

allow public vehicular access into the area, especially 

when such a perfect region neighbors to the west, Clear 

Creek! I am speaking from experience when I say that 

this area is impassable by vehicle under certain wet 

conditions. Perform the in-depth environmental study 

that should have been conducted prior to this proposal, 

and you will come to the same conclusion, public 

vehicular access in the San Carlos Bolsa and Cantua 

areas should remain prohibited. 

IND-COM-128 

For many years, when we lived in California, my 

family and I rode at Clear Creek. My boys learned a 

great deal from that experience. How sad that many 

more families are prohibited from enjoying Clear Creek 

because of misused and erroneous studies of a health 

hazard from asbestus in the soil. No evidence has ever 

been found that anyone has suffered asbestos caused 

illness from riding in the Clear Creek area. 

I strongly urge the BLM to reverse their decision to 

close this wonderful riding area. At the very least the 

BLM should extend the public comment period 90 days 

from the Feb. 12th date. Please apply common sense to 

this situation and start looking at a solution which 

considers the thousands of families who need an 

accessible place to ride. 

Refer to Common 

Responses Sections 

1D, 1F(i), 3A, 3D, 

and 4B. 

IND-COM-129 

I would like to express my outrage at the closed nature 

of the procedure employed regarding the use of this 

public land (CCMA). There is clearly an agenda against 

OHV use and there appears to be strong influence from 

anti-OHV political groups. There is no evidence to 

Refer to Common 

Responses Sections 

1A, 1B, 1C, 1D, 

1F(i), 3A, 3D, and 

4A. 

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prove that the soil within the CCMA has lead to any 

injury, respiratory illness, or long term disease. 

The decision to close CCMA happened with little to no 

transparency. There was no evidence presented to 

warrant the closure of this land. It took 2 years to write 

a report, yet you want to make a decision in less than 90 

days. This gives us no time to respond to the report. 

This procedure to close CCMA is rushed and strongly 

biased against OHV use. There appears to be no adult 

supervision at the Hollister Field Office and the horrific 

mis-management of CCMA should be investigated by 

an outside independent committee. 

My preference is that we approach the use of this land 

without any bias and political agendas. If science is 

required, then an epidemiology report should be 

conducted to prove beyond a shadow of a doubt that the 

use of this land causes health issues. As an adult, I 

would sign any waiver to allow me full access to this 

land. 

If health issues are not the driving force to this closure, 

then I would like this to be public knowledge with more 

transparency. From what I can tell, this is the 

independent action of the Hollister Field Office with an 

axe to grind against certain OHV users that can’t follow 

the rules. 

I am strongly against closing this land. This is a special 

place that is unique to OHV and the best use of this 

land is to continue full access to OHV users. 

IND-COM-130 

Having reciently driven the road between Coalinga and 

Holister I was reminded it is an incredibly scenic drive 

in the Spring. I was saddened to hear that the Clear 

Creek area is still closed to the public after two years in 

limbo. The Clear Creek area is both a beautiful area to 

see and a great photographers and rockhounders area as 

well as many other outdoors activities that needs to be 

open ASAP to the public to enjoy. I would consider 

myself a practical enviromentalist but it is obvious in 

this case the enviromental issues have obviously been 

very much overblown and do not remotely justify 

closing such a large area to the public, who collectively 

own the land, for such a long period of time. 

Refer to Common 

Responses Sections 

1D, 3A, 3D, and 4A. 

IND-COM-131 

I would like to champion the rights of ordinary, 

respectful rockhounds and mineral collectors, who have 

been shut out of area after area of public and private 

lands in California, particularly lately in the 

Refer to Common 

Responses Sections 

1D, 3A, 3D, and 4A. 

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southeastern deserts. I believe that the alleged cangers 

of potential exposure to asbestos-type materials in the 

dust of the Clear Creek area DOES NOT represent a 

significant health hazard in the case of casual mineral 

collectors, certainly not a hazard justifying removal of 

the lands from potential rockhounding areas. We do not 

need more government protection from so-called 

hazards we can clearly see, understand and evaluate. If 

you want to stop lung cancer, ban cigarettes, don't overreach yourselves and sound science, and ban healthy 

outdoor activities in California! 

INDCOM132 

I will begin by stating that I am a motorcycle rider, a mountain biker, a 

hiker, an environmentalist, and a land use professional. I am aware of 

the complex issues involved in the preparation and review of a 

management plan for an area such as Clear Creek. I also acknowledge 

the challenge the BLM faces in balancing access to public lands with 

protection of natural resources and in mitigating potential hazards from 

such public access. 

Although it is important to identify appropriate trail routes to protect 

natural resources and to provide public information for individuals 

entering an area of potential hazards, the elimination of OHVs from the 

Serpentine Area of Critical Environmental Concern (or the entire 

CCMA) is not warranted based on the studies performed. Proper route 

designation and location to protect natural resources, combined with 

public information regarding asbestos risk, are all that is needed to 

allow continued OHV access in the CCMA. 

As cited in section 3.2.3.1 of the DEIS, the off site exposure to asbestos 

from OHV use is limited and is similar to background thresholds in the 

North Central Coast and San Joaquin Valley air basins, therefore the 

only potential hazardous exposure is to individuals who voluntarily 

enter the ACEC. 

This potential hazard is further confused due to the fact that the 

thresholds used to measure the asbestos health risk were not developed 

for outdoor exposure from periodic OHV or other recreational use. As 

cited in section 3.2.3.1 of the DEIS, the IRIS and OEHHA toxicity 

values for asbestos were developed for workplace exposure to 

intermittent high asbestos concentrations over extended periods. These 

two methods were not developed to apply to periodic recreational 

asbestos exposure and additional testing is needed prior to arriving at 

the conclusion that periodic recreational use in the Serpentine ACEC 

will result in an increased risk to individual health. 

Prior to permanently closing the Serpentine ACEC to OHV use (or 

public motorized access of any kind), the following measures need to 

be taken: Additional testing of the amount of long term asbestos 

exposure any individual would have while using the area periodically 

Refer to 

Common 

Response 

s Sections 

1C, 1D, 

1F(iii), 

3A, 3D, 

4A, and 

4B. 

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on an OHV, the size and type of asbestos material that may be ingested 

or released, and the actual detrimental effect over the long term 

resulting from the amount and type of asbestos on any individual (or 

the general public) as a result of periodic OHV use in the ACEC. 

Regardless of the asbestos and natural resource concerns, the access for 

the general public to the CCMA and the Serpentine ACEC for 

motorized recreation should not be substantially reduced or eliminated 

in the management area. 1lf the CCMA becomes an area that is 

essentially closed to OHV use, there will be additional off-site impacts 

that need to be adequately evaluated. As cited in section 3.1.4.3 of the 

DEIS, OHV users are on the increase and demand for OHV areas is 

high in California. These OHV users need to have access to public 

lands in which to operate their OHVs in a safe and responsible manner. 

Additionally, the access to public lands for OHV use has become very 

limited near urbanized areas, as cited in section 3.3.5 of the DEIS. As a 

result, the permanent (or undetermined temporary) closure of the 

CCMA to OHV use will create additional impacts in terms of vehicle 

miles traveled on local roads and state highways to arrive at alternate 

OHV parks. The assessment of the impact of these additional trips and 

vehicle miles on state and local roadways and intersections has not been 

adequately evaluated. Such a closure will also result in additional OHV 

vehicle use at alternate OHV parks in the region. 

As cited in sections 4.1.8.1,4.1.9.1,4.1.11, & 4.3.11 of the DEIS, the 

closure of the ACEC to OHVs would result in foreseeable increased 

impacts to existing OHV parks in the surrounding region. This would 

apply to all Alternatives (B, C, D, E, F, G) that reduce OHV access or 

close the ACEC to OHV use, and are not limited to the “preferred” 

Alternative E or Alternatives F & G. The assessment of the impact of 

these additional OHVs at alternate parks has not been adequately 

evaluated. No mitigations to these potential impacts have been 

identified in the DEIS. Given the high recreational OHV demand in the 

region, every OHV park closure (or reduction in access) should identify 

new (previously closed or unavailable) public lands that are to be 

opened to OHV use within the same management region as the closure 

in order to offset these potential impacts. 

Although I have not attempted to address all of the issues raised in the 

DEIS, I feel that there is a need to question the fundamental thought 

process behind closing a management area entirely to public use 

without a full and complete scientific assessment of the impacts of such 

a closure. The removal of yet another of the very few OHV parks in the 

vicinity of the SF bay area and central coast region will only put more 

stress and strain on other parks (such as Metcalf, Hollister, & Carnegie 

- also facing threat of closure). In order to avoid potential impacts to 

other OHV parks (and natural resources on public lands in general) 

another park of equal size, quality, and proximity to the SF bay area 

and central coast region would need to be identified and established 

prior to any permanent closure of the CCMA or ACEC to OHV access. 

437
 
 

 

 

 

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For this reason alone, I strongly encourage your office to keep the 

existing OHV access to the CCMA and ACEC open to the greatest 

extent feasible. 

Comment 

Code Summary Response 

IND-COM133 

Comment 1: EPA CCMA 

Asbestos Exposure and 

Human Health Risk 

Assessment 2008 (EPA 2008) 

does not provide significant 

new information relative to 

actual human risk and instead 

merely provides yet another 

analysis of exposures to 

CCMA users. Inclusion of 

“significant new information” 

found in EPA 2008 as a Need 

for Draft Clear Creek 

Management Area Resource 

Management Plan & 

Environmental Impact 

Statement, November 2009 

(BLM 2009) is unjustified. 

Coimment 2: There have 

been multiple exposure 

investigations performed at 

CCMA in the past; Cooper et 

al. 1979; Popendorf and 

Wenk 1983; Human Health 

Risk Assessment for the 

Clear Creek Management 

Area, prepared by PTI 

Environmental Services in 

1992 (PTI 1992); EPA 1990a 

(Atlas Asbestos mine, located 

within the CCMA ACEC), 

and possibly others. Some 

investigations concluded that 

there was lesser exposure and 

some concluded that there 

was greater exposure. BLM 

was provided no significant 

new information by EPA 

2008 which had not been 

previously been presented in 

any other previous 

investigation. 

Note: Significant effort by the reviewer to 

understand the uncertainties in the evaluation and 

quantitatively estimate the effects are appreciated 

and the following responses are given to his 

detailed comments. 

Comment 1: Previous asbestos exposure 

information for off-road motorcyclists in CCMA 

was collected in 1978 (Cooper & Popendorf, et al 

1979, Popendorf & Wenk, 1983) and in the early 

1990’s (PTI Environmental 1992). The EPA Risk 

Assessment Report collected additional exposure 

information at two different breathing heights for 

motorcycling and for several other activities that 

are common in the Management Area but were not 

previously assessed. EPA analyzed the collected 

fibers by Transmission Electron Microscopy 

(TEM) following the International Organization 

for Standardization ISO 10321 (ISO 1995) 

protocols, the currently accepted standard. These 

additional activity-based samplings allowed for an 

up-to-date, more holistic determination of possible 

exposures associated with combined activity 

scenarios, and provide significant new and 

complete information about the magnitude of 

exposures associated with current CCMA 

activities. All the studies that have been conducted 

conclude that high dust-generating activities 

within the CCMA Area of Critical Environmental 

Concern (ACEC) result in increased exposure to 

asbestos. 

Comment 2: DOI employee monitoring has also 

demonstrated increased exposure during dustgenerating activities within the Area of Critical 

Environmental Concern (ACEC). Rangers’ 

activities were determined to be best represented 

as lead riders in the 2008 EPA risk assessment, 

and a risk analysis for this activity scenario was 

requested by BLM. The appropriate exposure 

scenario and resulting risks are presented in the 

Risk Assessment in Figures 10 and 11. The 

analytical method used in the occupational 

assessment was Phase Contrast Microscopy 

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Code Summary Response 

BLM Employee Exposure to 

Naturally Occurring Asbestos 

at the Clear Creek 

Management Area and the 

Knoxville Management Area, 

prepared by the Department 

of the Interior Office of 

Occupational Health and 

Safety, dated May 2008 

(DOI-OOHS 2008) provides 

actual, rather than simulated 

as in EPA 2008, risk analysis 

of occupational exposures for 

BLM employees at CCMA. It 

should be noted that in 

DOIOOHS 2008, mean 

composite time weighted 

average exposure 

concentrations (composite 

TWA, fibers divided by 

actual sampling time only) 

for specific activities, which 

are analogous to individual 

activity-based exposure 

concentrations determined in 

EPA 2008, are lower than 

corresponding exposure 

concentrations in EPA 2008. 

Comment 3: Additionally and 

possibly most importantly, 

the risk unit presented in 

EPA’s Integrated Risk 

Information System (IRIS) 

Summary for asbestos, 2.3E1 fibers/ml, is not appropriate 

for exposures at CCMA. This 

risk unit is derived from a 

number ofepidemiological 

studies associated with 

occupational exposure to 

asbestos. 

The IRIS asbestos risk unit, 

used in EPA 2008, is used 

inappropriately and applies 

processed asbestos risk to a 

large natural chrysotile 

(PCM). This is the standard analytical method for 

measuring occupational exposures, but it cannot 

discern smaller fibers with widths <0.25 um and 

does not distinguish asbestos from non-asbestos 

fibers. The TEM method used by EPA has the 

resolution to measure a wider range of fiber sizes 

and distinguish asbestos fibers from non-asbestos 

fibrous material. However, only the PCM 

equivalent asbestos fibers (PCMe) were used in 

the quantitative assessment of risk because those 

are the fiber sizes that were used to measure 

exposure in the epidemiological studies of the 

health outcomes of asbestos exposure. 

Additionally, in this study EPA followed the 1986 

World Health Organization (WHO) 

recommendation to use a width limit of 3 um 

diameter as a limit of respirability. This 

modification is particularly applicable to the 

situation at CCMA due to the unrefined nature of 

the asbestos exposure. Large blocks or “chunks” 

where seen in previous studies (W.C. Cooper et. 

al. 1979) and were present in EPA’s TEM analysis 

of the fiber dimensions. These large pieces would 

add to the PCMe counts using the older PCM 

method fiber definition, but would not be 

respirable and therefore would not add to the 

fraction that makes it into the lung. 

It is important to remember that fiber counts are 

being used as a surrogate measure of toxicity. In 

more recent TEM analysis of previous 

occupational PCM epidemiologic studies, all fiber 

dimensions - PCM, PCMe or other size fractions ­

correlate with disease; some more so than others 

and varying based on the exposure measured. (L.T 

Stayner, et al. Occupational Environmental 

Medicine 20 Dec 2007, D. Loomis, et al., ibid 5 

November 2009) This is part of the continuing 

scientific effort to find the best indicator of 

exposure that correlates to health outcomes. 

Comment 3: The commenter correctly points out 

that in the derivation of the Unit Risk Factor 

(URF) for cancer from airborne asbestos (US EPA 

1986), the milling and mining cohorts were not 

included. When EPA was reviewing the 

occupational studies that form the basis for the 

URF, positive correlations between fiber counts 

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Comment 

Code Summary Response 

deposit where human 

exposure would be far more 

similar to asbestos mining 

and milling human exposure 

and completely unlike human 

exposure to processed 

asbestos and asbestos 

products. 

Comment 4: EPA used 

sampling techniques that had 

been used at the site 

previously, but let the trailing 

riders ride in the dust of the 

rider ahead. 

Comment 5: Analytical 

methods and PCM vs PCMe 

comparison. 

Comment 6: Amphibole 

fibers were detected. 

Comment 7: EPA’s 

conclusion that children are 

of special concern is not 

supported by the data 

and cancer outcomes were observed for mining 

and milling cohorts, as well as for cohorts of other 

industries (textile production, insulation 

production, and installation and production of 

cement products). However, the milling and 

mining studies showed lower asbestos cancer 

potencies than those observed in other industries. 

This was thought to be due to differences in fiber 

size distribution between the industrial 

environments. The analytical method used at the 

time to measure exposures produced fiber counts 

that included fibers that were too large to reach the 

deep areas of the lung. Mining and milling 

exposures were logically thought to include a 

greater proportion of large blocky fibers that 

would not be respirable (EPA 1986). Inclusion of 

these nonrespirable fibers in the exposure 

estimates would dilute the apparent potency of 

respirable fibers present, thus artificially lowering 

the potency reported for the mining and milling 

cohorts (EPA 1986). Therefore, the URF is based 

on studies of processed materials where it was 

believed there was a lower proportion of 

nonrespirable fibers. These studies then more 

closely follow the exposure and response linkage 

manifested in the epidemiological studies. Large 

blocky fibers or “chunks” were seen in previous 

studies at CCMA (W.C. Cooper et al Science, 

1979, vol. 209, pgs 685-8) and were present in 

EPA’s TEM analysis of the fiber dimensions. In 

the EPA Risk Assessment, the definition of PCMe 

included a width definition of < 3 um that 

eliminated the thick fibers, as recommended by 

the WHO 1986. Therefore, the PCMe counts in 

the EPA study represent likely respirable fibers, 

and as such it is appropriate to apply the EPA 

URF to the EPA data for the CCMA. 

Comment 4: The commenter is correct that the 

classic industrial hygiene method of using a filter 

cassette placed in the breathing zone of the 

individual where air is sampled at a known rate 

was used in all the studies of activity based 

exposure at CCMA (W.C. Cooper et al 1979, 

Poperdorf and Wenk, 1983, PTI 1992, US EPA 

2008). This demonstrates the usefulness of this 

procedure in assessing a wide range of activities. 

W.C. Cooper first reported a difference in the lead 

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Code Summary Response 

and trailing riders’ exposure in 1978. The US EPA 

2008 report reproduced this result as illustrated in 

Figure 6 and Table G-4. It may be true that the 

riders in this study rode closer to the previous rider 

without experiencing a “mouthful of dust” because 

of their respiratory protection. However, group 

ride events are common among the activities at 

CCMA and the level of exposure would be 

increased in trailing riders. Table G-4 suggests as 

much as 10 fold higher with some degree of 

variability but still an increase in exposure. 

Comment 5: The commenter is correct that TEM 

measurements of fibers are different than PCM 

measures. The attributes of TEM - better 

resolution, ability to distinguish asbestos from 

non-asbestos structures, and standard international 

counting / annotation protocols - are an 

improvement over the previous PCM methods. 

Even though TEM provides additional refinement 

of the fiber size distribution, only PCM equivalent 

fibers were used in the risk evaluation. 

Additionally, in this study EPA followed the 

WHO 1986 recommendation to use a width limit 

of 3 um diameter as a limit of respirability. This 

would have the effect of reducing the fiber count, 

compared to only a fiber length and aspect ratio 

determination. Several authors have investigated 

the correlation of PCM and TEM-PCMe fiber 

counts (C.Y. Hwang and Z.M. Wang, 1983 

Archives of Environmental Health, vol. 38, pgs 5­

10, and more recently, L.T Stayner, et al. 

Occupational Environmental Medicine 20 Dec 

2007, D. Loomis, et al., Occupational 

Environmental Medicine, 5 November 2009). 

PCM and TEM-PCMe fiber counts are well 

correlated with correlation coefficients of about 

0.9. Even PTI, using the 10 samples which were 

analyzed by both techniques, had a correlation 

coefficient of 0.92. It must be kept in mind that 

fiber counts are only being used as a surrogate of 

toxicity. All fiber dimensions correlate with 

disease outcomes, but science is still seeking the 

best definition of that surrogate. Currently, the 

PCMe fiber counts are the measure by which 

exposure is determined. 

Comment 6: EPA did find amphibole asbestos in 

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Comment 

Code Summary Response 

the activity-based samples. The Agency currently 

makes no distinction of asbestos toxicity based on 

the form of asbestos. Asbestos is a natural mineral 

whose mineralogy is defined by the presence of 

minor amounts of other metals in the crystal 

structure. Refer to Common Responses Section 1. 

B. 

Comment 7: As illustrated in Figure 8 of the Risk 

Assessment, exposure measurements in child 

breathing zones closer to the source of the dust 

generation resulted in higher fiber counts. These 

increased exposures were incorporated into the 

risk assessment for the appropriate scenarios 

where children were recreating at the CCMA. The 

increased exposure resulted in increased risks. 

Additionally, there is still significant discussion in 

the medical community as to the physiological 

differences in the child lung that may make a child 

more sensitive to particulate exposures. EPA’s 

Particulate Matter Air Quality Criteria Document 

(2004), a consensus document which evaluated the 

state of the science for particulate inhalation, 

concluded that there are models and supporting 

experimental evidence that predict significant 

differences in particulates depositing in the child 

and adult lung, and that this may have irreversible 

effects on the developing lung. This is another 

uncertainty not quantitatively included in the risk 

assessment. Also, with respect to asbestos 

exposure, there is a latency period from time of 

first exposure to the manifestation of disease. The 

latency period may or may not be different 

between children and adults, but the longer life 

expectancy for children and the probability that a 

child will live long enough to express disease is 

increased and proportional to the extent and 

duration of exposure. Therefore, the combination 

of increased concentrations of asbestos measured 

in the child breathing zone, and the fact that the 

exposures are occurring early in life, lead EPA to 

the conclusion that children are of special concern. 

Comment Code Summary Response 

IND-COM-134 

The Centra Vally of Calif needs some place to 

go to enjoy, besides being bunched up in areas 

like Hollister Hills, Pismo, etc: Those areas 

are always full. I am a avid deer hunter, wild 

Refer to Common Responses 

Sections 1D, 3A, and 3D. 

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pig hunter, and also a trail rider of old Honda 

"90"s. I have been using the Clear Creek area 

for over 30 years, I have yet to find in my 

system any signs of Cancer or asbestos in my 

body. 

I used to play in the asbestos at the 3 area 

mines, when they were open. 

I support the No Action Alternative that 

restores historic OHV use on up to 270 miles 

of routes and approximately 450 acres of 

barrens. Permitted OHV events should be 

allowed. If some small health risk is identified 

by a new risk assessment or a review of the 

EPA's 2008 report, the BLM should use signs 

and educational outreach as a way to inform 

the public rather than closing this important 

OHV area on a permanent basis. It would be 

most important to warn people of the asbestos 

danger than close the riding area's of 

ClearCreek. 

When we were asked to stay away from the 

Mines in the area, WE DID SO! WHEN WE 

WERE ASKED TO DONT TREAD THERE 

WE DID SO! 

Even a higher use fee maybe?, and maybe to 

sign a affidavit that no one could sue the BLM 

because of sme thing happening to them in the 

area?. I love just to rockhound there and just 

camp, no riding. So please in some way, 

reconsider the opening of the area, or at least 

some of it. 

IND-COM-135 

Refer to Table X-6: HGMC-FORM Summary 

& Response. 

Refer to Table X-6: HGMCFORM Summary & 

Response. 

IND-COM-136 

I strongly support the closure of this 

management area to motorized recreation. 

The EPA risk assessment clearly demonstrates 

the serious risks to public health and safety 

from any continuation of this previous use. 

Asbestos from serpentine soils in this area can 

become airborne and be breathed into the 

lungs. This is especially true when motorized 

vehicles travel on these soil surfaces and stir 

up dust. Asbestos in lungs can become Comment noted. 

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Comment Code Summary Response 

mesothelioma, a very deadly form of cancer. 

In any balancing of public health with 

recreation, public health should always 

receive the priority and the benefit of any 

doubt. 

I know that the Blue Ribbon Coalition and 

other motorized recreation groups want this 

area to continue to be used for motorized 

recreation. They tend to downplay the risks, 

and question EPA's expertise in the risk 

assessment. I believe that this is irresponsible 

as it places riding for fun above the health of 

the riders. This is foolish, selfish, and 

dangerous. Please do not let these 

obstructionist tactics keep you from doing the 

right and safe thing in the public interest. 

IND-COM-137 

The Clear Creek closure was based on an 

incorrect conclusion. The type of asbestos at 

Clear Creek has never caused a health 

problem for a single person and you know this 

to be true. So why was Clear Creek closed? 

Clear Creek should be opened and BLM 

should take the position that the type of 

asbestos at Clear Creek is safe as has been 

shown in previous studies and health records 

of the asbestos workers at the asbestos plants 

that were at Clear Creek. I have been riding 

motorcycles at Clear Creek since 1970 and I 

have not had any health problems caused by 

asbestos. 

Refer to Common Responses 

Sections 1A, 1B, 1F(i). 

IND-COM-138 

My name is Rick Kennedy and I have had the 

pleasure of meeting some of you in the office 

personally. I also supplied most of the 

minerals that are in the display at the Hollister 

office. I have collected in the CCMA since 

1984. I have given a number of talks about 

the minerals found in the CCMA and led 

several field trips to various localities within 

the CCMA. Both clubs that I belong to (Bay 

Area Mineralogists and Santa Clara Valley 

Gem and Mineral Society) are working on 

official letters, but I thought it prudent to send 

my own letter in. 

As a mineral collector/rockhound, these are 

vital to my enjoyment of the CCMA: Four 

wheeled access and overnight camping. 

Although I am relatively hale and can hike 

Refer to Common Responses 

Section 3D. 

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several miles, most of the people in my clubs 

are Senior Citizens and need to be able to 

drive within a 1/2 mile or so of any locality. 

Keeping most of the "R" roads open, 

especially R1, R5, R11 and some of the roads 

between them would facilitate access to 

important collecting locations. Closing some 

of the "R" roads and most if not all of the "T" 

roads is a compromise I could live with. 

As for overnight camping, although we do day 

trips occasionally, we tend to prefer one or 

two night stays near the localities we are 

collecting. It is an awful lot of driving on 

rough roads to make every trip a day trip. 

Personally, I am open to paying for permits 

and for having a limited number of total days 

in the CCMA. I think somewhere between 10 

and 15 total days would be reasonable. 

I understand that drastic changes to the usage 

before the closure are needed to satisfy the 

EPA. I am hoping the accessibility I propose 

would satisfy them. 

The alternative chosen as the "best fit" by the 

BLM does very little to address the usage 

needs by the mineral collecting/rockhounding 

community, but it doesn't take very many 

changes to that alternative to allow for a 150 

year old tradition to continue. This area is a 

mining area and has been one since Mercury 

was discovered in New Idria so many years 

ago. It would be a shame to permanently 

close access to such a unique mineralogical 

area. 

IND-COM-139 

The studies used to justify the closure of Clear 

Creek Management Area are based on 40 hour 

work week occupational exposure to asbestos. 

The visitors at CCMA are recreational users 

with possible exposure of only a couple of 

hours to a couple of days at a time. The BLM 

needs to consider the vastly lesser exposure of 

recreational visitors compared to the studies 

daily workplace exposure. 

The BLM used an EPA report based mostly 

on theoretical analysis of potential asbestos 

Refer to Common Responses 

Sections 1C, 1D, 1F(i), and 

4A. 

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exposure hazards. There have been no 

documented cases of lung cancer or any other 

asbestos related health problems related to 

recreational exposure at Clear Creek. The 

BLM should not cite reports which are not 

supported by actual health cases at Clear 

Creek. 

IND-COM-140 

1. The 2008 EPA Assessment is biased. 

2. The 2008 EPA Assessment fails to 

include previous report/assessment data. 

3. Data is limited. 

4. Data is incorrectly weighted. 

5. Data numbers are incorrect. 

6. Invalid data has been included in the 

2008 EPA Assessment. 

The 2008 EPA Assessment has not provided 

the “substantial new information” as stated in 

the 2009 DEIS/RMP. The assessment has not 

provided conclusive evidence that there is a 

real risk to users of the 

area and there are numerous issues with the 

data collected and used (in common scientific 

terms “garbage in equals garbage out”). It is 

this author’s opinion that based on the above, 

the BLM has not proved a need for the current 

“emergency closure” and subsequent 

preparation of the 2009 DEIS/RMP. As such, 

the 2009 DEIS/RMP needs to be declared null 

and void, the area needs to be reopened 

immediately, and the BLM shall manage the 

CCMA under the current record of decision 

and amendments. 

Should the BLM elect to provide additional 

education outreach to users of the area and/or 

provide mitigation such as armoring of main 

roadways, I believe this would fall under an 

amendment to the current ROD, but does not 

warrant the need for a new EIS/RMP. 

The 2008 DEIS/RMP has erroneously listed 

[needs for 

species protected under the federal 1973 

Endangered Species Act (ESA),] as a need for 

the document. As such, it is this author’s 

opinion that based on the above, the BLM has 

not proved a need for the current “emergency 

closure” and subsequent preparation of the 

2009 DEIS/RMP. As such, the 2009 

Refer to Common Responses 

Sections 1C, 1D, 1E, 1F(i), 

1F(ii), 2A, 2B, 2C, 3A, and 

4A. 

The affected environment is 

described in Chapter 3, 

including all the public lands 

in the Serpentine ACEC. 

Maps of the public lands and 

the private lands that are in 

the ACEC are also included 

in Appendix 1 of the CCMA 

Draft RMP/EIS and this 

PRMP/FEIS. 

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DEIS/RMP needs to be declared null and 

void, the area needs to be reopened 

immediately, and the BLM shall manage the 

CCMA under the current record of decision 

and amendments. 

As the need [to address social and economic 

changes] is vague and misleading, it should be 

excluded from the DEIS/RMP. As such, it is 

this author’s opinion that based on the above, 

the BLM has not proved a need for the current 

“emergency closure” and subsequent 

preparation of the 2009 DEIS/RMP. As such, 

the 2009 DEIS/RMP needs to be declared null 

and void, the area needs to be reopened 

immediately, and the BLM shall manage the 

CCMA under the current record of decision 

and amendments. 

Abandonment of existing highways and 

rights of way. Pre existing highways and 

rights of way which were in existence to a 

certain date, which this author did not have 

time to verify, cannot be abandoned, closed, 

or impeded by the BLM. This is under 

existing land use and rights laws and 

decisions. Should the BLM elect to continue 

to close roads that the public has prescriptive 

rights to, it is my opinion the potential for 

litigation against the BLM is extremely high. 

Area of Environmental Concern is not 

clearly defined. The area of concern, which is 

currently shut down by the emergency 

closure, is not clearly defined. The BLM 

needs to provide a metes and bounds 

description of the area, or accurately map the 

area using GIS, to the closest 5 feet to ensure 

that users are clear if they are within the 

boundaries of closure or not. 

IND-COM-141 

Our property boarders large portions theses 

BLM properties, approximately 2,000 acres to 

the north and 2,000 acres to the south of the 

BLM leases. Since 2001 we have placed our 

ranch in cooperation with Department of Fish 

and Game (DFG) into a wildlife management 

plan called Private Lands Management 

(PLM). Prior to placing the ranch into the 

PLM program it was used as a cattle grazing 

Please refer to Common 

Responses Section 3D. 

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operation. Since the PLM program all 

livestock have been removed from all of the 

ranch except a small portion near our house at 

the southern edge of the property, we use the 

lease property for the grazing of the local 

wildlife. We have spent considerable time 

and expense over the last nine years 

improving the habitat (water, forage) 

surrounding the BLM property to the 

betterment of the local wildlife population and 

the results have been very good. Deer 

populations are up considerably, Turkey 

populations are increasing and the Elk 

populations have increased dramatically. 

There is even a pair of nesting Bald Eagles 

that have produced over nine offspring. These 

are a direct reflection of the removal of Cattle 

(vegetation competition) and the decrease in 

vehicle usage in and around the BLM 

property. 

We would like to propose the following: 

1. Keep the leases as they are now on a yearly 

lease. It does not cost the BLM any money 

and provides an invaluable wildlife resource 

to a very sensitive area. Disposing of the 

property at auction does not ensure that this 

pristine property stay as it has since it was 

homesteaded in the 1800’s. 

2. Keep existing restrictions on vehicle 

traffic. The soil type in #04410 and #04409 

are adobe and very susceptible to erosion from 

OHV and larger vehicles. The lessee is 

responsible for upkeep on the roads, no cost to 

BLM. 

3. Remove this property from the connection 

with the CCMA and manage it separately 

from the CCMA. BLM not adding these 

parcels to the CCMA OHV and trail system.. 

Just as there are many pieces of BLM in the 

surrounding areas that are not included in the 

CCMA. 

4. And lastly if the top three proposals are not 

feasible we ask that BLM sell it to us and as a 

condition of the sale we would sell, or BLM 

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can keep, the development rights of the 

parcels so that these delicate parcels will 

forever maintain their special status. 

IND-COM-142 

I am writing to voice my opposition to closure 

of the Clear Creek Management Area.There is 

a shortage of OHV riding areas in northern 

california.To close CCMA would be to 

concentrate usage in the other areas.Many 

taxpayers want & need more places to 

participate in OHV recreation .CCMA is one 

of the best, and it would be a horrible injustice 

for the BLM to use faulty science to justify 

the closure. 

The studies used to justify the closure of Clear 

Creek Management Area are based on 40 hour 

work week occupational exposure to asbestos. 

The visitors at CCMA are recreational users 

with possible exposure of only a couple of 

hours to a couple of days at a time. The BLM 

needs to consider the vastly lesser exposure of 

recreational visitors compared to the studies 

daily workplace exposure. 

The BLM used an EPA report based mostly 

on theoretical analysis of potential asbestos 

exposure hazards. There have been no 

documented cases of lung cancer or any other 

asbestos related health problems related to 

recreational exposure at Clear Creek. The 

BLM should not cite reports which are not 

supported by actual health cases at Clear 

Creek. Please consider not taking away 

another wonderful place that I love to enjoy. 

Refer to Common Responses 

Sections 1C, 1D, 1F(i), and 

4A. 

IND-COM-143 

My name is Rob Porcella and I am an avid 

motorcycle rider. I discovered Clear Creek in 

2004 and brought my wife and stepson there 

to ride for their very 1st time on motorcycles. 

We camped there many more times after that 

and grew closer as a family enjoying the 

recreational sport of motorcycling together. I 

had read about the asbestos that was natural to 

the area and decided that it was a risk I was 

willing to take because enjoying those 

mountains was worth the risk. I also consulted 

with my father who was a Geophysicist for 

the U.S. Geological Survey, and his thoughts 

were that the natural asbestos would probably 

have to be constantly inhaled on a daily basis 

Refer to Common Responses 

Sections 1C, 1D, 3D, and 

4A. 

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for years to adversely affect someone. For 

example the miners who worked in the caves 

for years inhaling the asbestos dust. I have yet 

to see a study that demonstrates where OHV 

riders who have enjoyed this area throughout 

the years have developed some sort of 

asbestos related illness. I am afraid however 

that the naturally occurring asbestos is just 

and excuse for more OHV closures by special 

interest groups that feel OHV recreation is 

destructive to the land and habitat of the areas 

in which they are designated. Please look at 

this issue in a fair and balanced view and 

make the decision that is right based on the 

facts of this individual case. Thank you for 

your time. 

IND-COM-144 

Clear Creek has been open to OHV use for 

decades. OHV enthusiasts have enjoyed and 

appreciated the riding opportunities Clear 

Creek has had to offer. We understand the 

current health concern regarding asbestos 

exposure. Perhaps a simple solution would be 

to open Clear Creek to OHV use on a seasonal 

basis. Once the winter rains have eliminated 

the dust, the health risk would seem to be 

minimal. This coupled with an OHV user fee 

expressly for trail and staging area 

maintenance should mitigate most of the 

problem. These measures would be 

acceptable to most OHV riders of the Central 

California area if it meant Clear Creek would 

remain open to OHV use. 

Refer to Common Responses 

Sections 3A and 3D. 

IND-COM-145 

While it is of concern to watch out for my 

well being on public lands, it is also a 

necessary consideration for you to allow me to 

explore this beautiful land. There are inherent 

hazards in rock falls, animals, plants and a 

host of critters: but we don't close parks and 

public lands because they exist. 

Take into account your concerns and level that 

with what works best for all of us to enjoy this 

beautiful natural resource. I doubt John Muir 

hesitated to hike anywhere in California 

because of concerns of radium in granite, 

phosphorous in rocks or asbestos in dirt. Do 

what is best for us all and do not pick the 

easiest alternative. Work with us on 

suggestions for safety, health and recreation 

issues at Clear Creek. 

Refer to Common Responses 

Sections 3A and 3D. 

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IND-COM-146 

The BLM used an EPA report based mostly 

on theoretical analysis of potential asbestos 

exposure hazards. There have been no 

documented cases of lung cancer or any other 

asbestos related health problems related to 

recreational exposure at Clear Creek. The 

BLM should not cite reports which are not 

supported by actual health cases at Clear 

Creek. 

Refer to Common Responses 

Sections 1C, 1D, 3D, and 

4A. 

IND-COM-147 

One idea that I've never heard discussed 

during the Clear Creek debate, are tires. 

By imposing a restriction on the type of tire 

used at Clear Creek the BLM could greatly 

reduce the impact of motorcycles there. I'm 

specifically talking about the use of trials type 

tires on the rear wheel. Trials tires use a soft 

compound low profile knobby. These tires 

are not made to spin, they use low pressure 

and greatly reduce impact. 

Refer to Common Responses 

Section 1F(iii). Future 

activity-based studies could 

evaluate the levels of 

emissions and asbestos 

exposure associated with 

different tires. 

IND-COM-148 

Open up clear creek for riding permanently! 

Us riders are running out of places to ride. 

Refer to Common Responses 

Sections 3A and 3D. 

IND-COM-149 

I do not feel that the EPA and others that put 

in these closure ideas are not representing the 

People. This is because these agencies are our 

employees, and serve at our, the People's 

choice. 

I personally do not want this or any area 

closed to the public and I have many friends 

and organizations who feel the same. I'm sure 

the Sierra Club and other such like ECO 

groups have threatened with law suites and 

such. That's just their way to push your 

agency to pressure other over bureaucratic 

agencies to issue illegal closures and disregard 

the Peoples choice. If the closures are not 

established by legislative process, they have 

not been established by the People. 

Enough said, again, closing Clear Creek to the 

Public is unjust and not a want of the People 

as a whole, there are dangers all around us 

every day, getting dirty is by far a lessor 

danger. 

Refer to Common Responses 

Section 1G. 

IND-COM-150 

I am an avid recreational motorcylist, a Board 

Member of the Oakland Motorcycle Club, and 

chairman of its dualsport committee. I have 

ridden multiple times at Clear Creek. The 

Clear Creek Management Area closure is ill 

considered. I believe the health claims to be 

Refer to Common Responses 

Sections 1C, 1D, 4A and 4B. 

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exagerated and undocumented. The effect on 

motorcycle recreation is devastating. Please 

reconsider this action. 

IND-COM-151 

Please find a way to continue to allow 

reasonable access to ATVs to this area. 

Refer to Common Responses 

Section 3A. 

IND-COM-152 

My letter is in response to the recent closure 

order of the Clear Creek Management Area 

(CCMA). I realize that no decision to close 

lands which affects large amounts of land and 

people is easy yet I do not feel the decision 

was made with long term implications in 

mind. I will site three reasons why I believe 

the decision was not in the public’s best 

interest. 

1. With current noise regulations of 96dbA 

being a continuing issue the closure of 

CCMA forces more motorcycles to ride near 

homes and cities which operate current OHV 

park. Even if all the motorcycles are under 

the noise regulations that larger number or 

motorcycles will create a greater overall noise 

pollution. This will continue to fuel the feud 

between neighbors and park users. Where as 

CCMA has very few neighbors directly 

affected by noise and is a good area to allow 

motorcycle use. 

2. With the continued closure of public 

lands, the most recent being CCMA, my wife 

and two young sons are forced to ride in small 

crowded OHV parks. Even with wonderfully 

maintain parks like Hollister Hills the 

weekend crowds have resulted in many close 

calls between my family members and other 

riders. “During 2003, among persons aged 19 

years, at least 245 died and an estimated 

56,870 were treated in U.S. hospital 

emergency departments for injuries sustained 

while riding a motorcycle.” (JAMA. 

2006;296:273-274.) With injuries always on 

the ride BLM should be looking for ways to 

spread out motorcycle rides not pack them 

tighter together. 

3. There will be long term revenue loss to 

cities near closed public lands. As fewer 

people ride and purchase motorcycles local 

shops will close and those cities will lose tax 

Refer to Common Responses 

Sections 4B and 4D. 

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revenue. Local governments will receive less 

money for motorcycle registration. Thus, 

many of whom do not ride motorcycles, will 

be forced to make up the loss with higher 

registration costs. 

IND-COM-153 

On behalf of all my partners of the OPT 

Ranch I would like it entered into the record 

that if any of the [Tucker Zone] BLM lands 

that touch our property go up for sale we get 

the opportunity to bid on purchase some of 

this property. I am hopeful however that the 

idea we proposed about the limited Elk hunt 

in this area is something the BLM will take 

into consideration in deciding what to do with 

his land. I think this is a win win situation for 

all concerned. 

Refer to Common Responses 

Section 3D. 

IND-COM-154 

The public meetings were scheduled without 

adequate notice for preparation and to allow 

time to attend. I believe my written notice 

came about one week prior to the three 

meetings, which were scheduled almost back 

to back in mid January. No meetings were 

held south of Clear Creek where my 

experience indicates a number of users live. 

In generating the 691 page DEIS, data of airborn asbestos fibers was collected in Nov. 04, 

Feb 05, and Sep 05. These timeframes were 

selected to represent both dry and wet 

conditions. According to an EPA rep. the data 

was only collected over a one or two day 

period during the above months. In addition, 

the Feb. 05 data was collected during the 

Quicksilver National Enduro. that data would 

have been generated by 500 motorcycles 

leaving 4 per minute, plus ghost riders 

premarking the course, sweep riders clearing 

it, Individual 5-7 person check crews, in 4X4's 

and quads, operating a dozen or more checks 

to score competitors, Search and Rescue 

coming and going and numerous "outlaw" 

riders traversing the course. In addition, the 

course would have repeated many of the same 

trails 2 or 3 times to achieve the necessary 

loop mileage for the competitive event. This 

data hardly represents the "average" asbestos 

exposure during an "average" wet weather 

weekend. None of the data collected should 

be used as a baseline due to the limited 

Refer to Common Responses 

Sections 1C, 1D, 3A, and 

4D. 

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timeframe of the samples and the Feb. 05 data 

being biased. 

Due to lack of notification will the economic 

impact be adequately considered not only in 

the immediate area but in outlying areas 

where users reside? 

Review of the seven alternatives raises 

questions. Alternatives such as the BLM 

Preferred Alternative would essentially 

remove all recreational access to the entire 

75,000 acres. Although it indicates 

"proposed" new access routes outside the 

Serpentine area, these would only allow 

access for rock hounds, hunters and hikers. 

According to a Hollister BLM rep. there is no 

timeline for implementation nor is there any 

funding source identified. Neither CORVA or 

the Green Sticker Fund will support or fund 

"access" roads. Remember the American 

Indian and promises the Government made? 

None of the Alternatives offer mile for mile 

alternate trails created prior to closure of 

existing trails in the Serpentine area. 

Therefore, I would suggest the public 

comment period be extended with a more 

zealous public notification process, the 

asbestos data be acquired over a broader 

sampling period by an outside contractor, 

economic impacts be more thoroughly 

addressed, and Alternatives include support 

for use of existing areas while alternate trails 

are created. 

IND-COM-155 

Refer to Table X-6: HGMC-FORM Summary 

& Response. 

Refer to Table X-6: HGMCFORM Summary & 

Response. 

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IND-COM-156 

Clear Creek Area is like a real life book of 

Nature with pages and pages of information 

on geology, rock formation, mineralogy, 

plants and animals. It gives one a real 

appreciation on the beauty of nature. Spending 

time there enriches the soul. It's value is 

incalculable. The area should be left open for 

all to enjoy!!!!!!!! 

I was very sad when my Grandpa told me we 

couldn't go rock collecting at Clear Creek any 

more. I hope he is wrong!!!!!!! I have FUN 

going with him. He has taught me alot about 

the different rocks. I like the green ones the 

best. Don't close my favorite spot in the whole 

world. 

Refer to Common Responses 

Sections 3D. 

INDCOM157 

My comments are limited to the "cultural resources" aspects of the 

DRMP/EIS, concerning the cultural/historical significance of the area and the 

impacts of management on cultural values. 

The DRMP/EIS is schizophrenic on the subject of cultural resources. In its 

generalities, it embraces a broad definition of the term that quite properly 

cites as examples historic properties of various kinds and culturally 

significant natural features of the environment. When it discusses how such 

"resources" will be managed, however, it appears to address only 

archaeological sites, with an occasional half-hearted bow toward Indian tribal 

traditional cultural properties. It is clear from the descriptive parts of the 

document that at least three and possibly four communities ascribe traditional 

cultural significance to the CCMA, more or less in its entirety -- (1) members 

of federally recognized and non-recognized Indian tribes; (2) rockhounds, (3) 

off-highway vehicle (OHV) users, and (4) possibly hunters. It appears likely 

that the significance ascribed to the area by each of these groups, grounded in 

association with their traditions and history, is sufficient to make all or much 

of the CCMA eligible for inclusion in the National Register of Historic 

Places, but once the evidence for it has been summarized, this likelihood is 

never further addressed in the DRMP/EIS. When the DRMP/EIS gets around 

to discussing management strategies, "cultural resources" and indeed by 

implication even the narrower category "historic properties" have seemingly 

come to mean archaeological sites alone, and the activities of the OHV 

community are treated only as impacts on this narrow range of resources. 

Clearly, there is a need for further analysis of the eligibility of the CCMA for 

the National Register based on its traditional cultural value to tribes, 

rockhounds, the OHV community, and hunters, performed in proper 

consultation with these groups. I find no evidence in the DRMP/EIS that 

BLM has undertaken efforts to comply with the requirements for such 

consultation imposed by Section 110 of the National Historic Preservation 

See 

reply 

below. 

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Act (NHPA) or by the regulations implementing Section 106 of the same 

statute, except via its "protocol agreement" with the California State Historic 

Preservation Officer. If this agreement (which itself is virtually inaccessible 

to the public) allows BLM to "comply" with Section 106 without consulting 

such affected groups as the tribes, rockhounds, OHV people, and hunters, it is 

a questionable agreement indeed. 

BLM Response to IND-COM-157: Refer to Common Responses Sections 2A , 2B, 2C, 3A, 

3D, 4B and 4D. The CCMA Draft RMP/EIS and this PRMP/FEIS identify the CCMA public 

lands recreation resources in Section 3.1 and cultural resources in Section 3.13. The CCMA Draft 

RMP/EIS and this PRMP/FEIS identify the impacts of the range of alternatives for CCMA on 

OHV recreation in Section 4.1 and social and economic values in Seciton 4.15. 

The purpose and need statement contained in Chapter 1 (Section 1.1) of the CCMA Draft 

RMP/EIS and this PRMP/FEIS includes designating areas in CCMA for appropriate recreation 

opportunities and protecting sensitive natural and cultural resources from impacts due to 

recreation activities. Listing a traditional cultural property (TCP) to the National register of 

Historic Places (NRHP) does not afford automatic protection of the TCP for the use of the group 

that values the TCP, nor does it provide for exclusive use of the TCP. 

Section 4.2.1.1 of the CCMA Draft RMP/EIS and this PRMP/FEIS identify assumptions 

incorporated into the analysis of human helath risks associated with allowable uses in the 

Serpentine ACEC. Based on the assumption that “Risk calculations for hiking and hunting would 

be representative of all non-motorized use (i.e. rockhounding)”, the traditional use activities 

practiced by the Native American community and the rockhounding community would continue 

to be allowable uses in the Serpentine ACEC undet the BLM’s proposed resource management 

plan. 

Chapter 1 (Section 1.5) details the relationship of the CCMA RMP/EIS to other policies, plans, 

and programs, including requirements for agency and tribal consultation, as well as public 

involvement pursuant to NEPA. Chapter 5 (Section 5.2.5) of the CCMA Draft RMP/EIS and this 

PRMP/FEIS describes the Federal, State, Tribe, and local government consultation and 

coordination that took place during the preparationof this land use plan for CCMA public lands in 

compliance with Section 106 of the NHPA. 

IND-COM-158 

pls include this email in support of Clear Creek being 

open for OHV use. Our family (wife, young daughter, 

young son, father) have chose to direct some of our 

resources (including money in local businesses—about 

$3,000 per year) in this sport for the quality of family time 

it provides. No TV’s, no PDA’s, no texting, etc....we are 

with each other w/o distractions, and, in nature and we 

appreciate that. As parents, we also use these times as an 

opportunity to teach our kids to appreciate nature and 

preserve mother earth. 

Refer to Common 

Responses 

Sections 3D and 

4D. 

IND-COM-159 

Please reopen Clear Creek to OHV use, rode may Enduros 

that the Salinas Ramblers & the Timekeepers Motorcycle 

Clubs put on, motorcyclists are great stewards of the land, 

thank you for considering my views, 

Refer to Common 

Responses 

Sections 3A and 

3D. 

IND-COM-160 The rate at which OHV parks and other legal OHV areas Refer to Common 

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are being closed or otherwise made unavailable to the 

paying public is sickening. I would greatly value the 

opportunity to be able to ride a motorcycle somewhere 

other than private property in the future. Even if it means 

imposing and/or increasing fees for use, keep clear creek 

open. 

Responses 

Sections 3A and 

3D. 

IND-COM-161 

I am an active outdoors person with a family of 3 young 

boys who engage in outdoor activities regularly. I have 

been visiting the Clear Creak Management area for the 

past 10 years quite often taking my family there on 

camping excursions. 

A friend and I had started mining various rocks in 2007 

and shortly after filed a mining claim, which I believe it 

our right to continue to use. 

In addition to other outdoor activities such as hiking, 

fishing, and rock collecting, my family is engaged in 

recreational motorcycle trail riding. I have used the trails 

at clear creek for ten years now and profoundly effected 

by this closure. 

Due to this closure, I believe my rights are significantly 

impacted and I will be one of many to fight for my legal 

use to mine my claim and fight for the right to use the 

lands in the most logical way...which is to continue to 

allow OHV use in the CCMA 

Refer to ORG-TMC & ORG-3ROCKS Comment 

Summary 

Refer to ORGTMC & ORG3ROCKS 

Comment 

Response 

IND-COM-162 

I support Alternative B. Alternative B will need future 

fine tuning, but, it satisfies more of the public's needs. I 

would like to see the inclusion of public wash rack. Do 

not restrict ages as mentioned in Alternative C. OHV use 

is a family activity! 

Refer to Common 

Responses 

Sections 3A, 4B, 

and 4D. 

IND-COM-163 

I wanted to register my request for consideration of access 

to the Clear Creek Management Area for the recreation of 

hang-gliding and paragliding on behalf of myself, and 

several clubs in the San Francisco, San Jose, and 

Monterey areas. 

Until the recent closure, we had been flying from Goat 

Mountain and San Carlos Peak to landing areas outside 

the CCMA. Although our launch points also lie outside 

the CCMA boundary, our access had been via R011, 

R001, and T104 along the interior edge of the CCMA. 

Our use is very low impact on the CCMA as we only need 

occasional vehicle access to the Goat Mountain and San 

Carlos Peak areas to drop off our gear, then leave the 

CCMA. 

Refer to Common 

Responses 

Sections 3A and 

3D. 

IND-COM-164 

The BLM needs to correct the report and replace the the 

words "The result of the study concluded" to "The EPA 

report indicates the risks are uncertain". 

Refer to Common 

Responses 

Sections 1D and 

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4A. 

IND-COM-165 

As a user of public lands for recreation, I am strongly 

opposed to the closure of Clear Creek. In the past I have 

used this area for OHV recreation and would like to use 

this area for hunting and OHV use in the future. With the 

growing population of this state so also grows the need for 

more available public accessto properties such as Clear 

Creek. The more area available the safer we can keep 

these activities and the more we can reduce the impact on 

any one area. Please consider plea to reopen Clear Creek 

for recreation. 

Refer to Common 

Responses 

Sections 3A and 

3D. 

IND-COM-166 

We are writing to make comments on the future 

disposition of the Clear Creek Management Area. Our 

comments are both professional, as my wife is a PhD 

trained epidemiologist, and personal, as I am a 

horticulturist and both of us are members of the California 

Native Plant Society, birdwatchers and rockhounds. We 

attended the meeting on the Clear Creek closure to hear 

what chances we would have to enter this area and 

understand that a number of possible outcomes are being 

considered. 

From a risk and hazard standpoint, we want to point out 

two recent articles in the environmental and occupational 

peer-reviewed literature that point to the difficulty in 

measuring environmental asbestos risk accurately and the 

adverse health outcomes of denying people the ability to 

enjoy the outdoors. 

1. Silverstein MA, Welch LS, Lemen R. Developments in 

asbestos cancer risk assessment. Am J Ind Med. 2009 

Nov;52(11):850-8. 

These researchers are from the Department of 

Environmental and Occupational Health Sciences, 

University of Washington School of Public Health, 

Seattle, Washington. They describe efforts that have been 

made for the past 25 years to determine valid information 

on asbestos risk at both the worksite and the community. 

In a comprehensive review of risk assessments by the 

EPA, OSHA and NIOSH, these researchers determined 

that none of the efforts to use statistical models to predict 

cancer risks from asbestos of different fiber types and 

sizes were able to overcome limitations of the exposure 

data. They conclude “Resulting uncertainties have been so 

great that these estimates should not be used to drive 

occupational and environmental health policy.” 

We agree, and understand that while occupational health 

providers and researchers have examined asbestos risks 

Refer to Common 

Responses 

Sections 1A, 1B, 

1C, 1D, 1F(i), 

1F(ii), 3D, 4A, 

and 4D. 

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and outcomes for a number of years, these investigations 

have been based on exposure to specific asbestos fibers 

within defined closed settings of the occupational site, and 

not related to recreation in an open area. 

2. Harper M. J 10th Anniversary Critical Review: 

Naturally occurring asbestos. Environ Monit. 2008 

Dec;10(12):1394-408. 

Dr. Harper is from the Exposure Assessment Branch, 

Health Effects Laboratory Division, of the National 

Institute for Occupational Safety and Health. He describes 

the ubiquitous nature of naturally occurring asbestos in a 

number of areas of the world. While he acknowledges the 

risk of diseases from high exposures among miners and 

asbestos products workers, he clearly states that the risk to 

health of living or being in an area where there are natural 

occurrences of asbestos minerals is not well proven, and 

points out that the accepted definitions of asbestos, 

including dose and mechanisms of measurement, are not 

clear or well accepted. He concludes “The discovery of 

asbestos or related minerals has consequences beyond any 

immediate risks to health, including profound effects on 

the value of and ability to use or enjoy property.” 

As an epidemiologist, my wife fully understands the 

scientific mistakes that are made when anecdotal evidence 

is provided to justify a position (for example, someone 

who smoked for many years and never got cancer). 

However, anecdotal evidence can be the start of scientific 

inquiry; and to date, there has been no anecdotal – much 

less scientific – evidence of people getting the diseases 

associated with asbestos from the Clear Creek area or 

from other naturally occurring outside sites. While 

difficult to study diseases with long incubation periods, it 

is possible to do so, and there simply is no evidence in the 

medical literature to support an excess risk from asbestos 

in naturally occurring regions. And the fact that California 

has so much naturally occurring asbestos, one would think 

that our morbidity and mortality from asbestos-related 

causes would be higher in the general public, and long 

ago brought to the attention of public health officials. 

The statement of Dr. Harper about the effects of people 

not being able to use or enjoy property embodies the 

sentiments of many of us who want to enjoy recreation at 

Clear Creek. There could and should be studies of quality 

of life issues related to reduced ability to use national 

lands. For us and for many others, the benefits of being in 

this unique and special region clearly outweigh the risks – 

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whatever they may be and however they may be 

measured. 

We are sure the BLM understands what a special and 

unusual place Clear Creek really is. If a risk related to 

recreational exposure to naturally occurring asbestos 

actually exists, the risk to us personally is extremely low: 

we are both in our sixties and our exposure while driving 

in an enclosed auto lowers this yet further. Our interest is 

in being able to hike and enjoy the area, and having to 

walk in from the entrance would be difficult if not 

impossible. While we wish the BLM would reopen Clear 

Creek entirely, we profoundly hope that we will retain 

access to the area. Specifically we would think that a 

minimal access for recreation would include keeping open 

a circle loop of roads: from Clear Creek Road into the 

area, meeting the Idria Road that climbs the ridge 

(allowing access all the way to Spanish Lake) then to 

T175 that gives access to the California State Gem Mine, 

meeting the paved road that ends at Sawmill Creek, then 

completing the loop (through Four Corners and T151) 

back to the Clear Creek Road. This loop goes through all 

the geologic, plant and wildlife regions in this magnificent 

area, allowing enjoyment for rockhounds, native plant 

folks and bird watchers. 

IND-COM-167 

If the dangers are so real and present, why are there NO 

deaths or health related problems surfacing today? I feel 

the BLM closed the area to avoid lawsuits that might 

appears in the future and can't afford to defend themselves 

from frivolous claims. Just check out the mining records 

for a real perspective of the risks over the last 100 years. 

The land should be open to the public with maps provided 

and supervision supplied by BLM. 

IND-COM-168 

Refer to Table X-6: HGMC-FORM Summary & 

Response. 

Refer to Table X6: HGMC-FORM 

Summary & 

Response. 

IND-COM-169 

I tried to read through the EIS and what I gleaned from it 

is that this will be one more area that the powers that be 

are trying to make unavailable to the off road community. 

I have been on the loosing side of so many of these 

debates I sometime wonder why I even bother. Then my 

family suggests that we go riding and it becomes clear to 

me that I have a responsibility as a father, husband, 

taxpayer, citizen to fight for me right to the land I pay for. 

KEEP THE OHV AREAS OPEN PLEASE!!! 

Refer to Common 

Responses 

Sections 1G. 

IND-COM-170 

The (EPA Report) designated the 11/02/2004 testing as to 

have occurred under “moist” conditions despite not one of 

Refer to Common 

Responses Section 

1C. 

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the soil samples collected on 11/02/2004 actually meeting 

the specified criteria to be considered “moist”, instead 

they met criteria to be considered “dry”. 

The (EPA Report) did not provide the BLM with any data 

representing the “moist” season, the very season that the 

BLM and EPA both state that the most people visit the 

Clear Creek Management Area. 

Therefore the BLM has no asbestos exposure data 

representing the most popular visitor season at the 

Clear Creek Management Area, the “moist” 

(fall/winter/spring) season. Furthermore the BLM has no 

data representing “typical” asbestos exposures due to the 

EPA employees riding their ATV’s at excessively high 

speeds (breaking posted speed-limit) and the employees 

riding back and fourth through their own dust. 

IND-COM-171 

I find it hard to believe that our findings are factual. I 

would like to think that you would welcome a peer group 

to come in and do their own study. Since I don’t show any 

effects of asbestos I don’t understand why there can’t be a 

compromise. Mybe just red sticker season. That way it 

can be open for hikers and rockhounds during green 

sticker season. 

Refer to Common 

Responses Section 

1F(iii) and 3A. 

IND-COM-172 

It is in the best interests of all concerned to manage the 

area as it has always been. I have been using the area 

since the middle sixties and have suffered no health issues 

related to that usage. That means I have used the area 

about 45 years, making as many as 30 trips a year for 

various activities at different seasons and have no asbestos 

related problems. In addition, the lands in question were 

set aside for the people of the United States of America to 

enjoy and recreate on. Clear Creek is the last remaining 

land of it’s type and the only place close enough to the 

Central Valley and the Bay Area for the multiple uses that 

are allowed there. I’m old enough to remember when the 

Panoche Hills were closed to use. It was only going to be 

for “a little while” and then the area would be open again. 

Same thing with Tumey Hills and The Griswold area. 

Well, we saw how that worked out. 

I ask that the Clear Creek area be managed as it has been 

with signs warning of the asbestos in the area and let 

people decide if they want to use the area or not. It should 

be the users decision to use it or not instead of the 

government telling the people what to do and how to live. 

Refer to Common 

Responses 

Sections 1F(i), 3A, 

and 3D. 

IND-COM-173 

I question many of the base assumptions and I am very 

much concerned with the approach used in your draft 

environmental statement (DEIS) wherein you consider all 

types of naturally occurring asbestos as being of equal 

Refer to Common 

Responses 

Sections 1A, 1B, 

1C, 1D. 1F(i), 3A, 

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health risk, when there is growing evidence that such is 

not the case, and those risks being based on occupational 

health studies involving manufacturing of and 

manufactured asbestos products. I do not think, as it has 

not been demonstrated, that all serpentine soils exhibit the 

same toxicity as assumed in your consideration of 

alternatives, and I do not believe the occupational health 

studies you cite are applicable to the very limited 

exposures that might be encountered during my 

occasional visits within the CCMA. The DEIS fails to 

identify or cite any actual case where an individual has 

contracted any of the negative health 

conditions as a result of exposure to serpentine soils. 

My use of the CCMA certainly does not fit within the 

parametric assumptions used in EPA’s Risk Analysis 

study with regard to acceptable exposure levels, nor with 

actual real life experiences of those who have used the 

CCMA. 

EPA’s suggested acceptable death rate for cancers from 

exposures to asbestos is 1 in 10,000. The EPA proposed 

acceptable cancer risk rates are what the EPA has used in 

the past for people, who because of their occupation, or 

where they live, are exposed to asbestos in a continuous 

and cumulative manner and is not an appropriate value for 

occasional educational and recreational activities where 

persons, well informed of the potential risk, do so of their 

own free will. 

Many people who have lived and recreated in the CCMA 

for long periods of time have commented, over and over, 

that they have not seen any of their contemporaries 

developing cancers or long term diseases for which 

asbestos exposures are known causes. It is by no means 

certain that such limited individual access as mine will 

ever come close to the cumulative exposures suggested in 

the EPA Risk Assessment study. 

Rather than arbitrary restriction of access into the CCMA, 

I feel strongly that there are better means of mitigation of 

the perceived hazard. I assume the BLM is well aware of 

the studies showing that overlaying of existing serpentine 

soil roads with nonserpentine gravels or other surface 

treatments can reduce the amount of natural occurring 

airborne asbestos particles raised by vehicular travel on 

such roads by as much as 98%. (Seç California 

Department of Toxic Substances: “Study of Airborne 

Asbestos from a Serpentine Road in Garden Valley, 

California”). This is a sensible, effective and inexpensive 

3D, 4A, and 4D 

462
 
 

 

 

 

 

 

 

 

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means of abatement, and I am curious as to why, if the 

concern here is primarily about asbestos exposure, has not 

the Clear Creek Road been so graveled and maintained in 

the past. 

I believe that the Federal Land Policy Act of 1976, as 

amended, would dictate that BLM provide safe passage of 

the public land to users along public roads to meet the 

management goals outlined in your governing legislation 

and congressional intent. The section of the Clear Creek 

Road along the creek and some of the campgrounds 

associated with this road, which receives the bulk of 

public use, should be the primary candidate for remedial 

treatment, in keeping with the Federal Land Policy Act. 

This would help all users of the CCMA, including BLM 

personnel in administering their duties in the 

CCMA. I see no reason that non-serpentine soils or 

gravels or other type treatments cannot be done to surface 

the existing roadways and campgrounds. For those roads 

and trails where it is not practicable to provide surface 

treatment, I would suggest that the BLM develop a permit 

system for general public use based on user age and the 

frequency of access to the CCMA. The establishment of 

such dosage limits for exposures where potential hazards 

are identified is a common environmental and health 

safety practice. 

When I visit the CCMA, I usually stop in either Coalinga 

or Hollister and purchase fuel and supplies for camping 

for which I usually spend approximately $125. Your 

DEIS estimates future use of the CCMA of 50,000 visitor 

use days. At $125 per visitor use day that is $ 6,250,000 

dollars lost to the local economies per year, if you close 

access to users of the CCMA. This is a tremendous social 

and economic loss not accounted for in your DEIS. In that 

regard your DEIS is legally insufficient. 

Alternatives D and E in your DEIS are also not real 

alternatives, since implementing those alternatives would 

require another EIS. Those Alternatives would also open 

new areas to soil erosion. Again your DEIS is legally 

insufficient. Alternative E allows limited vehicle access 

from New Idria to Wright Mountain with surface 

treatment of only that particular road. Why is just this 

road the only one considered for surface treatment? Why 

not the Clear Creek Road? Again, your DIES is legally 

insufficient. 

IND-COM-174 

I’ve been riding there for 30 years with my family, 

friends, and club members; and we spend money down 

there. Hollister Hills is very over busy with bikes and is 

Refer to Common 

Responses 

Sections 4B and 

463
 
 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

very dangerous. 4D. 

IND-COM-175 

I strongly believe that we need to keep our existing ohv 

areas open. We only have so many places to ride as it is. 

Close clear creek and we just send more into illegal 

forests to ride. 

Refer to Common 

Responses Section 

4B. 

IND-COM-176 

I have gone to clear creek to ride as long as i can 

remember... It is very important to have places for off 

road motorcycles and recreational activity... I do not 

suffer from any health problems of any kind... We must 

have land like this for this kind of usage.... Can we please 

have some common sense reasoning... 

Refer to Common 

Responses 

Sections 3A, 3D, 

and 4B. 

IND-COM-177 

By modifying the language of the initial EPA 

environmental exposure report, the BLM severely 

compromised the integrity of the report. Therefore any 

actions taken utilizing this report as guidance are flawed 

from the starting point. 

BLM failed to disclose that the locations to be tested were 

historical industrial dump sites. The results of the tests 

themselves are questionable as the EPA failed to track the 

location of the field agents collecting data to be used in 

the final report. 

Even if testing results yielded valid information, the data 

still would not be applicable as it does not take into 

consideration the nature of exposure that visitors to the 

CCMA will experience on site. 

Forcing an industrial asbestos exposure model where it 

does not fit completely discredits EPA as well as the BLM 

as it simply appears that the current BLM agenda to close 

the CCMA must be afforded at all costs. People recreating 

in Clear Creek are not engaging in 40 hour work weeks 

there. 

There is a total lack of physical evidence to support the 

actions of the BLM and this speaks louder than any study 

or claim made by the EPA regarding the environmental 

dangers associated with Clear Creek. To date, not one 

single report of illness or death has ever been presented by 

any party within the pervue of this closure. 

Motorcycle shops, restaurants, gas stations and 

supermarkets have all felt the impact of this closure and in 

a devastated economy, the closure may well sound the 

death knell of many honest American small businesses. 

This is a shameful legacy the BLM has not taken any 

interest in outside of the prerequisite public meetings that 

are required by law. 

Refer to Common 

Responses 

Sections 1C, 1D, 

1F(i), 3A, 4B, and 

4D. 

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With the notable exception of Alternative “A”, the BLM 

has failed to put forth a suitable remedy that does not 

either severely restrict or force a total prohibition of 

motorized recreation in the CCMA. This is contrary to the 

parks original chartered purpose. 

The closure of Clear Creek has resulted in dangerous 

congestion of the very few remaining off road parks that 

remain open. Head on collisions are up and the ability 

to maintain trails and paths is becoming difficult from 

over use. This is creating an unsustainable environment in 

which too many riders are confined in small spaces and 

the end result is physical injuries and damage to the trail 

systems in the parks themselves. 

IND-COM-178 

I would like to express my desire to have the Clear Creek 

Management area kept open for limited recreational use. I 

believe the studies used as a basis for closure are flawed 

in that they only take maximum exposure into account. 

No recreational users or management personnel have ever 

been diagnosed with any asbestos-related diseases. OHV 

use, which does have significant impact, asbestos aside 

could be relocated to nearby areas outside the area of 

elevated asbestos. Other recreational activities such as 

hunting, rockhounding, birdwatching and hiking have a 

much more minimal impact. 

Refer to Common 

Responses 

Sections 1C, 1D, 

1F(i), 3A, 3C, and 

3D. 

IND-COM-179 

I belong to two rockhound clubs: San Francisco Gem and 

Mineral Society, and the Sequoia Gem and Mineral 

Society. It has come to my attention that you intend to 

close the Clear Creek area because of “asbestos” in the 

area. Also found in the area are rocks that are Serpentine, 

as well as other minerals. Rockhounds have been going to 

the area for years and banning the area because of only 

one suspect mineral is not reasonable. Benitoite, which is 

a rare mineral, is found in only this area, and is mentioned 

in several Rock books. This is an important area for 

collecting and studying our earth and I hope you 

reconsider your thoughts in this manner and allow access 

to this area for future use. 

Refer to Common 

Responses Section 

3D. 

IND-COM-180 

I wanted to share how unfair I believe it is to close Clear 

Creek for ever. Public Lands are important to our 

History. Comment noted. 

IND-COM-181 We have fun out there. Open it all back up. Comment noted. 

IND-COM-182 

[Clear Creek] needs to be reopened to the public. It is 

hurting the local economie and the over state budget 

Refer to Common 

Responses Section 

4D. 

IND-COM-183 

The new proposed restrictions are a slap in the face to the 

hard working American families that have paid for & 

enjoyed these public lands for generations. With the 

expanding population of people wanting access to their 

Refer to Common 

Responses 

Sections 4B and 

4D. 

465
 
 

 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

public lands , closing or restricting access just increases 

the overuse of the few areas that remain open. The 

American public needs more access, not less. The 

majority of us also do not require any new structures, 

signs, parking lots, roads or improvements, we just want 

sensible access to our lands. 

IND-COM-184 

The BLM used an EPA report is based on theoretical 

analysis of potential asbestos exposure hazards. There 

have been no documented cases of lung cancer or any 

other asbestos related health problems related to 

recreational exposure at Clear Creek. The BLM should 

not cite reports which are not supported by actual health 

cases at Clear Creek. 

The studies used to justify the closure of Clear Creek 

Management Area are based on 40 hour work week 

occupational exposure to asbestos. The visitors at CCMA 

are recreational users with possible exposure of only a 

couple of hours to a couple of days at a time. The BLM 

needs to reconsider projected exposure levels for 

recreational visitors, as compared to studies of 

occupational workplace exposure. 

There are no documented cases of BLM employees 

diagnosed with cancer due to exposure at CCMA to the 

Chrysotile form of asbestos. BLM employees spend more 

time in the area than recreational visitors. If employees 

are not experiencing health related asbestos issues then 

there must not be any real health risk. 

Actual health risks are much lower than those estimated in 

the CCMA assessment since the area doesn?t have the 

same exposure levels as studied in occupational examples. 

The DEIS must consider the uncertainty rather than using 

worst case scenarios. 

The EPA report is flawed and should not be relied upon 

for the agency?s decision to enact a closure of the CCMA 

to all public use. 

Refer to Common 

Responses Section 

1C, 1D, 1F(i), and 

4A.. 

IND-COM-185 

I would like to express my feelings as a Geologist with 3 

degree's and have been collecting minerals in the Clear 

creek area since I graduated high school in Danville CA in 

1977. Makes me 50+ years old now collecting jade and 

gems and minerals for 33 years there. What I would like is 

unrestricated access to where I have been going for the 

past 33 years without having to fill out forms and pay 

more money. I don't understand the closure legal 

formalities I am a field geologist. I have many physical 

ailments but luckely so far my lungs are strong partly due 

to hiking and packing out rocks in the clean mountain air 

Refer to Common 

Responses Section 

3D. 

466
 
 

 

 

 

 

 

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Proposed RMP and Final EIS – Volume II 

and swimming in the streams. I do see an issue with the 

installment of multiple staging area's designed to promote 

ohv use and then subsequntly denying that use to the 

public of public lands. I do believe that the dust is 

potentially harmful and people should not breath dirt. The 

children should be protected and aware of the hazards. 

The dirt bikers are a nusance to me during my mineral 

collecting and I don't like their presense but I believe they 

have there rights to access. I belong to the Calaveras gem 

and mineral society and we must all adhere to a code of 

ethic's for mineral collecting. So please do what you will 

but let me do what I do best, collect, process and beautify 

peoples lives with gems. I do 40 trade shows a year, been 

selling as California Mineral Company since 1982 and 

power seller on ebay, Doing my job to promote the 

ecomony and generate out of state dollars. So I would 

appreciate a special use permit or some type of 

unrestricted access permit.would be my ideal situation, 

IND-COM-186 

I have read the report that closed Clear Creek. According 

to the Federal Government, unproccessed espstose can not 

harm, nor endanger any one. The report actually stated the 

levels, and they are low enough. Victoms of nemponiliom 

from Clear Creek really exist? It wasn't from some place 

they worked, or a school they went to? I have worked in 

the trades almost my entire life, and I have seen more 

espestose in schools, public buildings government offices, 

and Hospitals. That’s the bad stuff, processed. 

How many cases have actually been related to Clear 

Creek, New Idria area. or can it be proved? It can't. 

I grew up having the hills of Prunedale to ride in with out 

a problem. The generation before me did as well. Those 

guys had no real problems, minus the drunks, and a few 

vets had drug issues, but it gave us an outlet, and some 

thing constructive to do with our time. Kids now 

days don't have that, just better vidoe games and better t.v. 

to watch. 

I guess my total point is, please stop take what little we 

have to do away. If its posted that possibly this could 

happen, fine. Let the public make there own decisions, 

and give some of our tax paying privlegdes back. If we 

want to smoke, ride, eat dirt, or what have you, lets do it 

on our own, not with someone dictating what we can do. 

Refer to Common 

Responses Section 

1G. 

IND-COM-187 We would vote for plan b. Comment noted. 

IND-COM-188 

I do not understand why the area had to be closed. I used 

to live in the North East and when fishing we all knew to 

limit our consumption because of the mercury 

contamination of the fish. There was never a thought of 

not allowing any fishing and I can not understand why 

asbestos warnings would not be sufficent. 

Refer to Common 

Responses Section 

3A and 3D. 

IND-COM-189 As part of the federal government the BLM should take Refer to Common 

467
 
 

 

 

 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

the same course of action with the Clear Creek 

Management Area that it has with the tobacco industry. 

Each year more people die of the affects of tobacco use 

than from any activity at Clear Creek. The alternative 

which leaves Clear Creek as is and promotes educating 

the public on the risks of activity in the area is consistent 

with how the federal government handles tobacco. 

Each year thousands of people are killed or injured from 

the effects of alcohol. How has the government handled 

this? They have not banned alcohol use. They have 

established limits on blood alcohol levels. How have they 

enforced this? They leave it up to the individual to decide 

when they have had enough. They do not physically track 

how much you are drinking they only enforce the rules 

after the fact. 

What course of action should the BLM take? They should 

follow the same pattern that has been set by the federal 

government. Educate the people on the risks associated 

with activity in the Clear Creek Management Area and let 

them decide if the risk is worth taking. Don’t put a limit 

on how much time can be spent in the area, let the 

individual decide when they have had enough. Please 

apply the same standards to the Clear Creek Management 

Area that federal government has applied to the tobacco 

and alcohol industry. Let us choose for ourselves. Let us 

ride. 

Responses Section 

3A and 3D. 

IND-COM-190 

I have ridden motorcycles at Clear Creek since 1984. I am 

well aware of the asbestos problem and ride when the 

terrain is damp or wet and the dust is not a problem. Clear 

Creek should not be closed because someone else thinks it 

may be a health hazard! Our family of friends share my 

feelings and have always held Clear Creek as the Premier 

riding area in the State of California!!! 

Refer to Common 

Responses 

Sections 1D, 3D, 

and 4A. 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Table X-5; Form Letter Author List (Written and e-mail) 

Extend Public Comment Period Form Letter 

Comment 

Code Commenter 

EXT-COM-01 Alex Wagner-Jauregg 

EXT-COM-02 Andrew Hagen 

EXT-COM-03 Arago, Alec 

EXT-COM-04 Barry Siebenthall 

EXT-COM-05 Bill Charles 

EXT-COM-06 Brian Dean 

EXT-COM-07 Brian Jansen 

EXT-COM-08 charlie hartmetz 

EXT-COM-09 CHUCK MONASMITH 

EXT-COM-10 Cory Borovicka 

EXT-COM-11 David Furrer 

EXT-COM-12 david taylor 

EXT-COM-13 ED SANTIN 

EXT-COM-14 Eric Buchner 

EXT-COM-15 Ernie Salle 

EXT-COM-16 Garcia, Anson 

EXT-COM-17 Tom Keith 

EXT-COM-18 home 

EXT-COM-19 Justin Hensley 

EXT-COM-20 John F. Humphries 

EXT-COM-21 Jason Weihe 

EXT-COM-22 Jeff Davies 

EXT-COM-23 Jeff Peterson 

EXT-COM-24 Jeff Steiner 

EXT-COM-25 Jennifer Schreck 

EXT-COM-26 Jerry 

EXT-COM-27 Jim & Laurie Carrick 

EXT-COM-28 John Spaulding 

EXT-COM-29 John W. 

EXT-COM-30 Jon Lee 

EXT-COM-31 Justin Hensley 

EXT-COM-32 Wayne Berry 

EXT-COM-33 Ware-Rachels, Christine 

EXT-COM-34 Tom Stillman 

EXT-COM-35 Tim Kerber 

EXT-COM-36 suzbandit987 

EXT-COM-37 Steve Hatch 

EXT-COM-38 Steve Farinelli 

EXT-COM-39 Sean Biggs 

EXT-COM-40 

Christopher G. Rudy 

Esq. 

EXT-COM-41 Robert Morris 

EXT-COM-42 Robert Henry 

EXT-COM-43 Ray McCaskey 

EXT-COM-44 Neil Schmidt 

EXT-COM-45 kga125 

EXT-COM-46 Ken Clarke 

EXT-COM-47 Justin Kulikov 

EXT-COM-48 JOSEPH C FISHER 

EXT-COM-49 Jon Heyliger 

EXT-COM-50 John Bengtson 

EXT-COM-51 Jodi Collins 

EXT-COM-52 Jeff Wiley 

EXT-COM-53 Jeff Schulz 

EXT-COM-54 Justin Hensley 

EXT-COM-55 George Portugal 

EXT-COM-56 Frank Schweininger 

EXT-COM-57 Frank Nye 

EXT-COM-58 Nick Harris 

EXT-COM-59 Evan Jessee 

EXT-COM-60 Durinda Thomas 

EXT-COM-61 Daniel Epper 

EXT-COM-62 Curtis Matthews 

EXT-COM-63 Bob Wilson 

EXT-COM-64 Andrew Lesslie 

EXT-COM-65 John Ruiz 

EXT-COM-66 Andrew Hagen 

EXT-COM-67 Dave Pickett 

EXT-COM-68 Robert Hale 

EXT-COM-69 Anson Garcia 

469
 
 

 

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EXT-COM-70 Ken Flores 

EXT-COM-71 Kimiko Lauris 

EXT-COM-72 kyle newman 

EXT-COM-73 Ladd Johnson 

EXT-COM-74 Howard L Hughes 

EXT-COM-75 Mark Norman 

EXT-COM-76 melissa allen 

EXT-COM-77 Michael Miller 

EXT-COM-78 Michael Studzinski 

EXT-COM-79 mike monroe 

EXT-COM-80 Murray, Jaclyn 

EXT-COM-81 Nick Avakian 

EXT-COM-82 Paul Toepel 

EXT-COM-83 Steve Brown 

EXT-COM-84 Ric Williams 

EXT-COM-85 Rick Field 

EXT-COM-86 Rigby, Greg 

EXT-COM-87 Rob Stuart 

EXT-COM-88 Shawn Williams 

EXT-COM-89 Tim Cecil 

EXT-COM-90 THURMAN CREEL JR 

EXT-COM-91 Tim Field 

EXT-COM-92 Tim Stockwell 

EXT-COM-93 Todd Mansfield 

EXT-COM-94 tony smith 

EXT-COM-95 William McGibbon 

EXT-COM-96 William Ow 

EXT-COM-97 Ed Poe 

Save the Trails Form Letter 

Comment Code Commenter 

STT-FORM-01 Aaron Davis 

STT-FORM-02 ahmed nasus 

STT-FORM-03 AJ BILA 

STT-FORM-04 Al Larrus 

STT-FORM-05 Alex Seyedi 

STT-FORM-06 Allen Marker 

STT-FORM-07 Alton Tuttle 

STT-FORM-08 Andres Caicedo 

STT-FORM-09 Andrew Dickson 

STT-FORM-10 andrew speights 

STT-FORM-11 Ann Branch 

STT-FORM-12 Anthony Rodriguez 

STT-FORM-13 Bagwell, Wright 

STT-FORM-14 Ben Brookens 

STT-FORM-15 Ben Russell 

STT-FORM-16 benny king 

STT-FORM-17 Beverly Ashley 

STT-FORM-18 bill naps 

STT-FORM-19 BILLY WALTRIP 

STT-FORM-20 Blake Bogner 

STT-FORM-21 Bob Balunda 

STT-FORM-22 bobby naps 

STT-FORM-23 Brad Kerr 

STT-FORM-24 Bradley Nevins 

STT-FORM-25 Brain Svec 

STT-FORM-26 Brenda Hoard 

STT-FORM-27 Brian Faris 

STT-FORM-28 Brian Fraser 

STT-FORM-29 Brian Wright 

STT-FORM-30 Brion McHale 

STT-FORM-31 Bruce Boring 

STT-FORM-32 Bruce Leighton 

STT-FORM-33 Bruce Hendrickson 

STT-FORM-34 Bryan Manternach 

STT-FORM-35 Bryan Parkin 

STT-FORM-36 Carl Anderson 

STT-FORM-37 Casey Crandall 

STT-FORM-38 Chad Delany 

STT-FORM-39 Charles Hirst 

STT-FORM-40 Charles Polan 

STT-FORM-41 charlie williams 

STT-FORM-42 Chris burnett 

STT-FORM-43 chris cameron 

STT-FORM-44 Chris Milligan 

STT-FORM-45 Christina Wilson 

470
 
 

 

Clear Creek Management Area Appendix X 

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STT-FORM-46 Chuck Worley 

STT-FORM-47 Cindy Hursh 

STT-FORM-48 Com Chewy 

STT-FORM-49 craig hodges 

STT-FORM-50 Craig Jelich 

STT-FORM-51 

CTVA Action 

Committee 

STT-FORM-52 Dale Barkhoff 

STT-FORM-53 Dan LaMere 

STT-FORM-54 Dan Thomson 

STT-FORM-55 Daniel Fukai 

STT-FORM-56 

DANIEL JENNIFER 

WINES 

STT-FORM-57 Darryl Sheets 

STT-FORM-58 Dave Pickett 

STT-FORM-59 Dave Seghi 

STT-FORM-60 David Blau 

STT-FORM-61 David Cherniss 

STT-FORM-62 David Fowley 

STT-FORM-63 David Grogan 

STT-FORM-64 David Olaveson 

STT-FORM-65 DAVID OLSON 

STT-FORM-66 David Trevisan 

STT-FORM-67 David Vaassen 

STT-FORM-68 David Wasson 

STT-FORM-69 David Wheeler 

STT-FORM-70 Dean Corbella 

STT-FORM-71 Dean Whiteside 

STT-FORM-72 Denis Van Gundy 

STT-FORM-73 Dennis Engelhardt 

STT-FORM-74 Dennis Scroggins 

STT-FORM-75 Derrick Morris 

STT-FORM-76 Devin Carter 

STT-FORM-77 Dick Coppcok 

STT-FORM-78 Dodd Stange 

STT-FORM-79 Dodd Stange 

STT-FORM-80 Don Barich 

STT-FORM-81 Don Fukushima 

STT-FORM-82 Donald Gerber 

STT-FORM-83 Doug Conner 

STT-FORM-84 Doug Holcomb 

STT-FORM-85 Doug Machado 

STT-FORM-86 Earle Cummings 

STT-FORM-87 Ellen Amador 

STT-FORM-88 Emile Estassi 

STT-FORM-89 Eric Benson 

STT-FORM-90 Eric Buchner 

STT-FORM-91 Eric Komrosky 

STT-FORM-92 Eric Orrill 

STT-FORM-93 Eric Wilson 

STT-FORM-94 Erik Schaffer 

STT-FORM-95 Frank Nye 

STT-FORM-96 Frank Vest 

STT-FORM-97 Garrett Lewis 

STT-FORM-98 Gary Hendricks 

STT-FORM-99 Gary Otremba 

STT-FORM-100 Geoffrey Tobin 

STT-FORM-101 Gerard Shuba 

STT-FORM-102 Gina Johnson 

STT-FORM-103 Gino Fortunato 

STT-FORM-104 Glen Anderson 

STT-FORM-105 Glen Coddington 

STT-FORM-106 Greg Matthews 

STT-FORM-107 Greg McNeil 

STT-FORM-108 Greg Taylor 

STT-FORM-109 Harvey Bye 

STT-FORM-110 Heidi Murphy 

STT-FORM-111 Richard Hoppe 

STT-FORM-112 Howard Jones 

STT-FORM-113 Bart Milam 

STT-FORM-114 J. Braun 

STT-FORM-115 J. Muhlestein 

STT-FORM-116 Jack Davies 

STT-FORM-117 Jack Traver 

STT-FORM-118 Jacqueline Machado 

STT-FORM-119 Jacquelyn Iddings 

STT-FORM-120 Jacquelyne Theisen 

STT-FORM-121 Jake Beckett 

STT-FORM-122 James jackson 

STT-FORM-123 James Miller 

STT-FORM-124 JAMIE DATAN 

STT-FORM-125 Jamison Burchfield 

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STT-FORM-126 Jamison Donato 

STT-FORM-127 Janette Damaso 

STT-FORM-128 Jason Eickhoff 

STT-FORM-129 jason herbig 

STT-FORM-130 Jason Wise 

STT-FORM-131 Jay Peterson 

STT-FORM-132 Jeff Davies 

STT-FORM-133 Jeff Hayes 

STT-FORM-134 jeff johnson 

STT-FORM-135 Jeff Kasper 

STT-FORM-136 Jeff Ossman 

STT-FORM-137 Jeff Radtke 

STT-FORM-138 Jeff White 

STT-FORM-139 Jeffrey Lewis 

STT-FORM-140 Jeffrey Sebern 

STT-FORM-141 jeffrey strutz 

STT-FORM-142 JENNIFER CASO 

STT-FORM-143 Jerry Marsh 

STT-FORM-144 Jerry Sparkman 

STT-FORM-145 jesse ziegler 

STT-FORM-146 Jim Bowsher 

STT-FORM-147 Joe Gomes 

STT-FORM-148 Joe DiSalvo 

STT-FORM-149 joe reisinger 

STT-FORM-150 Joe Workman 

STT-FORM-151 Joel Becher 

STT-FORM-152 John Aiton 

STT-FORM-153 John Alexander 

STT-FORM-154 John Brown 

STT-FORM-155 John Davis 

STT-FORM-156 John Gauldin 

STT-FORM-157 John Maloy 

STT-FORM-158 John Ortiz 

STT-FORM-159 John Martin 

STT-FORM-160 Johnny Cox 

STT-FORM-161 jon berkhemer 

STT-FORM-162 Jon Bui 

STT-FORM-163 Jose Acevedo 

STT-FORM-164 Joseph Nufer 

STT-FORM-165 Joseph Wilkiemeyer 

STT-FORM-166 Josh Davis 

STT-FORM-167 Jason P. Howell 

STT-FORM-168 Justin Kulikov 

STT-FORM-169 Kade Hendrick 

STT-FORM-170 Karen Marsh 

STT-FORM-171 Kay Hadland 

STT-FORM-172 Keith Schreck 

STT-FORM-173 Ken Flores 

STT-FORM-174 Ken Perkins 

STT-FORM-175 Kevin Bak 

STT-FORM-176 Kevin Beller 

STT-FORM-177 kevin Hedrick 

STT-FORM-178 Kevin Liles 

STT-FORM-179 Kirk Demarest 

STT-FORM-180 Kirk Harris 

STT-FORM-181 James Culver 

STT-FORM-182 Les Brekke 

STT-FORM-183 Ladd Johnson 

STT-FORM-184 Larry Beardslee 

STT-FORM-185 Larry Garrido 

STT-FORM-186 laymon bunch 

STT-FORM-187 Leonard Young 

STT-FORM-188 Linda Chen 

STT-FORM-189 Lois Kobayashi 

STT-FORM-190 Lon Hadland 

STT-FORM-191 Lou St.George 

STT-FORM-192 Lowell Webb 

STT-FORM-193 MANUEL DATAN 

STT-FORM-194 Marcia Gibbs 

STT-FORM-195 Mark Benzinger 

STT-FORM-196 Mark Harris 

STT-FORM-197 Mark Hvass 

STT-FORM-198 Mark Meulpolder 

STT-FORM-199 Mark Mulliner 

STT-FORM-200 Mark Olund 

STT-FORM-201 Matt Angier 

STT-FORM-202 matt beck 

STT-FORM-203 Matt Leighton 

STT-FORM-204 Matt Ruiz 

STT-FORM-205 Matthew Ruiz 

STT-FORM-206 Michael Damaso 

STT-FORM-207 Michael Garrett 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

STT-FORM-208 Michael Lompart 

STT-FORM-209 Michael Scott 

STT-FORM-210 Michael Scruggs 

STT-FORM-211 michael Shuck 

STT-FORM-212 Michael Studzinski 

STT-FORM-213 Miguel Flores 

STT-FORM-214 Mike Adams 

STT-FORM-215 Mike Bohnhoff 

STT-FORM-216 Mike Chaplin 

STT-FORM-217 MIke colsell 

STT-FORM-218 mike locke 

STT-FORM-219 mike naps 

STT-FORM-220 mike orr 

STT-FORM-221 mike rustay 

STT-FORM-222 Mike Wubbels 

STT-FORM-223 mountain miller 

STT-FORM-224 Nate DeLaney 

STT-FORM-225 Nick Johnson 

STT-FORM-226 Greg Burns 

STT-FORM-227 Oscar Wahlberg 

STT-FORM-228 Patrick McCaleb 

STT-FORM-229 PAUL BUCHKOVICH 

STT-FORM-230 Paul Hawthorne 

STT-FORM-231 Paul Henry 

STT-FORM-232 Paul Kobayashi 

STT-FORM-233 Paul Ward 

STT-FORM-234 Paul White 

STT-FORM-235 William G. Ward 

STT-FORM-236 pete hunter 

STT-FORM-237 Pete Tanzillo 

STT-FORM-238 Peter Cassidy 

STT-FORM-239 Peter Sakai 

STT-FORM-240 Peter, Keith E 

STT-FORM-241 Philip Wunderle 

STT-FORM-242 R Bruce Leighton 

STT-FORM-243 Randy Norton 

STT-FORM-244 Randy Frint 

STT-FORM-245 Ray Iddings 

STT-FORM-246 Raymond Kirchner 

STT-FORM-247 Rebekah Hermann 

STT-FORM-248 Regentine, Russell 

STT-FORM-249 Renae Virden 

STT-FORM-250 Rhonda Mumm 

STT-FORM-251 Richard Adan 

STT-FORM-252 Richard D. Pankey 

STT-FORM-253 Richard Dent 

STT-FORM-254 Richard Eidsmoe 

STT-FORM-255 Richard Marlin 

STT-FORM-256 Rick Guidice 

STT-FORM-257 Robert Adams 

STT-FORM-258 Robert Burson 

STT-FORM-259 Robert Castelhano 

STT-FORM-260 Robert Condra 

STT-FORM-261 Robert H Leighton II 

STT-FORM-262 Robert Howard 

STT-FORM-263 Robert Pushwa 

STT-FORM-264 robert smith 

STT-FORM-265 Roger Pennington 

STT-FORM-266 Ronald MAITREJEAN 

STT-FORM-267 Ronald Wilcher 

STT-FORM-268 Rory Dow 

STT-FORM-269 Ryan Raymond 

STT-FORM-270 Amy Delaney 

STT-FORM-271 Scott Johnston 

STT-FORM-272 scott sinclair 

STT-FORM-273 Sean Greer 

STT-FORM-274 Shawn Baker 

STT-FORM-275 shawn harvey 

STT-FORM-276 Sherri Broome 

STT-FORM-277 skip zierolf 

STT-FORM-278 Stacie Albright 

STT-FORM-279 Stephen Dix 

STT-FORM-280 Stephen Smith 

STT-FORM-281 Stephens,Mike 

STT-FORM-282 Steve Boardman 

STT-FORM-283 Steve Christensen 

STT-FORM-284 Steve Egbert 

STT-FORM-285 Steve Farinelli 

STT-FORM-286 Steve Wright 

STT-FORM-287 Steven Esau 

STT-FORM-288 Terry Nimmo 

STT-FORM-289 Thomas Bank 

473
 
 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

STT-FORM-290 Thomas Amador 

STT-FORM-291 Thomas Ketter 

STT-FORM-292 Thomas Neu 

STT-FORM-293 Thurman Creel Jr 

STT-FORM-294 Tim Clark 

STT-FORM-295 Tim McDowell 

STT-FORM-296 Tim Richards 

STT-FORM-297 tom keith 

STT-FORM-298 tom taflin 

STT-FORM-299 Tomi Johnson 

STT-FORM-300 Tony McCants 

STT-FORM-301 Travis Franz 

STT-FORM-302 Travis Patzkowsky 

STT-FORM-303 Jon & Tammie Wilcox 

STT-FORM-304 Troy Weis 

STT-FORM-305 URIEL COLLETT 

STT-FORM-306 Vince LaROcca 

STT-FORM-307 Wade Wilson 

STT-FORM-308 Walter Koch 

STT-FORM-309 Warren Krause 

STT-FORM-310 Wesley Paik 

STT-FORM-311 William Auth 

STT-FORM-312 William Burwell 

STT-FORM-313 william charles 

STT-FORM-314 William Hoard 

STT-FORM-315 william jensen sr 

STT-FORM-316 William Lyttle 

STT-FORM-317 william meilandt 

STT-FORM-318 William Willis 

STT-FORM-319 Wojtek Dolski 

STT-FORM-320 Zaya Taylor 

474
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Blue Ribbon Coalition Form Letter 

Comment 

Code Commenter 

BRCFORM-01 14mikemc@sbcglobal.net 

BRCFORM-02 1casey1@sbcglobal.net 

BRCFORM-03 1tom@earthlink.net 

BRCFORM-04 200mphtape@cox.net 

BRCFORM-05 2bbishop@sbcglobal.net 

BRCFORM-06 4bigfoot@sbcglobal.net 

BRCFORM-07 4myreview@pacbell.net 

BRCFORM-08 7hv@att.net 

BRCFORM-09 a.ballard@live.com 

BRCFORM-10 a94cobra@gmail.com 

BRCFORM-11 aaarrstamps@aol.com 

BRCFORM-12 aaron_morris21@yahoo.com 

BRCFORM-13 abressoud80@yahoo.com 

BRC­ abstractstorage@frontiernet. 

FORM-14 net 

BRC­ acasyam@hotmail.com 

FORM-15 

BRCFORM-16 accurate5060@sbcglobal.net 

BRCFORM-17 ace2002@gmail.com 

BRCFORM-18 aceguybiggs@Gmail.com 

BRCFORM-19 acerbis24@gmail.com 

BRCFORM-20 acjjkamp@yahoo.com 

BRCFORM-21 acwmachinery@yahoo.com 

BRCFORM-22 adam.ayala@intel.com 

BRCFORM-23 adam@realtyexecsnw.com 

BRCFORM-24 adamsauto@gocalnet.com 

BRCFORM-25 adeocampo@gmail.com 

BRCFORM-26 agilman@signalactive.com 

BRCFORM-27 agreen@evalveinc.com 

BRCFORM-28 ajrodriguez01@hotmail.com 

BRCFORM-29 AJZ3@pge.com 

BRCFORM-30 al.porter@pklservices.com 

BRCFORM-31 alain.valois@gmail.com 

BRCFORM-32 alan@bajadesigns.com 

BRC­ alan@crissmancommercial.c 

FORM-33 om 

BRCFORM-34 alan@viader.com 

BRCFORM-35 awagner@exponent.com 

BRCFORM-36 alexwis@gmail.com 

BRCFORM-37 alltrade59@yahoo.com 

BRCFORM-38 Alphq2026@aol.com 

BRC­ alton.stevens@HOTMAIL.C 

FORM-39 OM 

BRCFORM-40 altonfox@sbcglobal.net 

BRCFORM-41 altroute1-lists@yahoo.com 

BRCFORM-42 ambergreen33@yahoo.com 

BRCFORM-43 ambluemax@comcast.net 

BRCFORM-44 amcrofts@aol.com 

BRCFORM-45 ameriweld@hotmail.com 

BRCFORM-46 amsegura@gmail.com 

BRCFORM-47 andre2254@sbcglobal.net 

BRC­ Andres@caicedo.net 

475
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

FORM-48 

BRCFORM-49 andrew.ross.mt@gmail.com 

BRC­ ANDREWCSLAIRD@GM 

FORM-50 AIL.COM 

BRCFORM-51 andymoto@pacbell.net 

BRCFORM-52 AnEv942@aol.com 

BRCFORM-53 angryshawn@gmail.com 

BRC­ anthony.dambrosio@microse 

FORM-54 mi.com 

BRC­ anthony@lifetime.oregonstat 

FORM-55 e.edu 

BRCFORM-56 anthony_86_@hotmail.com 

BRCFORM-57 antique.triumph@gmail.com 

BRCFORM-58 aplan2win@msn.com 

BRCFORM-59 aprilrael@yahoo.com 

BRCFORM-60 aragu36@sbcglobal.net 

BRCFORM-61 archer80@comcast.net 

BRCFORM-62 arcticrep1@msn.com 

BRCFORM-63 arnel@schuil.com 

BRCFORM-64 aronnau@p-a-c-e.com 

BRCFORM-65 ascpaul@att.net 

BRCFORM-66 ashleyornsby@hotmail.com 

BRC­ atempleton@smaFORM-67 america.com 

BRCFORM-68 atkinspw@yahoo.com 

BRC­ atomlinson@4wheelparts.co 

FORM-69 m 

BRCFORM-70 Atomtarah@gmail.com 

BRCFORM-71 ausderau@sonic.net 

BRCFORM-72 autowizz@gmail.com 

BRC­ AVEGGIO@SBCGLOBAL. 

FORM-73 NET 

BRCFORM-74 Averian@hotmail.com 

BRCFORM-75 avery.clifton@dishmail.net 

BRC­ AWareham1983@comcast.n 

FORM-76 et 

BRCFORM-77 awhagen@digitalpath.net 

BRCFORM-78 azmandzuk@cox.net 

BRCFORM-79 b.belknap@sbcglobal.net 

BRCFORM-80 b_philipp@msn.com 

BRC­ bagman1@insightbb.com 

FORM-81 

BRCFORM-82 bagwell79@yahoo.com 

BRCFORM-83 BAILEESPOP@yahoo.com 

BRCFORM-84 bajadog@sbcglobal.net 

BRCFORM-85 Bakto56@aol.com 

BRCFORM-86 ballmer@cox.net 

BRCFORM-87 balooppy@yahoo.com 

BRCFORM-88 barbdave1@cox.net 

BRC­ barryhansen@utilityFORM-89 trailer.com 

BRCFORM-90 barrymegan@gmail.com 

BRCFORM-91 Bartow@cox.net 

BRCFORM-92 battman55@ca.rr.com 

BRCFORM-93 bbailey74@aol.com 

BRCFORM-94 bbusloff@gmail.com 

BRCFORM-95 bcd11122@aol.com 

BRCFORM-96 bdavis@dynojet.com 

BRCFORM-97 bdb11111950@hotmail.com 

476
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

BRCFORM-98 bdeere4000@aol.com 

BRCFORM-99 bell352x@yahoo.com 

BRCFORM100 ben.renfrow@zurichna.com 

BRCFORM101 ben@man-a-fre.com 

BRCFORM102 bendblues@comcast.net 

BRCFORM103 benjhamina@gmail.com 

BRCFORM104 benjohnson@sbcglobal.net 

BRCFORM105 bennettgma@yahoo.com 

BRCFORM106 bennjencain@gmail.com 

BRCFORM107 bergertileworks@yahoo.com 

BRCFORM108 bermboy@yahoo.com 

BRCFORM­ bernathsg@gmail.com 

109 

BRCFORM110 berrydogs@msn.com 

BRCFORM111 betsy@fenderscollision.com 

BRCFORM112 beumeler@pacbell.net 

BRCFORM113 bevans37095@yahoo.com 

BRCFORM114 bfcasey17@comcast.net 

BRCFORM115 bgscott4422@yahoo.com 

BRCFORM116 bhenning@dot.state.nv.us 

BRCFORM117 bholzapfel@gmail.com 

BRCFORM118 bigb980@hotmail.com 

BRCFORM­ bigblock68chevelle@yahoo. 

119 com 

BRCFORM­ bike_pilot@msn.com 

120 

BRCFORM- bill.nancy.delacroix@gmail. 

121 com 

BRCFORM122 bill@piping.cc 

BRCFORM123 bill_boyer@ahm.honda.com 

BRCFORM124 billandkristin@sbcglobal.net 

BRCFORM125 billlesc@aol.com 

BRCFORM126 bills@slakkerracing.com 

BRCFORM127 billybob101@sbcglobal.net 

BRCFORM128 billybobesq@yahoo.com 

BRCFORM129 Bipk@yahoo.com 

BRCFORM130 Bird76Mojo@Yahoo.com 

BRCFORM­ bito@stanford.edu 

477
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

131 

BRCFORM132 Bitterboatboy@yahoo.com 

BRCFORM133 bjeeper@charter.net 

BRCFORM134 bk1096@cebridge.net 

BRCFORM135 bkaufman625@yahoo.com 

BRCFORM136 bkelchner1957@yahoo.com 

BRCFORM137 bkkohler@inreach.com 

BRCFORM138 bkmertz@gmail.com 

BRCFORM­ blainewimsatt@sbcglobal.ne 

139 t 

BRCFORM140 bleitzell@yahoo.com 

BRCFORM141 blissn777@msn.com 

BRCFORM­ blm@mytirade.com 

142 

BRCFORM143 blowmudd@hotmail.com 

BRCFORM144 bmajor234@sbcglobal.net 

BRCFORM145 bmechanic@hotmail.com 

BRCFORM146 bmisq@hotmail.com 

BRCFORM147 bmrice@sbcglobal.net 

BRCFORM148 bmw_dave@hotmail.com 

BRCFORM149 bncjsc@gulftel.com 

BRCFORM150 bnord15@gmail.com 

BRCFORM151 bob_basen@yahoo.com 

BRCFORM152 bob_e95482@yahoo.com 

BRCFORM­ bobc1@live.com 

153 

BRCFORM154 bobcat54s@cox.net 

BRCFORM155 bobL2@comcast.net 

BRCFORM156 bobn@lacrystal.com 

BRCFORM157 bobproaction@verizon.net 

BRCFORM158 boosh@cox.net 

BRCFORM159 bowerben@aol.com 

BRCFORM160 box123@fracstar.com 

BRCFORM161 bpallies@yahoo.com 

BRCFORM162 bperry3434@yahoo.com 

BRCFORM163 brad@renthal.com 

BRCFORM­ bradster@gmail.com 

478
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

164 

BRCFORM165 brandt.jason@sbcglobal.net 

BRCFORM166 breeziefbaybee@gmail.com 

BRCFORM167 brent@icespeedway.com 

BRCFORM­ brett T 

168 <bretttomas@aol.com> 

BRCFORM169 brian@chuckleheads.me 

BRCFORM170 brian@edwardsoregon.com 

BRCFORM171 briankash@cox.net 

BRCFORM172 briansb@charter.net 

BRCFORM173 brianwicked@yahoo.com 

BRCFORM174 brichter@pacbell.net 

BRCFORM­ brittleis@hotmail.com 

175 

BRCFORM176 brodave6@yahoo.com 

BRCFORM177 brokenoaknut@yahoo.com 

BRCFORM178 broncobliss@comcast.net 

BRCFORM179 bronkzilla@gmail.com 

BRCFORM­ brooktpeterson@hotmail.co 

180 m 

BRCFORM181 brookwade@gmail.com 

BRCFORM182 browland2@cox.net 

BRCFORM183 brownbearinc@sbcglobal.net 

BRCFORM184 bruce.constant@united.com 

BRCFORM185 bruce.saxton@sbcglobal.net 

BRCFORM­ Bruce35@pacbell.net 

186 

BRCFORM187 bruceh@mail.com 

BRCFORM188 brucekb1955@msn.com 

BRCFORM189 bruno.junnila@sbcglobal.net 

BRCFORM­ bryananddawn@bellsouth.ne 

190 t 

BRCFORM191 bryanlarson@gmail.com 

BRCFORM192 bryanth4@hotmail.com 

BRCFORM193 bsvec01@yahoo.com 

BRCFORM194 btschmidt@harbornet.com 

BRCFORM195 budinsac@hotmail.com 

BRCFORM196 burlybear@comcast.net 

BRCFORM­ burnrider1@yahoo.com 

479
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

197 

BRCFORM198 bweber@troyleedesigns.com 

BRCFORM199 byataco@aol.com 

BRCFORM200 c1m3@pge.com 

BRCFORM201 ca.58@hotmail.com 

BRCFORM202 cacruiserfj60@live.com 

BRCFORM203 cactus73@live.com 

BRCFORM204 cakejob@hotmail.com 

BRCFORM­ caledonia4wheelers@gmail.c 

205 om 

BRCFORM­ CALEGEND2@COMCAST 

206 .NET 

BRCFORM207 calicam_71@hotmail.com 

BRCFORM­ cameron@kemptoninc.com 

208 

BRCFORM209 cameronjacobs@gmail.com 

BRCFORM210 candcmiller@verizon.net 

BRCFORM211 cardoninc@comcast.net 

BRCFORM212 carljbryan@yahoo.com 

BRCFORM­ carlos_hernandez@yahoo.co 

213 m 

BRCFORM214 carlosfuchen@gmail.com 

BRCFORM­ CARTS4FUN@YAHOO.C 

215 OM 

BRCFORM216 cary.sklar@bydeluxe.com 

BRCFORM­ caseyrobbins@umail.ucsb.ed 

217 u 

BRCFORM218 cassidys1365@sbcglobal.net 

BRCFORM­ casweld@gmail.com 

219 

BRCFORM220 catfish542@comcast.net 

BRCFORM221 cbienusa@yahoo.com 

BRCFORM222 cbreakin@yahoo.com 

BRCFORM223 cbrown@xo.com 

BRCFORM224 cbruening@comcast.net 

BRCFORM225 ccoiner@comcast.net 

BRCFORM226 cd_drew@hotmail.com 

BRCFORM227 cdcamara@ca.rr.com 

BRCFORM228 cdgvw1@gmail.com 

BRCFORM229 CDWahh@aol.com 

BRCFORM­ cegsteve@socal.rr.com 

480
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

230 

BRCFORM231 cehl@pge.com 

BRCFORM232 cessna1@directv.net 

BRCFORM233 cfreschi@sbcglobal.net 

BRCFORM­ cgilbert@resortatredhawk.co 

234 m 

BRCFORM235 chad@surewest.net 

BRCFORM236 chadaway2@sbcglobal.net 

BRCFORM237 champines@centurytel.net 

BRCFORM238 championpsr@yahoo.com 

BRCFORM239 chargeng@carolina.rr.com 

BRCFORM­ Charles.Mahoney@verizon.n 

240 et 

BRCFORM­ Charles.Smith@aerojet.com 

241 

BRCFORM242 chartmetz@sbcglobal.net 

BRCFORM243 chasejcrew@comcast.net 

BRCFORM244 chayne333@yahoo.com 

BRCFORM­ chessrockwell11@yahoo.co 

245 m 

BRCFORM246 chglanz@comcast.net 

BRCFORM247 chicostanley@yahoo.com 

BRCFORM248 chilton771@cox.net 

BRCFORM249 chofch96@yahoo.com 

BRCFORM250 chris.l.david@gmail.com 

BRCFORM251 chris@bajadesigns.com 

BRCFORM­ chris@pcdc.us 

252 

BRCFORM253 chris@pivotcycles.com 

BRCFORM254 Chris@Slapdrum.com 

BRCFORM255 chris_briggi@yahoo.com 

BRCFORM256 chris_m_martin@yahoo.com 

BRCFORM­ chrisimmer@islandchapel.ne 

257 t 

BRCFORM258 chrissgage@gmail.com 

BRCFORM259 christheis@yahoo.com 

BRCFORM­ christina.marsden@yahoo.co 

260 m 

BRCFORM261 chstem@astound.net 

BRCFORM262 chuck.willhite@gmail.com 

BRCFORM­ chuck_below@sbcglobal.net 

481
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

263 

BRCFORM264 chuckesty@yahoo.com 

BRCFORM265 cjcrs@sbcglobal.net 

BRCFORM266 cjenterprisesinc@gmail.com 

BRCFORM267 cjost72@hotmail.com 

BRCFORM­ cjrademacher1@hotmail.co 

268 m 

BRCFORM269 cjzc@yahoo.com 

BRCFORM270 ckkindig@hotmail.com 

BRCFORM271 ckpcraig@sbcglobal.net 

BRCFORM272 ckumata@aol.com 

BRCFORM273 clarkdodd@gmail.com 

BRCFORM­ clarkr@wildblue.net 

274 

BRCFORM275 clarrew@yahoo.com 

BRCFORM­ cleverconstruction@comcast 

276 .net 

BRCFORM277 cli4523730@aol.com 

BRCFORM278 cmangus@nycap.rr.com 

BRCFORM279 cmeadeagle@yahoo.com 

BRCFORM280 cmorr31@sbcglobal.net 

BRCFORM281 co4x4family@msn.com 

BRCFORM282 codyboy33@yahoo.com 

BRCFORM283 colomtnmike@yahoo.com 

BRCFORM284 comprep@earthlink.net 

BRCFORM­ conradksmith@gmail.com 

285 

BRCFORM286 cop704@yahoo.com 

BRCFORM287 copequad@yahoo.com 

BRCFORM288 corby511@yahoo.com 

BRCFORM289 corey.kapahee@gcinc.com 

BRCFORM290 coryradov@gmail.com 

BRCFORM­ cowboy444_2000@yahoo.co 

291 m 

BRCFORM292 cowperthwaite@gmail.com 

BRCFORM293 coyote4u2be@yahoo.com 

BRCFORM294 cp9800@aol.com 

BRCFORM295 cpcork1@gmail.com 

BRCFORM­ cpoling@sierracollege.edu 

482
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

296 

BRCFORM297 craigcorwin@comcast.net 

BRCFORM298 craigj4vwelding@aol.com 

BRCFORM299 craigs380@hotmail.com 

BRCFORM300 craigw@told.com 

BRCFORM301 crashhash@embarqmail.com 

BRCFORM302 crashking1@gmail.com 

BRCFORM303 crashmsn@hotmail.com 

BRCFORM­ crazymoose1990@yahoo.co 

304 m 

BRCFORM305 crazysuzy2003@gmail.com 

BRCFORM306 crfxerik@gmail.com 

BRCFORM­ crissgjunk@cox.net 

307 

BRCFORM308 critesx4@yahoo.com 

BRCFORM309 crooks420@aol.com 

BRCFORM310 crpepmeier@hotmail.com 

BRCFORM311 cruiserfj45@hotmail.com 

BRCFORM312 crustyfrog88869@aol.com 

BRCFORM313 crwellsy@msn.com 

BRCFORM­ csilverberg@fiorebellainc.co 

314 m 

BRCFORM315 csmgj7@GMail.Com 

BRCFORM316 csmonty60@yahoo.com 

BRCFORM317 csprecher@earthlink.net 

BRCFORM­ cstatman@yahoo.com 

318 

BRCFORM319 ctensor@hotmail.com 

BRCFORM320 culdrby@aol.com 

BRCFORM321 curran@pacbell.net 

BRCFORM322 curtlewis1@hotmail.com 

BRCFORM323 cweaver7018@yahoo.com 

BRCFORM­ cwjacksonelectric@surewest 

324 .net 

BRCFORM325 cyclepro775@yahoo.com 

BRCFORM326 cyclepunk@gmail.com 

BRCFORM327 dadandsean06@yahoo.com 

BRCFORM328 dadcrno@hotmail.com 

BRCFORM­ dadiodo@comcast.net 

483
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

329 

BRCFORM­ dan.douglas@logan330 aluminum.com 

BRCFORM­ dan__dowding@hotmail.co 

331 m 

BRCFORM332 danes@cathedralcity.gov 

BRCFORM333 danheck7@hotmail.com 

BRCFORM334 danielfj@videotron.ca 

BRCFORM335 danjenn311@msn.com 

BRCFORM336 danmem@ymail.com 

BRCFORM­ DANNY.WHITE@WATER 

337 MANUSA.COM 

BRCFORM338 danny@studioworksllc.com 

BRCFORM339 danpineau@hotmail.com 

BRCFORM­ dard1324@yahoo.com 

340 

BRCFORM341 darexbone@yahoo.com 

BRCFORM- darryl@cyclopsmotorsports. 

342 com 

BRCFORM343 daugino@eduhsd.k12.ca.us 

BRCFORM344 dave@doudna.com 

BRCFORM345 dave@grundman.net 

BRCFORM346 dave3608@cox.net 

BRCFORM­ davesway1@embarqmail.co 

347 m 

BRCFORM348 davevossler@w-and-k.com 

BRCFORM349 davew99@sbcglobal.net 

BRCFORM350 david.milazzo@abbott.com 

BRCFORM­ david.reynar@gmail.com 

351 

BRCFORM352 david.smith2@ngc.com 

BRCFORM­ david@groundfloorlandscapi 

353 ng.com 

BRCFORM354 david84gill@yahoo.com 

BRCFORM355 david8786@sbcglobal.net 

BRCFORM356 davidaxeljones@yahoo.com 

BRCFORM357 davidensworth@gmail.com 

BRCFORM358 davidf@jps.net 

BRCFORM­ davidg@vanscabinetshop.co 

359 m 

BRCFORM360 DavidKnall@hotmail.com 

BRCFORM361 davidL9999@earthlink.net 

BRCFORM­ davidruiz1980@yahoo.com 

484
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

362 

BRCFORM363 davlyk@yahoo.com 

BRCFORM364 daybreak1116@att.net 

BRCFORM365 dayjeremy@gmail.com 

BRCFORM366 dazevedo@calpoly.edu 

BRCFORM367 dbaker@pro-tec.us 

BRCFORM­ dbarkhoff@scbuildersinc.co 

368 m 

BRCFORM369 dbcoooper1@yahoo.com 

BRCFORM370 dbender@chicousd.org 

BRCFORM­ dbwmarketing@dbwmetals.c 

371 om 

BRCFORM372 dc132@yahoo.com 

BRCFORM­ dclagg@socal.rr.com 

373 

BRCFORM374 dcullum1@comcast.net 

BRCFORM375 ddhstr@hotmail.com 

BRCFORM376 dean@techspec-usa.com 

BRCFORM377 deanne@bajadesigns.com 

BRCFORM­ deathvalleylizard@yahoo.co 

378 m 

BRCFORM379 debbie94551@sbcglobal.net 

BRCFORM380 debbieclark@prodigy.net 

BRCFORM381 debbiem@fracstar.com 

BRCFORM382 debbin68@comcast.net 

BRCFORM383 debbyrebel@aol.com 

BRCFORM­ dedwards@nbfd.net 

384 

BRCFORM385 degbert@gmail.com 

BRCFORM386 delarocha15@hotmail.com 

BRCFORM387 deltron@swbell.net 

BRCFORM388 demartin@softcom.net 

BRCFORM­ dennis.murphy@bustools.co 

389 m 

BRCFORM­ dennis_workman@trimble.c 

390 om 

BRCFORM­ derekd@seymourduncan.co 

391 m 

BRCFORM392 derwud2@yahoo.com 

BRCFORM­ desertoffroad2001@sbcgloba 

393 l.net 

BRCFORM394 desertracer12@hotmail.com 

BRC­ designsbycharles@worldnet. 

FORM- att.net 

485
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

395 

BRCFORM396 desmodetroit@comcast.net 

BRCFORM397 dettlinger@yahoo.com 

BRCFORM­ devious_101466@yahoo.co 

398 m 

BRCFORM399 dezrik@yahoo.com 

BRCFORM400 dghaynes@msn.com 

BRCFORM401 dhallada@hra.com 

BRCFORM­ dieseldoug1946@hotmail.co 

402 m 

BRCFORM403 dieselrammandude@aol.com 

BRCFORM404 digbyn@yahoo.com 

BRCFORM405 dillon.gorman@yahoo.com 

BRCFORM­ dirk.delaney@gmail.com 

406 

BRCFORM407 dirtbikinmotox@comcast.net 

BRCFORM408 dirtnut67@yahoo.com 

BRCFORM409 dirtrider572@gmail.com 

BRCFORM410 dirtywally@aol.com 

BRCFORM411 djaaronhawkins@yahoo.com 

BRCFORM412 djk11@cox.net 

BRCFORM413 djohnson@coronado.ca.us 

BRCFORM414 djohnson@fncinc.com 

BRCFORM­ djohnson@jackjamestow.co 

415 m 

BRCFORM- djones@microcellularsystem 

416 s.com 

BRCFORM­ djstubbs60@sbcglobal.net 

417 

BRCFORM­ dkelsey@goochandhousego. 

418 com 

BRCFORM419 dkf13@earthlink.net 

BRCFORM420 dl_williams@charter.net 

BRCFORM421 dmacrigs@gmail.com 

BRCFORM422 dmboardman@cebridge.net 

BRCFORM423 dmcmichen1@hotmail.com 

BRCFORM424 dmdxn4@sbcglobal.net 

BRCFORM425 dmptl@comcast.net 

BRCFORM426 dmunn1@comcast.net 

BRCFORM427 dnoorda@hotmail.com 

BRCFORM­ docfam@mac.com 

486
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

428 

BRCFORM429 don@abctrans.com 

BRCFORM­ don_simonenv@sbcglobal.n 

430 et 

BRCFORM431 Dondyoo@hotmail.com 

BRCFORM432 donh@plumtree.com 

BRCFORM433 DonLeaHW@aol.com 

BRCFORM434 donniedevries@hotmail.com 

BRCFORM435 donniewilhelm@msn.com 

BRCFORM436 Donovanneb@yahoo.com 

BRCFORM437 dontlindsey@gmail.com 

BRCFORM438 doug@hheng.com 

BRCFORM­ Doug760@gmail.com 

439 

BRCFORM440 dougbarth@sbcglobal.net 

BRCFORM441 dougiebehr@sbcglobal.net 

BRCFORM­ dougp@homeloanslending.c 

442 om 

BRCFORM443 dozergpw@yahoo.com 

BRCFORM444 dpihl@sbcglobal.net 

BRCFORM445 dpkiley@yahoo.com 

BRCFORM446 dpmurphy1@sbcglobal.net 

BRCFORM447 dpsul@comcast.net 

BRCFORM448 drammell@rammellcpa.com 

BRCFORM­ dreed@comstockmortgage.c 

449 om 

BRCFORM­ drfreddds@aol.com 

450 

BRCFORM451 drsalfen@sbcglobal.net 

BRCFORM452 drtracr2@yahoo.com 

BRCFORM453 druzmotomom1@yahoo.com 

BRCFORM454 drwly@yahoo.com 

BRCFORM­ dsergent@naturipefarms.co 

455 m 

BRCFORM456 dsmcgill2000@yahoo.com 

BRCFORM457 dsrlee@sbcglobal.net 

BRCFORM458 dstapp@papemachinery.com 

BRCFORM459 dstucker2@cox.net 

BRCFORM460 dszabados@hotmail.com 

BRCFORM­ dtconstantdds@aol.com 

487
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

461 

BRCFORM462 dtrider2@astound.net 

BRCFORM463 Dttbrown2@yahoo.com 

BRCFORM464 dualies@yahoo.com 

BRCFORM­ ducati0601@mindspring.co 

465 m 

BRCFORM466 ducatimarc11@gmail.com 

BRCFORM467 dukeduarte@comcast.net 

BRCFORM468 dukelambert@gmail.com 

BRCFORM469 dumbguy1234@yahoo.com 

BRCFORM470 dunelvr@gmail.com 

BRCFORM471 duners99@hotmail.com 

BRCFORM­ dunn1833@hotmail.com 

472 

BRCFORM­ dusty4x4ham473 bs@yahoo.com 

BRCFORM­ DVHREDRIDERCR500@H 

474 OTMAIL.COM 

BRCFORM475 dwcwiak@yahoo.com 

BRCFORM­ dws@dances-with476 snakes.com 

BRCFORM477 dylan288x@gmail.com 

BRCFORM478 e1093@hotmail.com 

BRCFORM479 eallred1@yahoo.com 

BRCFORM480 eatpasta133@aol.com 

BRCFORM481 ebutner@yahoo.com 

BRCFORM482 ecaii@aol.com 

BRC­ echenoweth@sanbrunocable. 

FORM­ com 

483 

BRCFORM484 ecjennings@sbcglobal.net 

BRCFORM485 eckermanjk@wavecable.com 

BRCFORM486 eclipse007@att.net 

BRCFORM487 Ed Linn Jr. <erlj@msn.com> 

BRCFORM488 edwin182@msn.com 

BRCFORM489 egrider1@sbcglobal.net 

BRCFORM490 egsgrode@sbcglobal.net 

BRCFORM491 ehodel@sbcglobal.net 

BRCFORM492 ehrmc72@sbcglobal.net 

BRCFORM493 ejbeckgt@comcast.net 

BRC­ elainebutterworth@hotmail.c 

FORM- om 

488
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

494 

BRCFORM495 eliascox1@gmail.com 

BRCFORM496 emailjdixon@aol.com 

BRCFORM­ emoryandfranci@sbcglobal. 

497 net 

BRCFORM498 endurojamie@gmail.com 

BRCFORM499 endurotrash@yahoo.com 

BRCFORM500 enginejake@hotmail.com 

BRCFORM501 eniven@mlml.calstate.edu 

BRCFORM502 Ensworth@comcast.net 

BRCFORM503 enystrom@cox.net 

BRCFORM504 eraffo@comcast.net 

BRCFORM­ eric.holthe@gmail.com 

505 

BRCFORM506 eric@worksconnection.com 

BRCFORM507 ericlarsen1@comcast.net 

BRCFORM508 erikf555@yahoo.com 

BRCFORM509 erikvb@gmail.com 

BRCFORM510 ermadlinn@msn.com 

BRCFORM511 ersartori@gmail.com 

BRCFORM512 ErynGray@hotmail.com 

BRCFORM513 Ethanfnp@comcast.net 

BRCFORM514 eweisler@ci.milpitas.ca.gov 

BRCFORM515 expertmarine@msn.com 

BRC­ eyvandnewcon@hotmail.co 

FORM- m 

516 

BRCFORM517 f16@iname.com 

BRCFORM518 f83tom1@sbcglobal.net 

BRCFORM519 fasano1000@aol.com 

BRCFORM520 fasteddieyj@yahoo.com 

BRCFORM521 fasterthanyou@earthlink.net 

BRCFORM522 fastfri@sbcglobal.net 

BRCFORM523 fatirerider@yahoo.com 

BRCFORM524 favserviceman@yahoo.com 

BRCFORM525 fbenz@pacbell.net 

BRCFORM526 fcc@sbcglobal.net 

BRCFORM­ fenech.adam@gmail.com 

489
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

527 

BRCFORM­ feralcomprehension@yahoo. 

528 com 

BRCFORM529 fifty6s@nicksilvaracing.com 

BRCFORM530 finishhand@dslextreme.com 

BRCFORM531 firedave62@yahoo.com 

BRCFORM532 firematt@sti.net 

BRCFORM533 firemike73mt@yahoo.com 

BRCFORM534 firerider182@aol.com 

BRCFORM535 fisher1648@hotmail.com 

BRCFORM536 fiyrman@hotmail.com 

BRCFORM537 florez426@yahoo.com 

BRCFORM­ fmeszaros@hotmail.com 

538 

BRCFORM539 fnyback@bbmetals.com 

BRCFORM540 fodofire@hotmail.com 

BRCFORM541 forbergler@aol.com 

BRCFORM542 fordnut@comcast.net 

BRCFORM543 fordwillman@yahoo.com 

BRCFORM544 fordy92284@yahoo.com 

BRCFORM545 fourallfun@hotmail.com 

BRCFORM546 fractalmotion@gmail.com 

BRCFORM547 frank@store-fixtures.com 

BRCFORM548 fred@cccpumping.com 

BRC­ Fredv9999@Rocketmail.co 

FORM- m 

549 

BRCFORM550 friedab@comcast.net 

BRCFORM551 frodady20@yahoo.com 

BRCFORM552 fxweaver@yahoo.com 

BRCFORM553 fz1junkie@gmail.com 

BRCFORM554 g.grace3@juno.com 

BRCFORM555 g41574@msn.com 

BRCFORM556 galaxie5k@aol.com 

BRCFORM557 gardner2853@yahoo.com 

BRCFORM­ garner@highlandcommercial 

558 .com 

BRCFORM559 Garret.tanner@yahoo.com 

BRCFORM­ garyarnold39@yahoo.com 

490
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

560 

BRCFORM561 garygerda@cox.net 

BRCFORM562 garyhooveris@yahoo.com 

BRCFORM563 garyinvis@aol.com 

BRCFORM­ garysswcycles@sbcglobal.ne 

564 t 

BRCFORM565 gassingerhard@surfnetc.com 

BRCFORM566 gboswell@simivalley.org 

BRCFORM567 gdadudley@verizon.net 

BRCFORM­ gdunnconstruction@yahoo.c 

568 om 

BRCFORM­ geckographics.clf@gmail.co 

569 m 

BRCFORM570 geharmon@pacbell.net 

BRCFORM­ george@fmfracing.com 

571 

BRCFORM572 georgedittle@yahoo.com 

BRCFORM­ gerald_lattimer@hotmail.co 

573 m 

BRCFORM574 gerbrony@hotmail.com 

BRCFORM575 gescober@yahoo.com 

BRCFORM576 gfasanaro@calcomfort.com 

BRCFORM577 gfox777@comcast.net 

BRCFORM578 ggreenlief@aol.com 

BRCFORM579 gibson_ryan69@yahoo.com 

BRCFORM580 giffturborzr@yahoo.com 

BRCFORM581 Giladom@yahoo.com 

BRCFORM­ Glewis4x4@yahoo.com 

582 

BRCFORM583 gmasters1@comcast.net 

BRCFORM584 gmbjabh@comcast.net 

BRCFORM585 gmer.schaefer@gmail.com 

BRCFORM586 gmeyner@trane.com 

BRCFORM587 gmkennard@aol.com 

BRCFORM588 gmoyer281@gmail.com 

BRCFORM589 gmpurdum@comcast.net 

BRCFORM590 gngcycle@comcast.net 

BRCFORM591 gngwillson@verizon.net 

BRCFORM592 goaliegm@msn.com 

BRCFORM- GoldenDaveH@Q.com 

491
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

593 

BRCFORM594 goldeneye@comcast.net 

BRCFORM595 golfisgood4u@yahoo.com 

BRCFORM596 gotssand@yahoo.com 

BRCFORM597 Gplapp@cox.net 

BRCFORM­ grasslandscaping@yahoo.co 

598 m 

BRCFORM599 grassmann1@sbcglobal.net 

BRCFORM­ grebensdorf@orangecountys 

600 cu.org 

BRCFORM601 greenpeck@cs.com 

BRCFORM602 Greentecheg@yahoo.com 

BRCFORM603 greg@ginner.com 

BRCFORM­ greg@TriplettFamily.com 

604 

BRCFORM605 Greg@wirelessworld.com 

BRCFORM606 greg_provencio@yahoo.com 

BRCFORM607 greytoe@earthlink.net 

BRCFORM608 grizzlyfrank@sbcglobal.net 

BRCFORM­ gsasville@paullawrealty.co 

609 m 

BRCFORM610 gttire2@comcast.net 

BRCFORM611 gtwaddle@columbus.rr.com 

BRCFORM612 gunjerrry@aol.com 

BRCFORM613 gus@chyba.net 

BRCFORM614 guzmanbryan26@gmail.com 

BRCFORM­ gwolfeden@gmail.com 

615 

BRCFORM616 gwynne@atis1.com 

BRCFORM617 hagerv@sbcglobal.net 

BRCFORM618 Halfsayne@yahoo.com 

BRCFORM619 Hammerulf@DEjazzd.com 

BRCFORM620 harley4julie@softcom.net 

BRCFORM621 Harleydav91@yahoo.com 

BRCFORM622 have-nice-day@verizon.net 

BRCFORM623 hawkins_52@hotmail.com 

BRCFORM624 hawkmann@hotmail.com 

BRCFORM625 hayes831@yahoo.com 

BRCFORM­ Hayhrst@sbcglobal.net 

492
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

626 

BRCFORM627 Hbmtr@sbcglobal.net 

BRCFORM628 heatherafield@comcast.net 

BRCFORM629 heishi79@gmail.com 

BRCFORM630 herman550@gmail.com 

BRCFORM631 heyjakt@gmail.com 

BRCFORM632 heypugh@hotmail.com 

BRCFORM633 hiattch@sbcglobal.net 

BRCFORM­ highdesertranger@yahoo.co 

634 m 

BRCFORM­ highlandwoodworks@msn.c 

635 om 

BRCFORM636 hksimpson@hotmail.com 

BRC­ hobsonconstruction@hotmail 

FORM­ .com 

637 

BRCFORM638 hocky70@aol.com 

BRCFORM639 hodaka72t@hotmail.com 

BRCFORM640 hogbody@sbcglobal.net 

BRCFORM641 hollenbk61@gmail.com 

BRCFORM642 hollylm76@yahoo.com 

BRCFORM643 hondacbx@comcast.net 

BRCFORM644 hondajimz@yahoo.com 

BRCFORM645 hondamac@comcast.net 

BRCFORM646 hondarider230@gmail.com 

BRCFORM647 hopkinsp@sbcglobal.net 

BRCFORM­ hornet10@comcast.net 

648 

BRCFORM649 horsebabs@wildblue.net 

BRCFORM650 hp_simi@yahoo.com 

BRCFORM651 hps_2001@yahoo.com 

BRCFORM652 hrabas@yahoo.com 

BRCFORM653 hray69@yahoo.com 

BRCFORM654 hrowen3@hotmail.com 

BRCFORM655 Husky300@clearwire.net 

BRCFORM656 husky450tc@yahoo.com 

BRCFORM657 hwy204@gmail.com 

BRCFORM658 hydebuster@sbcglobal.net 

BRCFORM­ hydindser@yahoo.com 

493
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

659 

BRCFORM660 iamstoker@yahoo.com 

BRCFORM661 ianarth@mac.com 

BRCFORM662 ianc408@gmail.com 

BRCFORM663 ibblessed03@hotmail.com 

BRCFORM664 ibrew@sbcglobal.net 

BRCFORM665 iceomatic95@hotmail.com 

BRCFORM666 id4dan@yahoo.com 

BRCFORM­ ill_kick_ur_butt@mail2cutey 

667 .com 

BRCFORM668 imapiche@comcast.net 

BRCFORM669 imcooter@yahoo.com 

BRC­ info@westernminingclaims.c 

FORM- om 

670 

BRCFORM671 inkaman@aol.com 

BRCFORM672 irondogtnt@charter.net 

BRCFORM673 isignedup@ca.rr.com 

BRCFORM674 ivanpen@hotmail.com 

BRCFORM675 izzy_perrin@hotmail.com 

BRCFORM676 J.ingram@att.net 

BRCFORM­ J_GOULETT@HOTMAIL. 

677 COM 

BRCFORM­ jabrams@cdsengineeringinc. 

678 com 

BRCFORM679 jacckpfisthner@yahoo.com 

BRCFORM680 jace.sandstrom@gmail.com 

BRC­ jack@hondasb.sbcoxmail.co 

FORM- m 

681 

BRCFORM682 jack_shook@hotmail.com 

BRCFORM683 jacklanto@comcast.net 

BRCFORM684 jacobcummings@gmail.com 

BRCFORM685 jacobpd@telstar-online.net 

BRCFORM­ JAdamsrmk900@sbcglobal. 

686 net 

BRCFORM687 jaferro@aol.com 

BRCFORM688 jakegnz1415@gmail.com 

BRCFORM689 jakewears@yahoo.com 

BRCFORM690 Jamainland@comcast.net 

BRCFORM691 jamesshermit@aol.com 

BRCFORM­ janhder@hotmail.com 

494
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

692 

BRCFORM693 jared.knowles@gmail.com 

BRCFORM694 jasmoore3@hotmail.com 

BRCFORM695 jason.hipkiss@gmail.com 

BRCFORM696 jason.t.beren@lmco.com 

BRCFORM697 Jason@high-speed-cnc.com 

BRCFORM698 jason_bort@yahoo.com 

BRCFORM­ jason_n_clement@hotmail.c 

699 om 

BRCFORM700 jasonfifield@netscape.net 

BRCFORM701 jasonsteck@hotmail.com 

BRCFORM702 jassen@motionpro.com 

BRCFORM­ jasummers@earthlink.net 

703 

BRCFORM704 javnta2007@hotmail.com 

BRCFORM705 jaxdon2@cox.net 

BRCFORM706 jayebart@yahoo.com 

BRCFORM707 jaymacdonald@comcast.net 

BRCFORM708 jaynen00@gmail.com 

BRCFORM709 jayort30@yahoo.com 

BRCFORM710 jb@prefmortgage.com 

BRCFORM711 jbeite@comcast.net 

BRCFORM712 jbird104@yahoo.com 

BRCFORM713 jbozarthbsmm@hotmail.com 

BRCFORM­ jbrewer24@hotmail.com 

714 

BRCFORM715 jbrownkyr1@Hotmail.com 

BRCFORM716 jbrownmxr@yahoo.com 

BRCFORM717 jc.dirt@gmail.com 

BRCFORM718 jcarn65@yahoo.com 

BRCFORM719 jcreel38@yahoo.com 

BRCFORM720 jdaivs1@sbcglobal.net 

BRCFORM721 jdininger@surewest.net 

BRCFORM722 JEEPCREW@AOL.COM 

BRCFORM723 Jeepfavreau@gmail.com 

BRCFORM724 jeepruler@hotmail.com 

BRCFORM­ JEEPY@INREACH.COM 

495
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

725 

BRCFORM- Jeff Steiner 

726 <jeff.steiner@gmail.com> 

BRCFORM727 jeff@atis1.com 

BRCFORM728 jeff@kynetics.com 

BRCFORM729 jeff_davis@comcast.net 

BRCFORM730 jeff_lts@msn.com 

BRCFORM731 jeffandre1@aol.com 

BRCFORM732 jeffbanister@sbcglobal.net 

BRCFORM733 jefferyshicks@hotmail.com 

BRCFORM734 jeffh@casepak.com 

BRCFORM735 Jeffh@future-home.net 

BRCFORM­ jeffhoward@gmail.com 

736 

BRCFORM737 jeffreyjaymorris@gmail.com 

BRCFORM738 jeffreyogden@sbcglobal.net 

BRCFORM739 jeffs@nofear.com 

BRCFORM740 jeffve@gmail.com 

BRCFORM741 jeffzilla@hotmail.com 

BRCFORM742 jefgil123@yahoo.com 

BRCFORM743 jejb@att.net 

BRCFORM744 jensenb001@yahoo.com 

BRCFORM745 jerrycunha@aol.com 

BRCFORM746 jerrykap@pacbell.net 

BRCFORM­ jesisme@gmail.com 

747 

BRCFORM748 jesse.trevino@av.abbott.com 

BRCFORM749 jetconnection1@cs.com 

BRCFORM750 jfatbalance@att.net 

BRCFORM­ jfavorite@foxracingshox.co 

751 m 

BRCFORM752 jforrest66@yahoo.com 

BRCFORM753 jgildner@emercon.com 

BRCFORM754 jgill@dslextreme.com 

BRCFORM755 jginsj@yahoo.com 

BRCFORM756 jgrizzly660@gmail.com 

BRCFORM757 jguthals@centurytel.net 

BRCFORM­ jh4303@yahoo.com 

496
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

758 

BRCFORM759 jheiser@mac.com 

BRCFORM760 jiensupkim@earthlink.net 

BRCFORM761 jim.mcconnell@varian.com 

BRCFORM762 jim.p@sbcglobal.net 

BRCFORM763 jim@airsis.com 

BRCFORM764 jim@hoodlift.com 

BRCFORM765 jim@le-suspension.com 

BRCFORM766 jim@siemons.com 

BRCFORM767 jim_schulz@charter.net 

BRCFORM768 jim9006@comcast.net 

BRCFORM­ jimauc@totalspeed.net 

769 

BRCFORM770 jimb_83@yahoo.com 

BRCFORM771 jimjr@fulling.org 

BRCFORM772 jimmartens1@msn.com 

BRCFORM773 jimmiller62@me.com 

BRCFORM774 jimmy.j.garcia@dole.com 

BRCFORM775 jimmy.lewis@sorc.com 

BRCFORM776 jimmy.patshorty@att.net 

BRCFORM777 jimperreira@hotmail.com 

BRCFORM778 jimwatt1@yahoo.com 

BRCFORM779 jisaak@isaakag.com 

BRCFORM­ jjb4x4@yahoo.com 

780 

BRCFORM781 JJCUSS@COMCAST.NET 

BRCFORM782 jjeffrey_r@hotmail.com 

BRCFORM783 jjustj@hotmail.com 

BRCFORM784 jkb6wvg@nccn.net 

BRCFORM785 jkkizz@netzero.net 

BRCFORM786 jkkniss@comcast.net 

BRCFORM787 jladrigan@aol.com 

BRCFORM788 jlamb4483@aol.com 

BRCFORM789 jlegt@prodigy.net 

BRCFORM790 JLeighton@Comcast.net 

BRCFORM­ jlhufford@att.net 

497
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

791 

BRCFORM792 jlnewsom1@gmail.com 

BRCFORM793 jmacfam3@att.net 

BRCFORM794 jmadre@hotmail.com 

BRCFORM795 jman5150@comcast.net 

BRCFORM796 jmason3849@aol.com 

BRCFORM797 jmcrae72@gmail.com 

BRCFORM798 jmelzer@nnex.net 

BRCFORM799 jmollahan@surewest.net 

BRCFORM800 jmoonmtn@sbcglobal.net 

BRCFORM801 jmpotter1@aol.com 

BRCFORM­ jmtipps@comcast.net 

802 

BRCFORM803 jnybbad@comcast.net 

BRCFORM804 joannacurd@aol.com 

BRCFORM805 joaquin5252@hotmail.com 

BRCFORM806 jodi@tjdenning.com 

BRCFORM­ JODYCCKC@HOTMAIL.C 

807 OM 

BRCFORM808 jodyhum@hotmail.com 

BRCFORM809 joe.tralongo@gmail.com 

BRCFORM810 joe@mail2bad.com 

BRCFORM­ joebianchi92835@yahoo.co 

811 m 

BRCFORM812 joecranehand@aol.com 

BRCFORM­ joeferrante@sbcglobal.net 

813 

BRCFORM814 joej5150@msn.com 

BRCFORM815 joel.beck@hp.com 

BRCFORM816 joelberg1@hotmail.com 

BRCFORM817 joellekos@yahoo.com 

BRCFORM818 joemoto600@yahoo.com 

BRCFORM819 joemotocross@yahoo.com 

BRCFORM820 joeredrider@yahoo.com 

BRCFORM821 joevieira@clearwire.net 

BRCFORM­ Joey@TerminatorEngineerin 

822 g.com 

BRCFORM823 joeymaxvill@att.net 

BRC- John Ruiz 

FORM­ <John.Ruiz@Aviatnet.com> 

498
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

824 

BRCFORM825 john.a.starbuck@intel.com 

BRCFORM­ John.Bauer@RackNRoad.co 

826 m 

BRCFORM827 john@bollman.com 

BRCFORM828 john@mpdc.com 

BRCFORM829 johnh17@sonic.net 

BRCFORM830 johnjoanjohnson@att.net 

BRCFORM­ johnnymurphree@hotmail.co 

831 m 

BRCFORM­ johnnyscustom@earthlink.ne 

832 t 

BRCFORM­ johntriolo64@YAHOO.CO 

833 M 

BRCFORM834 johnwfrey@hotmail.com 

BRCFORM­ joiseyshore@comcast.net 

835 

BRCFORM836 jon@mandrell.com 

BRCFORM837 jonboyauto@yahoo.com 

BRCFORM838 jonchrislarson@gmail.com 

BRCFORM839 joncrf250x@me.com 

BRCFORM840 jonhjohnson@yahoo.com 

BRCFORM841 jonnorth@comcast.net 

BRCFORM842 jonpatzer@hotmail.com 

BRCFORM843 jordan.reaves@gmail.com 

BRCFORM­ josephjacobs06@comcast.ne 

844 t 

BRCFORM845 josephroy@hotmail.com 

BRCFORM­ Josroak@yahoo.com 

846 

BRCFORM847 jp@thedavilagroup.com 

BRCFORM848 jpastore@wildblue.net 

BRCFORM849 jphoyle727@aol.com 

BRCFORM850 jpjnke@verizon.net 

BRCFORM851 JPKTrout@yahoo.com 

BRCFORM852 jptarcinski@yahoo.com 

BRCFORM853 jrdavis269@hotmail.com 

BRCFORM854 jrfisher.co@gmail.com 

BRCFORM855 jrosa@certifiedsign.com 

BRCFORM856 jrp1947@aol.com 

BRCFORM­ jrusus@charter.net 

499
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

857 

BRCFORM858 jscc@citlink.net 

BRCFORM859 jshaverjr@carolina.rr.com 

BRCFORM860 Jsjalm@msn.com 

BRCFORM861 jsmith807@gmail.com 

BRCFORM862 jsmoffitt@comcast.net 

BRCFORM863 jsrcr@comcast.net 

BRCFORM864 jsteckline@rocksolidnv.com 

BRCFORM­ JSTILWELL@BARIPROD 

865 UCE.COM 

BRCFORM866 jsumm119@yahoo.com 

BRCFORM867 jthomp4112@sbcglobal.net 

BRCFORM­ jtkingsr@sbcglobal.net 

868 

BRCFORM869 jtroidl@cox.net 

BRCFORM870 jtrumpower@yahoo.com 

BRCFORM871 jtyrone3@sbcglobal.net 

BRCFORM872 juliapoulsen@gmail.com 

BRCFORM873 juliecovey@ca.rr.com 

BRCFORM874 junkmaildf@gmail.com 

BRCFORM875 justin_6226@yahoo.com 

BRCFORM876 jutty@hotmail.com 

BRCFORM877 jwilcox28@hotmail.com 

BRCFORM878 jwlerch@roadrunner.com 

BRCFORM- k.jacinto@sbcglobal.net 

879 

BRCFORM880 kaffleck@gmail.com 

BRCFORM881 kahalapo@hotmail.com 

BRCFORM882 kalcon@sbcglobal.net 

BRCFORM883 kanawyerss@att.net 

BRCFORM884 kanerds@kanab.net 

BRCFORM885 kap@sopris.net 

BRCFORM886 karchek@juno.com 

BRCFORM887 kari@blueflystudio.com 

BRCFORM888 karin@karinmiyabara.com 

BRCFORM889 karl.mason@adelphia.net 

BRC­ kathy@onejourneyatatime.co 

FORM- m 

500
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

890 

BRCFORM891 Katieturne@gmail.com 

BRCFORM892 kattoom@msn.com 

BRCFORM893 kawmotodad@hotmail.com 

BRCFORM894 kberkovitz@gmail.com 

BRCFORM895 kcalassa@sbcglobal.net 

BRCFORM896 kdx@plipson.com 

BRCFORM897 kedrz4@yahoo.com 

BRCFORM898 keithmclachlan@yahoo.com 

BRCFORM899 kelly@drakestile.com 

BRCFORM900 ken@klageswebdesign.com 

BRCFORM­ kenarmann@hotmail.com 

901 

BRCFORM902 kencamet@yahoo.com 

BRCFORM­ kenneth903 arrington@sbcglobal.net 

BRCFORM904 kens08@yahoo.com 

BRCFORM905 kentabooth@comcast.net 

BRCFORM906 kevin.myers79@yahoo.com 

BRCFORM­ kevin.winwood@honeywell. 

907 com 

BRCFORM908 kevin_majeski@yahoo.com 

BRCFORM909 kevinknbuddy@yahoo.com 

BRCFORM910 kevinmollard@aol.com 

BRCFORM­ KEVINROSEVEAR@GMA 

911 IL.COM 

BRCFORM­ kevinz2@charter.net 

912 

BRCFORM913 kevone353@aol.com 

BRCFORM914 kevstoph@hotmail.com 

BRCFORM­ keystonemachine@hotmail.c 

915 om 

BRCFORM916 kga125@aol.com 

BRCFORM917 kgtrider@sbcglobal.net 

BRCFORM918 kheynen@socal.rr.com 

BRCFORM919 khylton11@yahoo.com 

BRCFORM920 kindorb@hotmail.com 

BRCFORM921 kingosat@yahoo.com 

BRCFORM922 kipwoody@yahoo.com 

BRCFORM­ kirk.johanns@gmail.com 

501
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

923 

BRCFORM924 kjk68@hotmail.com 

BRCFORM925 kkramasz@sbcglobal.net 

BRCFORM926 kls57@comcast.net 

BRCFORM927 kmanning@alldata.com 

BRCFORM928 knobb490@gmail.com 

BRCFORM­ KNOBBIETIRE@YAHOO. 

929 COM 

BRCFORM930 knobbytyre@hotmail.com 

BRCFORM931 kolt61@bak.rr.com 

BRCFORM932 kosherdog65@hotmail.com 

BRCFORM933 koyer@mac.com 

BRCFORM­ KPritten@aol.com 

934 

BRCFORM935 krazeeracer@hotmail.com 

BRCFORM936 kreeds@msidesign.com 

BRCFORM937 krice15@cox.net 

BRCFORM938 krynock@gmail.com 

BRCFORM939 kstockman@comcast.net 

BRCFORM940 ktb4546@sbcglobal.net 

BRCFORM941 kungchild@gmail.com 

BRCFORM942 kvhepler@earthlink.net 

BRCFORM943 kyarnall2@verizon.net 

BRCFORM944 kyarnell@trane.com 

BRCFORM­ kyle.McCraw@cdcr.ca.gov 

945 

BRCFORM­ kyle.weaver@cvn70.navy.mi 

946 l 

BRCFORM947 kyle@4-yes.com 

BRCFORM948 ladd@sonitusmedical.com 

BRCFORM949 ladd_johnson@yahoo.com 

BRCFORM950 lambmp@gmail.com 

BRCFORM951 lambson.four@verizon.net 

BRCFORM­ lance@experiencepowerspor 

952 ts.com 

BRCFORM­ landshark11099@sbcglobal. 

953 net 

BRCFORM954 larry@motionpro.com 

BRCFORM955 larry05@bresnan.net 

BRCFORM­ larryroak@yahoo.com 

502
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

956 

BRCFORM957 larx2002@hotmail.com 

BRCFORM958 lauren_caputo@yahoo.com 

BRCFORM959 laypipe2003@yahoo.com 

BRCFORM960 laythomas@yahoo.com 

BRCFORM961 lazz@digitalpath.net 

BRCFORM962 lboal@verizon.net 

BRCFORM963 lcwp2000@hotmail.com 

BRCFORM964 ledesmajess@yahoo.com 

BRCFORM965 leftonthetable@yahoo.com 

BRCFORM966 lelandmason@excite.com 

BRCFORM­ leonard.pawlak@yahoo.com 

967 

BRCFORM968 leslie250@columbus.rr.com 

BRCFORM969 lester131@mchsi.com 

BRCFORM970 lghtruck@msn.com 

BRCFORM971 liftedscout@msn.com 

BRCFORM972 likebrewmike@yahoo.com 

BRCFORM973 lilcruzer1977@yahoo.com 

BRCFORM974 lildude92mk@gmail.com 

BRCFORM975 linan@eecs.berkeley.edu 

BRCFORM976 linda@wrightcolor.com 

BRCFORM977 linda_mann@hotmail.com 

BRCFORM­ lithebayr@aol.com 

978 

BRCFORM979 lithgow129bs@aim.com 

BRCFORM980 live.bait@live.com 

BRCFORM981 livewireme@sbcglobal.net 

BRCFORM982 lizziez99@yahoo.com 

BRCFORM983 llakemayor@aol.com 

BRCFORM984 lolson1174@aol.com 

BRCFORM­ longwayround@sbcglobal.ne 

985 t 

BRCFORM986 loonybin1314@msn.com 

BRCFORM987 Lowtideracing@aol.com 

BRCFORM988 lreader@socal.rr.com 

BRCFORM­ lroberts411@yahoo.com 

503
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

989 

BRCFORM990 lrstead@msn.com 

BRCFORM­ lschulz@wheelerandgray.co 

991 m 

BRCFORM992 ltsnyders@aol.com 

BRCFORM­ ltsrock38@mesanetworks.ne 

993 t 

BRCFORM994 lucasdawson@yahoo.com 

BRCFORM­ lundgrenconstruction@yaho 

995 o.com 

BRCFORM996 luv2ridemx@sbcglobal.net 

BRCFORM997 Lytell3333@cox.net 

BRCFORM998 m.hartsell@sbcglobal.net 

BRCFORM999 m_stenkilsson@yahoo.com 

BRCFORM­ mac@willeyprinting.com 

1000 

BRCFORM1001 macgems@sbcglobal.net 

BRCFORM1002 macwhinney@sbcglobal.net 

BRCFORM­ MADEAPURCHASE@GM 

1003 AIL.COM 

BRCFORM­ madmetalman@sbcglobal.ne 

1004 t 

BRCFORM1005 maermigo@comcast.net 

BRCFORM1006 magillaprime@yahoo.com 

BRCFORM1007 Magnut22@aol.com 

BRCFORM1008 mahern@netapp.com 

BRCFORM1009 maproslan@yahoo.com 

BRCFORM1010 marekc@ixiacom.com 

BRCFORM­ mariposa.john@gmail.com 

1011 

BRCFORM1012 mark.levy@maxim-ic.com 

BRCFORM1013 mark.roznos@verizon.net 

BRCFORM- Mark.stadler@verizonbusine 

1014 ss.com 

BRCFORM1015 mark@calaccess.net 

BRCFORM1016 mark@fosterenterprises.com 

BRCFORM1017 mark@lvhentertainment.com 

BRCFORM­ Mark@mtnhomeconstruction 

1018 .com 

BRCFORM1019 markee950@dishmail.net 

BRCFORM1020 markkaiser1@earthlink.net 

BRCFORM1021 markrobb@sbcglobal.net 

BRCFORM­ marksp@mpcomputers.biz 

504
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1022 

BRCFORM1023 markv@sd215.net 

BRCFORM1024 marsdust525@hotmail.com 

BRCFORM1025 martincoe@sbcglobal.net 

BRCFORM­ martyskiridemoore@yahoo.c 

1026 om 

BRCFORM1027 Marvd@rmi.net 

BRCFORM1028 marvdogmiller@aol.com 

BRCFORM1029 Marymoehnke@aol.com 

BRCFORM1030 mason_xcr@hotmail.com 

BRCFORM1031 matt@hi-standard.com 

BRCFORM1032 matt_rsb@sbcglobal.net 

BRCFORM­ matt267@comcast.net 

1033 

BRCFORM1034 mattflatter@yahoo.com 

BRCFORM1035 matthew.mettes@gmail.com 

BRCFORM1036 mattstavish@frontiernet.net 

BRCFORM1037 mauman@maui.net 

BRCFORM1038 mauriceswan@sbcglobal.net 

BRCFORM1039 maxdiannaeddy@aol.com 

BRCFORM1040 mayrabraselton@gmail.com 

BRCFORM­ mbeltramo@piedmontmovin 

1041 g.com 

BRCFORM1042 mbibarra@hotmail.com 

BRCFORM1043 mbonin@wavecable.com 

BRCFORM­ mccrab@earthlink.net 

1044 

BRCFORM1045 Mcfungle@aol.com 

BRCFORM1046 mckenna019@yahoo.com 

BRCFORM1047 Mclay@coj.net 

BRCFORM1048 mcnewcrew@gmail.com 

BRCFORM1049 mcr500@anlin.com 

BRCFORM1050 mcrcr4@charter.net 

BRCFORM1051 mcrobert@hdo.net 

BRCFORM1052 mcussins@WKRP.biz 

BRCFORM1053 mcwcraig@aol.com 

BRCFORM1054 mdamick@hughes.net 

BRCFORM­ mdbconst@qnet.com 

505
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1055 

BRCFORM1056 mdhavner@verizon.net 

BRCFORM1057 mdinspections@aol.com 

BRCFORM1058 MegacabDRZ@gmail.com 

BRCFORM1059 meharper@inreach.com 

BRCFORM1060 merooks@sbcglobal.net 

BRCFORM1061 mertsdad@yahoo.com 

BRCFORM1062 mewooly@yahoo.com 

BRCFORM1063 mfcopley@yahoo.com 

BRCFORM1064 Mgcollaco@yahoo.com 

BRCFORM1065 mgrimes1@socal.rr.com 

BRCFORM­ mhagest@yahoo.com 

1066 

BRCFORM1067 mhildebrand@charter.net 

BRCFORM1068 mholman12@yahoo.com 

BRCFORM­ michaelcahill61@hotmail.co 

1069 m 

BRCFORM1070 michaeldea@comcast.net 

BRCFORM1071 MichaelRaasch260@aol.com 

BRCFORM­ michaelwebb@accessbee.co 

1072 m 

BRCFORM1073 michaud42@aol.com 

BRCFORM­ michelle@rallyontherocks.co 

1074 m 

BRCFORM1075 michelle66@pacbell.net 

BRCFORM1076 michellem@directv.net 

BRCFORM­ mickiejc@yahoo.com 

1077 

BRCFORM1078 mike.scott@cox.net 

BRCFORM1079 mike.signdesign@gmail.com 

BRCFORM­ mike.stephens@colostate.ed 

1080 u 

BRCFORM­ Mike.Yeomans@alcatel1081 lucent.com 

BRCFORM1082 mike@alpinelink.com 

BRCFORM1083 mike@creativecomp.com 

BRCFORM1084 Mike@EMTElectric.com 

BRCFORM­ mike@westpointautomotive. 

1085 com 

BRCFORM1086 mike_chaney@pashanet.com 

BRCFORM1087 mike_ryan702@hotmail.com 

BRCFORM­ mike4jewel@yahoo.com 

506
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1088 

BRCFORM1089 mikeandjanie@yahoo.com 

BRCFORM1090 mikehome07@msn.com 

BRCFORM1091 mikekirsch@sbcglobal.net 

BRCFORM1092 mikelowenstein@att.net 

BRCFORM1093 mikeofiesh@msn.com 

BRCFORM1094 Mikerocchio@gmail.com 

BRCFORM1095 mikerosa.21d@gmail.com 

BRCFORM1096 MikeSand52@msn.com 

BRCFORM1097 mikey47x@comcast.net 

BRCFORM­ MILANISAUTOCRAFT@A 

1098 OL.COM 

BRCFORM­ miles@mileskeepfoto.com 

1099 

BRCFORM1100 millerracing1@verizon.net 

BRCFORM­ minimax20002000@yahoo.c 

1101 om 

BRCFORM1102 ministokracr9@aol.com 

BRCFORM1103 misterco@yahoo.com 

BRCFORM1104 mjgradek@sbcglobal.net 

BRCFORM1105 mjoew@msn.com 

BRCFORM1106 mjronfarm@aol.com 

BRCFORM1107 mjwaldrop@hotmail.com 

BRCFORM1108 mkomrosk@comcast.net 

BRCFORM1109 mlcaples@msn.com 

BRCFORM­ mls234@humboldt.edu 

1110 

BRCFORM1111 mlwn2001@yahoo.com 

BRCFORM1112 mmshaner@comcast.net 

BRCFORM1113 mmwr87@comcast.net 

BRCFORM1114 mn8luv@verizon.net 

BRCFORM1115 mnichols@nicholsmfg.com 

BRCFORM1116 mnmleitch2@yahoo.com 

BRCFORM1117 molinenorski@msn.com 

BRCFORM1118 mongo158.1@sbcglobal.net 

BRCFORM1119 montywolf@gmail.com 

BRCFORM­ MOONERGOLF@AOL.CO 

1120 M 

BRCFORM­ moonstorm74@yahoo.com 

507
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1121 

BRCFORM1122 moopalace@aol.com 

BRCFORM1123 moparkids66@yahoo.com 

BRCFORM1124 mordakiss7@yahoo.com 

BRCFORM1125 morlnbro@aol.com 

BRCFORM1126 morris77s@att.net 

BRCFORM1127 motodreaming@gmail.com 

BRCFORM1128 motoguy21@yahoo.com 

BRCFORM1129 motoian45@yahoo.com 

BRCFORM1130 motojoe17@sbcglobal.net 

BRCFORM1131 Motomergan@gmail.com 

BRC­ motomikebuilder@comcast. 

FORM- net 

1132 

BRCFORM1133 motonate21@Hotmail.com 

BRCFORM1134 mototyme@earthlink.net 

BRCFORM1135 mountainjeeper@aol.com 

BRCFORM1136 MPC@SUREWEST.NET 

BRCFORM1137 mpiche@elliston.com 

BRCFORM1138 mpl38737@yahoo.com 

BRCFORM1139 mr_barranti@yahoo.com 

BRCFORM­ mrayback@woodrodgers.co 

1140 m 

BRCFORM1141 mrmgzx12@gmail.com 

BRCFORM1142 mrodgers@westernblue.com 

BRCFORM­ mrustay@hotmail.com 

1143 

BRCFORM1144 mschorpp@protectolite.com 

BRCFORM1145 mshmotox@yahoo.com 

BRCFORM1146 msw23@sbcglobal.net 

BRCFORM1147 mthill@gmail.com 

BRCFORM­ mtoconstruction1@comcast. 

1148 net 

BRCFORM­ MTrowbridge@StrategicPro 

1149 curementSolutions.com 

BRCFORM1150 mudrod@pirate4x4.com 

BRCFORM­ mumiller@mammoth1151 mtn.com 

BRCFORM1152 mushrush83@yahoo.com 

BRCFORM1153 mwurtzel@flash.net 

BRC- MX_Fyrcaptain@sbcglobal. 

FORM- net 

508
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1154 

BRCFORM1155 mx114@hotmail.com 

BRCFORM1156 mxlunde@yahoo.com 

BRCFORM- n.martin@oregon1157 physics.com 

BRCFORM­ n2boarding2003@yahoo.co 

1158 m 

BRCFORM1159 N2Roost@aol.com 

BRCFORM1160 nagelmotox@hotmail.com 

BRCFORM1161 naomi112074@hotmail.com 

BRCFORM­ nasrallahstrick@sbcglobal.ne 

1162 t 

BRCFORM1163 nastrodamus67@yahoo.com 

BRCFORM1164 nate@dirttricks.com 

BRCFORM­ nate_annie@yahoo.com 

1165 

BRCFORM1166 nathanweiher@hotmail.com 

BRCFORM1167 nbts1@comcast.net 

BRCFORM1168 ndelgado9@yahoo.com 

BRCFORM1169 Needforsand@comcast.net 

BRCFORM1170 neilnovack@yahoo.com 

BRCFORM1171 nelliemark@sbcglobal.net 

BRCFORM1172 nemosis1121@sbcglobal.net 

BRCFORM­ neuenswanderhazel@hotmail 

1173 .com 

BRCFORM­ nicholas.garza@sbcglobal.ne 

1174 t 

BRCFORM­ nick@access1175 substratesusa.com 

BRCFORM­ nick_monroy@yahoo.com 

1176 

BRCFORM1177 nickfranco1@gmail.com 

BRCFORM1178 nik@ostergren.us 

BRCFORM1179 nikki.sabye@gmail.com 

BRCFORM1180 nikwags@gmail.com 

BRCFORM1181 nkamplin@yahoo.com 

BRCFORM1182 nkimberger@bak.rr.com 

BRCFORM1183 no2tracks@yahoo.com 

BRCFORM1184 noelleandclint@netzero.com 

BRCFORM1185 nojeeps@yahoo.com 

BRCFORM1186 NorCalCruiser@aol.com 

BRCFORM­ norcalfilmer@gmail.com 

509
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1187 

BRCFORM1188 normmatzen@yahoo.com 

BRCFORM1189 northfacedave@hotmail.com 

BRCFORM1190 northmesa@yahoo.com 

BRCFORM­ northwestglass@clearwire.ne 

1191 t 

BRCFORM1192 norules90@msn.com 

BRCFORM1193 ntsqd@yahoo.com 

BRCFORM­ nuggetautobody@hotmail.co 

1194 m 

BRCFORM1195 nukldragger@charter.net 

BRCFORM1196 nwcycle@sbcglobal.net 

BRCFORM1197 oakcreekranch@yahoo.com 

BRCFORM­ oakhillsauto@yahoo.com 

1198 

BRCFORM1199 odonnks@windstream.net 

BRCFORM1200 offroadash4@aol.com 

BRCFORM1201 offroadjcr@gmail.com 

BRCFORM1202 oldmoto12@aol.com 

BRCFORM1203 oldmoto12@att.net 

BRCFORM1204 olson16@frontiernet.net 

BRCFORM1205 omcrider@sbcglobal.net 

BRCFORM1206 onadyme@aol.com 

BRCFORM1207 One20one@comcast.net 

BRCFORM1208 onedante@hotmail.com 

BRCFORM­ onesassey@comcast.net 

1209 

BRCFORM1210 oneupracing@earthlink.net 

BRCFORM1211 onto1wheel@yahoo.com 

BRCFORM1212 opiebennett@gmail.com 

BRCFORM1213 orangerider06@yahoo.com 

BRCFORM1214 orders@dirttricks.com 

BRCFORM1215 ortizst1@hotmail.com 

BRCFORM1216 oshnspray@yahoo.com 

BRCFORM1217 ossaman@pacbell.net 

BRCFORM1218 overkill45@aol.com 

BRCFORM1219 owa_owa@yahoo.com 

BRCFORM­ owtcast@hotmail.com 

510
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1220 

BRCFORM1221 Ozmister@gmail.com 

BRCFORM1222 oztown1@yahoo.com 

BRCFORM1223 p_ingram3541@hotmail.com 

BRCFORM1224 paddlesurfmg@gmail.com 

BRCFORM1225 padres@cox.net 

BRCFORM1226 pahadden22@yahoo.com 

BRCFORM1227 panosandrea@yahoo.com 

BRCFORM- parts@the-motorcycle1228 shop.com 

BRCFORM1229 pascochris@yahoo.com 

BRCFORM1230 pat.speece@sbcglobal.net 

BRCFORM- pat@waite.net 

1231 

BRCFORM1232 patmcf@swbell.net 

BRCFORM1233 patrick.collins@dole.com 

BRCFORM1234 paul.schauer@gmail.com 

BRCFORM1235 paul@atis1.com 

BRCFORM1236 paul@rmtarchitects.com 

BRCFORM1237 paul@specialtravel.com 

BRCFORM1238 paulfranck@sbcglobal.net 

BRCFORM1239 paulquade@moondog.net 

BRCFORM1240 paultownsend73@gmail.com 

BRCFORM1241 pavelaw@aol.com 

BRCFORM­ pbspiffer@aol.com 

1242 

BRCFORM1243 pcassidy111@comcast.net 

BRCFORM1244 pdcolema@gmail.com 

BRCFORM1245 pdpeel@sbcglobal.net 

BRCFORM1246 peacefrogmoto@gmail.com 

BRCFORM1247 pedeq40@hotmail.com 

BRCFORM­ Pete@ContraCostaLiving.co 

1248 m 

BRCFORM1249 petra.iris@gmail.com 

BRCFORM1250 petunia9@pacbell.net 

BRCFORM1251 pgf750@yahoo.com 

BRCFORM1252 phil@rockaholics.com 

BRCFORM­ philbilly@mac.com 

511
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1253 

BRCFORM1254 philheynen@yahoo.com 

BRCFORM1255 Phill@Kenoyer.com 

BRCFORM1256 philsamenzo@cs.com 

BRCFORM1257 piedralone@yahoo.com 

BRCFORM1258 piotr94014@yahoo.com 

BRCFORM1259 pismo1327@sbcglobal.net 

BRCFORM1260 pjaymot@hotmail.com 

BRCFORM1261 pkelly5@mail.csuchico.edu 

BRCFORM1262 pkswork@yahoo.com 

BRCFORM1263 Plasticsguy@aol.com 

BRCFORM­ plinyjr2000@yahoo.com 

1264 

BRCFORM1265 plkl@sbcglobal.net 

BRCFORM1266 polarismann500@aol.com 

BRCFORM1267 polingk@gmail.com 

BRCFORM1268 pooleschl1@hotmail.com 

BRCFORM1269 popeshouse@sbcglobal.net 

BRCFORM- popeshouse@vzw.blackberry 

1270 .net 

BRCFORM­ PRECISIONMOTO@VERI 

1271 ZON.NET 

BRCFORM1272 pschiess@sbcglobal.net 

BRCFORM1273 psimis1@yahoo.com 

BRCFORM1274 ptrickjw@sbcglobal.net 

BRCFORM­ pudgypaintguy@yahoo.com 

1275 

BRCFORM1276 pwabbit@hotmail.com 

BRCFORM1277 qdude79@yahoo.com 

BRCFORM­ QT1RACING@GMAIL.CO 

1278 M 

BRCFORM1279 qtpy123@comcast.net 

BRCFORM1280 quicfix500@yahoo.com 

BRCFORM1281 r.hallberg@halfab.com 

BRCFORM1282 r.marshall@comcast.net 

BRCFORM1283 r.young71@hotmail.com 

BRCFORM1284 r_dlemler@att.net 

BRCFORM1285 r_oeser@yahoo.com 

BRCFORM­ r1chs57634@gmail.com 

512
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1286 

BRCFORM1287 racerextreme@hotmail.com 

BRCFORM1288 racerx107@yahoo.com 

BRCFORM1289 ralves1@earthlink.net 

BRCFORM1290 Ramiller24@hotmail.com 

BRCFORM1291 ramracer@sbcglobal.net 

BRCFORM1292 ranchinc@sbcglobal.net 

BRCFORM­ randalcates@bendbroadband 

1293 .com 

BRCFORM1294 randallaj@msn.com 

BRCFORM1295 randyb5y@hotmail.com 

BRCFORM1296 randypreston@comcast.net 

BRCFORM­ randysoo@rocketmail.com 

1297 

BRCFORM1298 rap_n_rod@yahoo.com 

BRCFORM1299 rawly89@sbcglobal.net 

BRCFORM1300 raydrums@hotmail.com 

BRCFORM1301 rbdebusk@hotmail.com 

BRCFORM­ rbowser@paceengineering.u 

1302 s 

BRCFORM1303 rchamberlin@cci.edu 

BRCFORM1304 rcoody@hotmail.com 

BRCFORM1305 rcrabtree@chicodrywall.com 

BRCFORM1306 Rct34me@aol.com 

BRCFORM1307 rcuneo67@hotmail.com 

BRCFORM­ rdc949@aol.com 

1308 

BRCFORM1309 rddubree@com-pair.net 

BRCFORM1310 rdohboy@hotmail.com 

BRCFORM1311 rebmc@verizon.net 

BRCFORM1312 redfred47@gmail.com 

BRCFORM1313 redone451@yahoo.com 

BRCFORM1314 reiffj@yahoo.com 

BRCFORM1315 relam@earthlink.net 

BRCFORM1316 res6njnv@verizon.net 

BRCFORM1317 rex@rexr.com 

BRCFORM1318 rexscates@sbcglobal.net 

BRCFORM­ rgottschalk@verizon.net 

513
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1319 

BRCFORM1320 rhalepeska@yahoo.com 

BRCFORM­ RHarrah@InnovativePestMa 

1321 nagement.com 

BRCFORM1322 rhmachine@yahoo.com 

BRCFORM1323 rhodamgreen@hotmail.com 

BRCFORM1324 rhurson@yahoo.com 

BRCFORM1325 ric@tasksavvy.com 

BRCFORM­ ricardoftravassos@yahoo.co 

1326 m 

BRCFORM1327 rich@givethanksawards.com 

BRCFORM1328 rich@motionpro.com 

BRCFORM1329 richard-box@sbcglobal.net 

BRC­ richardfarinelli@sbcglobal.n 

FORM- et 

1330 

BRCFORM1331 richcochran@att.net 

BRCFORM1332 rick.adan@sri.com 

BRCFORM1333 rick@motionpro.com 

BRCFORM1334 rickbollinger@hotmail.com 

BRCFORM1335 rickddunagan@aol.com 

BRCFORM1336 rickhamner@att.net 

BRCFORM1337 ridetahoe@sbcglobal.net 

BRCFORM1338 ridewfo@gmail.com 

BRCFORM1339 Riding4me@Live.com 

BRCFORM1340 Rigsbyr@ATt.net 

BRCFORM­ rileysparman@gmail.com 

1341 

BRCFORM1342 riptide@sbcglobal.net 

BRCFORM1343 rjcranch@aol.com 

BRCFORM1344 rjfrey1@yahoo.com 

BRCFORM1345 rkajr@comcast.net 

BRCFORM1346 rkp2@att.net 

BRCFORM1347 rmf525@att.net 

BRCFORM1348 rmills@teichert.com 

BRCFORM1349 rnegronsprint@earthlink.net 

BRCFORM1350 rnuss256@msn.com 

BRCFORM1351 roadoman@aol.com 

BRCFORM­ rob.cravens@iap.com 

514
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1352 

BRCFORM1353 robbins.fly@gmail.com 

BRCFORM1354 robbseg@gmail.com 

BRCFORM1355 robcberry@yahoo.com 

BRCFORM1356 robert.myrann@nabors.com 

BRCFORM1357 robert.sawhill@att.net 

BRCFORM­ robert@santaluciaengineerin 

1358 g.com 

BRCFORM1359 robertkopka@sbcglobal.net 

BRCFORM1360 robincolo@yahoo.com 

BRCFORM1361 robrael@garlic.com 

BRCFORM1362 rockn785@yahoo.com 

BRC­ rockymandeville@yahoo.co 

FORM- m 

1363 

BRCFORM1364 roctoy4fun@yahoo.com 

BRCFORM­ rodriguez_ben4@hotmail.co 

1365 m 

BRCFORM1366 rodseney@yahoo.com 

BRCFORM1367 roger.boisjolie@c-a-m.com 

BRCFORM1368 rogerz_1000@hotmail.com 

BRCFORM1369 rokalo@charter.net 

BRCFORM1370 rolinirn@verizon.net 

BRCFORM1371 rollerclutch@sbcglobal.net 

BRCFORM­ ROM8V38AND39@GMAI 

1372 L.COM 

BRCFORM1373 ron.larkin@comcast.net 

BRCFORM­ ron.sobchik@gmail.com 

1374 

BRCFORM1375 rona@smith-valley.com 

BRCFORM1376 ronday@comcast.net 

BRCFORM1377 ronedmcg@sbcglobal.net 

BRCFORM1378 ronklx400@gmail.com 

BRCFORM1379 ronwestberg@gmail.com 

BRCFORM1380 roons@mindspring.com 

BRCFORM1381 rootxxxx@yahoo.com 

BRCFORM1382 ross.jennings@comcast.net 

BRCFORM1383 rossross139@yahoo.com 

BRCFORM1384 roverflooring@yahoo.com 

BRCFORM­ rowdyhulse@yahoo.com 

515
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1385 

BRCFORM1386 roy@stonehamrepair.com 

BRCFORM1387 royfur@yahoo.com 

BRCFORM1388 royg42@msn.com 

BRCFORM1389 rpmjls@yahoo.com 

BRCFORM­ rpmperformance@hotmail.c 

1390 om 

BRCFORM­ rradiobutton300@embarqma 

1391 il.com 

BRCFORM1392 rsbriglia@charter.net 

BRCFORM1393 rsolis@jps.net 

BRCFORM1394 rsrider@sbcglobal.net 

BRCFORM1395 rstruhm@aol.com 

BRCFORM­ rtisky@yahoo.com 

1396 

BRCFORM­ rubiksrubiksrubiks@hotmail. 

1397 com 

BRCFORM1398 ruger284@msn.com 

BRCFORM1399 rw254q@gmail.com 

BRCFORM1400 rwallaceconst@hotmail.com 

BRCFORM1401 rwbereman@charter.net 

BRCFORM1402 rwilson1906@att.net 

BRCFORM1403 rwisted@aol.com 

BRCFORM1404 rx713bt@yahoo.com 

BRCFORM1405 Ryan.byrkit@sbcglobal.net 

BRCFORM1406 ryan@tcbonding.com 

BRCFORM­ ryanmeith@gmail.com 

1407 

BRCFORM1408 ryanrmail-cl@yahoo.com 

BRCFORM­ ryanscustomwork@roadrunn 

1409 er.com 

BRCFORM1410 rydnskyhigh@aol.com 

BRCFORM1411 rynderss@netzero.net 

BRCFORM1412 rzr@windstream.net 

BRCFORM1413 s.e.thomas@sbcglobal.net 

BRCFORM1414 s.keables@att.net 

BRCFORM1415 s.m.chambers@cox.net 

BRCFORM1416 s2m0@yahoo.com 

BRCFORM1417 saarem@sbcglobal.net 

BRCFORM­ sabaj@pacbell.net 

516
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1418 

BRCFORM1419 sacirish@yahoo.com 

BRCFORM1420 saljr@gec-jss.com 

BRCFORM1421 sam@admo-tours.com 

BRCFORM­ Sam@RiverBlossomJade.co 

1422 m 

BRCFORM1423 sandnutz5@yahoo.com 

BRCFORM1424 sandraplasse@hotmail.com 

BRCFORM1425 sasha@setthemfree.com 

BRCFORM1426 savant@elisd.org 

BRCFORM1427 savant237@gmail.com 

BRCFORM1428 savethetrails@groves.be 

BRC- savethetrails@number88.co 

FORM- m 

1429 

BRCFORM1430 scallywag1@sbcglobal.net 

BRCFORM1431 SCH2530@sbsheriff.org 

BRCFORM1432 schidel@msn.com 

BRCFORM1433 schoep29s@hotmail.com 

BRCFORM1434 scmrider@gmail.com 

BRCFORM­ scobb.spservices@yahoo.co 

1435 m 

BRCFORM1436 scody049@cox.net 

BRCFORM- Scott Cunningham 

1437 <scottcunningham@att.net> 

BRCFORM­ scott.fleming@pcexploration 

1438 .com 

BRCFORM1439 scott.halbleib@shps.com 

BRCFORM­ scott.rose@beis.com 

1440 

BRCFORM1441 scott@myrsdoor.com 

BRCFORM1442 scott@scottsonline.com 

BRCFORM1443 scottcunningham@att.net 

BRCFORM1444 scottgri@comcast.net 

BRCFORM1445 scottmain@hotmail.com 

BRCFORM1446 scoutdog1@hotmail.com 

BRCFORM­ SCRAA@SBCGLOBAL.NE 

1447 T 

BRCFORM1448 sdanville@rivcoda.org 

BRCFORM1449 sdeeke@corrpro.com 

BRCFORM1450 sdr0612@ckt.net 

BRCFORM­ seancecil@comcast.net 

517
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1451 

BRCFORM1452 seancolleen@gmail.com 

BRCFORM1453 seanmcwhirr14@yahoo.com 

BRCFORM1454 sebas01@gmail.com 

BRCFORM1455 serickson32@comcast.net 

BRCFORM­ Sethboarder2000@hotmail.c 

1456 om 

BRCFORM1457 sfevents2003@yahoo.com 

BRCFORM1458 sgrady41@aol.com 

BRCFORM1459 shane.rucker@yahoo.com 

BRCFORM1460 shanna3000@aol.com 

BRCFORM1461 sharid5@yahoo.com 

BRCFORM­ sharonqvs@aol.com 

1462 

BRCFORM1463 shaunkclark@hotmail.com 

BRCFORM­ shawn.strickland3@gmail.co 

1464 m 

BRCFORM1465 shawnback@sbcglobal.net 

BRCFORM1466 shawncapitani@yahoo.com 

BRCFORM1467 sheetsracing450@yahoo.com 

BRCFORM1468 sheppardbill@gmail.com 

BRCFORM1469 shooter080803@msn.com 

BRCFORM1470 sierraktm@gmail.com 

BRCFORM1471 sierratreecare@sbcglobal.net 

BRCFORM1472 signworks220@yahoo.com 

BRC­ SILVERSTARINDUSTRIE 

FORM­ S@YAHOO.COM 

1473 

BRCFORM1474 simboticus@yahoo.com 

BRCFORM1475 SIMPORTHO@yahoo.com 

BRCFORM1476 simsfamilyidaho@msn.com 

BRCFORM1477 sirsparki@yahoo.com 

BRCFORM1478 sjkls@yahoo.com 

BRCFORM1479 sjturner66@gmail.com 

BRCFORM1480 skenney1@charter.net 

BRCFORM1481 skibz@earthlink.net 

BRCFORM1482 skion@sbcglobal.net 

BRCFORM1483 Skipnkerry@aol.com 

BRCFORM­ skipsatc@sbcglobal.net 

518
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1484 

BRC- Sky 

FORM­ Murphy/CASO/CA/BLM/D 

1485 OI 

BRCFORM1486 slocustomworks@aol.com 

BRCFORM1487 slyko@comcast.net 

BRCFORM1488 smoqetr@roadrunner.com 

BRCFORM1489 smracing@verizon.net 

BRCFORM1490 sms@sierramotorsports.com 

BRCFORM1491 smuehler@yahoo.com 

BRCFORM1492 snotrans@verizon.net 

BRCFORM1493 snow6328@hotmail.com 

BRCFORM1494 sobiloff@gmail.com 

BRCFORM­ socalvc@aol.com 

1495 

BRCFORM1496 soccerloco@msn.com 

BRCFORM1497 sod2007@gmail.com 

BRCFORM1498 soldout1998@yahoo.com 

BRCFORM1499 soyrico69@hotmail.com 

BRCFORM1500 Spetz762@gmail.com 

BRCFORM1501 spicerkeith@hotmail.com 

BRCFORM1502 spodoll@csu.org 

BRCFORM1503 spraylinem@aol.com 

BRCFORM1504 springer_greg@sbcglobal.net 

BRCFORM1505 sproatal@yahoo.com 

BRCFORM­ srenz@surewest.net 

1506 

BRCFORM1507 srmjk@bellsouth.net 

BRCFORM1508 srw1980@comcast.net 

BRCFORM1509 ssboardman@yahoo.com 

BRCFORM1510 sschutz1911@gmail.com 

BRCFORM1511 sssmaly@msn.com 

BRCFORM1512 st4gary@hotmail.com 

BRCFORM1513 stadden440@yahoo.com 

BRCFORM1514 steamin_orange@yahoo.com 

BRC- Steigmeyer, Bruce 

FORM­ <bruce.steigmeyer@lmco.co 

1515 m> 

BRCFORM­ stephbrad3803@sbcglobal.n 

1516 et 

BRCFORM­ stephen.hall@ars.usda.gov 

519
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1517 

BRCFORM­ stephen_peppa@sbcglobal.n 

1518 et 

BRCFORM­ stephencjackson@yahoo.co 

1519 m 

BRCFORM­ steve@americanwatertech.co 

1520 m 

BRCFORM1521 steve_surber@ajg.com 

BRCFORM1522 steve92672@gmail.com 

BRCFORM1523 steven@heat-tech.com 

BRCFORM1524 steven@motionpro.com 

BRCFORM1525 steveo@pca-nocal.com 

BRCFORM1526 steve-o@usa.net 

BRCFORM1527 stevewr426@comcast.net 

BRCFORM­ stewart316q@yahoo.com 

1528 

BRCFORM1529 sthomas10@hotmail.com 

BRCFORM­ stovertileanddesign@charter. 

1530 net 

BRCFORM1531 stovetop18@yahoo.com 

BRCFORM1532 stoyo1@mac.com 

BRCFORM1533 sts475@gmail.com 

BRCFORM1534 stuartfrazer@hotmail.com 

BRCFORM1535 suehop@pacbell.net 

BRCFORM1536 superdave496@yahoo.com 

BRCFORM­ superloopersandy@gmail.co 

1537 m 

BRCFORM1538 supermotobrok@aol.com 

BRCFORM­ surfer1100@gmail.com 

1539 

BRCFORM1540 susanandkato@yahoo.com 

BRCFORM­ susanlynnbrown@hotmail.co 

1541 m 

BRCFORM1542 suzi.rider@verizon.net 

BRCFORM1543 swannerdon@earthlink.net 

BRCFORM1544 sweet41k@aol.com 

BRCFORM- swobber@great1545 northwest.com 

BRCFORM1546 swood2500@gmail.com 

BRCFORM1547 sydugan@comcast.net 

BRCFORM1548 synergyseals@yahoo.com 

BRCFORM- T_L_McDowell@yahoo.co 

1549 m 

BRCFORM- ta56@coastside.net 

520
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1550 

BRCFORM1551 tad4646@yahoo.com 

BRCFORM1552 tahoetwins1965@yahoo.com 

BRCFORM1553 tajohnson421@hotmail.com 

BRCFORM1554 talkalot25@sbcglobal.net 

BRCFORM1555 talya@talyadodson.com 

BRCFORM1556 tamhes@charter.net 

BRCFORM1557 taniashannon@hotmail.com 

BRCFORM1558 tankdeelux@hotmail.com 

BRCFORM1559 tapermarkh@comcast.net 

BRCFORM1560 taryn_marie85@yahoo.com 

BRC­ TAYZHOUSE@YAHOO.C 

FORM­ OM 

1561 

BRCFORM1562 tb437w@sbcglobal.net 

BRCFORM1563 TBunch@cocc.edu 

BRCFORM1564 tcullen1@ix.netcom.com 

BRCFORM1565 tddowns@dstoutput.com 

BRCFORM1566 teaduck@gmail.com 

BRCFORM1567 telges@sbcglobal.net 

BRCFORM1568 telliott68@gmail.com 

BRCFORM1569 terrance.bailey@us.army.mil 

BRCFORM1570 terri@motionpro.com 

BRCFORM1571 terrycaldw@aol.com 

BRCFORM­ terryroseman@sbcglobal.net 

1572 

BRCFORM1573 tgswierk@gmail.com 

BRCFORM1574 tguidice@sbcglobal.net 

BRCFORM1575 the_dominat0r@yahoo.com 

BRCFORM1576 thebrougher@sbcglobal.net 

BRCFORM1577 theehunt1@aol.com 

BRCFORM1578 thefriar@comcast.net 

BRCFORM1579 thegemsmith@msn.com 

BRCFORM1580 theloanpro@yahoo.com 

BRCFORM1581 therockstar109@yahoo.com 

BRCFORM1582 theruizclan@sbcglobal.net 

BRCFORM­ thespaguy@yahoo.com 

521
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1583 

BRCFORM1584 theyoungs@gbis.com 

BRCFORM1585 thingbb@yahoo.com 

BRCFORM1586 thmterry@hotmail.com 

BRCFORM1587 thoffer2000@yahoo.com 

BRCFORM- Thomas Neu 

1588 <tjneu@sbcglobal.net> 

BRCFORM1589 thomas.freda@norfolk.gov 

BRCFORM- thomas.phuong.hamilton@us 

1590 .army.mil 

BRCFORM1591 thomperxb@comcast.net 

BRCFORM1592 thooten1@woh.rr.com 

BRCFORM1593 thorflooring@gmail.com 

BRCFORM­ thorne.parker@gmail.com 

1594 

BRCFORM­ thrillseeker97216@yahoo.co 

1595 m 

BRCFORM1596 tibguys@yahoo.com 

BRCFORM1597 ticke2110@yahoo.com 

BRCFORM1598 tiera@sbcglobal.net 

BRCFORM1599 tim@norcalsystem.com 

BRCFORM1600 timlopezondirt@yahoo.com 

BRCFORM1601 timothyG2@aol.com 

BRCFORM1602 timpilg@gmail.com 

BRCFORM1603 timscruse@gmail.com 

BRCFORM1604 timsfastgoat@comcast.net 

BRCFORM­ timtbess@gmail.com 

1605 

BRCFORM1606 timtcfp@aol.com 

BRCFORM1607 timxr650l@frontiernet.net 

BRCFORM1608 tinone1@prodigy.net 

BRCFORM1609 tiptop41@hotmail.com 

BRCFORM1610 tis_2001@yahoo.com 

BRCFORM1611 tjacinto@usa.com 

BRCFORM1612 tjcjr61@sbcglobal.net 

BRCFORM1613 tjcjr61@sbcglobal.net 

BRCFORM1614 tjerrilds@sbcglobal.net 

BRCFORM1615 tjneu@sbcglobal.net 

BRCFORM­ tjranch@att.net 

522
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1616 

BRCFORM1617 tleacu@yahoo.com 

BRCFORM1618 Tlf163@yahoo.com 

BRCFORM1619 tm400cyclone@yahoo.com 

BRCFORM1620 tmac@lemoorenet.com 

BRCFORM1621 tmluigi@att.net 

BRCFORM1622 tmnln55@yahoo.com 

BRCFORM1623 tnm525@hotmail.com 

BRCFORM1624 toby@motionpro.com 

BRCFORM1625 toddemt@hotmail.com 

BRCFORM1626 toddmohr@sbcglobal.net 

BRCFORM­ tom.martin.sna@gmail.com 

1627 

BRCFORM1628 tom@atis1.com 

BRCFORM1629 Tom@cut7.com 

BRCFORM1630 tom@securematics.com 

BRCFORM1631 tom@xlsix.com 

BRCFORM1632 tonygiotta@hotmail.com 

BRCFORM1633 tonyjsmith03@yahoo.com 

BRCFORM1634 tonyl1970@yahoo.com 

BRCFORM1635 tonytug@yahoo.com 

BRCFORM1636 tootall424@gmail.com 

BRCFORM1637 TOYOTADEN@AOL.COM 

BRCFORM­ toyrunner7031@gmail.com 

1638 

BRCFORM1639 tparle@roadrunner.com 

BRCFORM1640 tperasco@hotmail.com 

BRCFORM1641 tpyzer@juno.com 

BRCFORM1642 traceejcee@sbcglobal.net 

BRCFORM1643 trailfolk@q.com 

BRCFORM1644 travismann@hotmail.com 

BRCFORM1645 trdrak01@msn.com 

BRCFORM1646 Triumphmaster@aol.com 

BRCFORM1647 TrojanFanBart@msn.com 

BRCFORM1648 troy.bartle@navy.mil 

BRCFORM­ trunyard@inreach.com 

523
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1649 

BRCFORM1650 tsmotoup@yahoo.com 

BRCFORM1651 ttracer14@aol.com 

BRCFORM1652 turbondr@aol.com 

BRCFORM1653 twhitey10@yahoo.com 

BRCFORM1654 twisz@verizon.net 

BRCFORM1655 twnty4jg@msn.com 

BRCFORM1656 tws70@hotmail.com 

BRCFORM1657 txcrlb@gmail.com 

BRCFORM1658 tythew19@msn.com 

BRCFORM1659 uncajimm@sbcglobal.net 

BRCFORM­ unibrow5150@hotmail.com 

1660 

BRCFORM1661 unome831@hotmail.com 

BRCFORM1662 Unravels@gmail.com 

BRCFORM1663 unreng@hotmail.com 

BRCFORM1664 urbantrash@comcast.net 

BRCFORM1665 urclever_1@yahoo.com 

BRCFORM1666 utahdesertfox@msn.com 

BRCFORM1667 v8petty@sbcglobal.net 

BRCFORM1668 vaninnv@juno.com 

BRCFORM1669 veedubgti@hotmail.com 

BRCFORM1670 velo333@sbcglobal.net 

BRCFORM­ vetmxracer@yahoo.com 

1671 

BRCFORM1672 Vince_m_97@yahoo.com 

BRCFORM1673 vinnyl26@yahoo.com 

BRCFORM­ Volumemachine@socal.rr.co 

1674 m 

BRCFORM1675 vx3@directcon.net 

BRCFORM1676 wagner_gary@sbcglobal.net 

BRCFORM1677 waldopepper66@cox.net 

BRCFORM­ wannabjeepin@miataman.co 

1678 m 

BRCFORM1679 wardalexandro@yahoo.com 

BRCFORM1680 washhouse@sbcglobal.net 

BRCFORM1681 waspain@aol.com 

BRCFORM­ wassonsj@yahoo.com 

524
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1682 

BRCFORM1683 watu@comcast.net 

BRCFORM1684 wayne.halozan@comcast.net 

BRCFORM1685 waynenowak@sbcglobal.net 

BRCFORM1686 wbeams@innovativesd.net 

BRCFORM1687 wblack8709@msn.com 

BRCFORM1688 wbunt@netscape.com 

BRCFORM1689 wchirichigno@hotmail.com 

BRCFORM1690 wdeutsch@pqbon.com 

BRCFORM­ wendy@missionmotorcycles 

1691 .com 

BRCFORM1692 wendy_aparton@yahoo.com 

BRCFORM­ wheelie-king@hotmail.com 

1693 

BRCFORM1694 whighfill@comcast.net 

BRCFORM1695 whitedd99@aol.com 

BRCFORM­ WILL@OMNIASALESINC 

1696 .COM 

BRCFORM1697 william.g.munson@navy.mil 

BRCFORM1698 william@atis1.com 

BRCFORM1699 windersaz@yahoo.com 

BRCFORM1700 windowguru@earthlink.net 

BRCFORM1701 wizo@wildblue.net 

BRCFORM1702 WM_FIX@YAHOO.COM 

BRCFORM1703 wolfiee831@gmail.com 

BRCFORM­ WoodsChick@comcast.net 

1704 

BRCFORM1705 wrays@sbcglobal.net 

BRCFORM1706 writenelson@hotmail.com 

BRCFORM1707 wrward812@hotmail.com 

BRCFORM1708 wscottd@hotmail.com 

BRCFORM1709 wtrskinut@yahoo.com 

BRCFORM1710 wwcharles@comcast.net 

BRCFORM1711 wwdixonjr@yahoo.com 

BRCFORM1712 wyannel@yahoo.com 

BRCFORM1713 wyatt511@yahoo.com 

BRCFORM1714 wymanracing@clearwire.net 

BRCFORM­ xlbigrocks@yahoo.com 

525
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1715 

BRCFORM1716 xr250rdr@gmail.com 

BRCFORM1717 

YAMAZATTR@HOTMAIL 

.COM 

BRCFORM1718 yoabbott59z@gmail.com 

BRCFORM1719 yozeppi@sbcglobal.net 

BRCFORM1720 yubamike@sbcglobal.net 

BRCFORM1721 yz426tony@yahoo.com 

BRCFORM1722 Zackatk10@yahoo.com 

BRCFORM1723 zeberj@sbcglobal.net 

BRCFORM1724 zerbe2000@yahoo.com 

BRCFORM1725 zgoose@sbcglobal.net 

BRCFORM­ zigmx614@hotmail.com 

1726 

BRCFORM1727 zipbeers13@verizon.net 

BRCFORM1728 zmanjames@verizon.net 

BRCFORM1729 zpartshouse@yahoo.com 

526
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Center for Biological Diversity Form 

Letter 

Comment 

Code Commenter 

CBD-FORM01 A Davis 

CBD-FORM02 A Lotsch 

CBD-FORM03 A R 

CBD-FORM04 A. Guderian 

CBD-FORM05 A. Iturrioz 

CBD-FORM06 A. Rhodes 

CBD-FORM07 A. S. Evans 

CBD-FORM08 A.E. White 

CBD-FORM09 aa f 

CBD-FORM10 Aaeron Robb 

CBD-FORM11 Aaron Ucko 

CBD-FORM12 Aaron Ximm 

CBD-FORM13 Abby Bline 

CBD-FORM14 Abigail Gindele 

CBD-FORM15 Adam Brazil 

CBD-FORM16 Adam D'Onofrio 

CBD-FORM17 Adam Hopkins 

CBD-FORM18 Adam Izak-Sunna 

CBD-FORM19 Adam Sloan 

CBD-FORM20 Adam Stipano 

CBD-FORM21 Addie Smock 

CBD-FORM22 adene katzenmeyer 

CBD-FORM23 Adina Parsley 

CBD-FORM24 adora lee 

CBD-FORM25 adrian stubblefield 

CBD-FORM26 Adrianne Vasey 

CBD-FORM27 Adrienne Dollyhigh 

CBD-FORM28 Adrienne Saddler 

CBD-FORM29 agela r 

CBD-FORM30 Aileen O'Brien < 

CBD-FORM- Aimee Gintz 

31 

CBD-FORM32 aj pierre-louis 

CBD-FORM33 Akebono Airth 

CBD-FORM34 Akira Asada 

CBD-FORM35 Al Anderson 

CBD-FORM36 Al Eastman 

CBD-FORM37 Alan Bailey 

CBD-FORM38 Alan Blixt 

CBD-FORM39 Alan Fawley 

CBD-FORM40 Alan J Nishman 

CBD-FORM41 Alan Jasper 

CBD-FORM42 Alan Somers 

CBD-FORM43 Alan Wojtalik 

CBD-FORM44 Alana Davis 

CBD-FORM45 Albert Fecko 

CBD-FORM46 Albert Jenkins 

CBD-FORM47 Albert Minugh 

527
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM48 Alberta Householder 

CBD-FORM49 alberto moryusef israel 

CBD-FORM50 Aleata Illusion 

CBD-FORM51 Alejandra Vega 

CBD-FORM52 Alejandro Munoz 

CBD-FORM53 Aleksandra Cieslak 

CBD-FORM- Alessander Botti 

54 Benevides 

CBD-FORM55 Alessandro Zabini 

CBD-FORM56 Alex Balboa 

CBD-FORM57 Alex Dillard 

CBD-FORM58 Alexander Wilson 

CBD-FORM59 Alexandra Campbell 

CBD-FORM60 Alexandra Eaton 

CBD-FORM61 Alexandra Scarborough 

CBD-FORM62 Alexandra Sipiora 

CBD-FORM63 Alexandra Sweitzer 

CBD-FORM- Ali Hotmer 

64 

CBD-FORM65 Alice Green 

CBD-FORM66 Alice Keyes 

CBD-FORM67 Alicia Liang 

CBD-FORM68 Alicia Williams 

CBD-FORM69 Alicia Williams 

CBD-FORM70 Alicie Warren 

CBD-FORM71 alikona bradford 

CBD-FORM72 alina dollat 

CBD-FORM73 Alisa Polk 

CBD-FORM74 Alison Halm 

CBD-FORM75 Alison Lake 

CBD-FORM76 Alison Tyler 

CBD-FORM77 Alison Voss 

CBD-FORM78 Alixine Sasonoff 

CBD-FORM79 Allison Farber 

CBD-FORM80 Allison Frymoyer 

CBD-FORM81 allison golden 

CBD-FORM82 Allison Pierce 

CBD-FORM83 allison saft 

CBD-FORM84 Alonna Johnson 

CBD-FORM85 Alta Bardsley 

CBD-FORM86 Alva Crom 

CBD-FORM87 Alys G 

CBD-FORM88 Alyssa Freeman 

CBD-FORM89 Amanda Clairmonte 

CBD-FORM90 Amanda Layton 

CBD-FORM91 Amanda Levesque 

CBD-FORM92 Amanda Lowe 

CBD-FORM93 Amanda Lowe 

CBD-FORM94 Amanda Pekin 

CBD-FORM95 Amanda Reed 

CBD-FORM96 Amanda Stahl 

CBD-FORM- Amber Dudkowski 

528
 
 

 

 

 

 

 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

97 

CBD-FORM98 AMBER GILCHRIST 

CBD-FORM99 AMBER TASCHNER 

CBD-FORM100 Ambrey Nichols 

CBD-FORM101 ami ringler 

CBD-FORM102 Amitav Dash 

CBD-FORM103 Amy Anderson 

CBD-FORM104 Amy Bergmann 

CBD-FORM105 Amy BIggs 

CBD-FORM106 Amy Bostick 

CBD-FORM107 Amy Cervene 

CBD-FORM108 amy frieden 

CBD-FORM109 Amy Hettrick 

CBD-FORM110 Amy Lidle 

CBD-FORM111 Amy Schumacher 

CBD-FORM112 Amy Snyder 

CBD-FORM113 Amy Spade Silverman 

CBD-FORM114 amy wold 

CBD-FORM115 Ana Aranguren 

CBD-FORM116 Ana Bulnes 

CBD-FORM117 Ana Lee 

CBD-FORM118 AnaLisa Crandall 

CBD-FORM119 Andrea Levy 

CBD-FORM120 Andrea Pike 

CBD-FORM121 Andrea Todd 

CBD-FORM122 Andrew Arneson 

CBD-FORM123 Andrew Arneson 

CBD-FORM124 Andrew Bezella 

CBD-FORM125 Andrew Ewald 

CBD-FORM126 Andrew Kurzweil 

CBD-FORM127 andrew merlin 

CBD-FORM128 Andrew Phillips 

CBD-FORM129 Andrew Sutphin 

CBD-FORM- Andrew Tate 

130 

CBD-FORM131 Andrew Wadsworth 

CBD-FORM132 Andrew Warren 

CBD-FORM133 Andrew Zugay 

CBD-FORM134 Andy Philpot 

CBD-FORM135 Angela Beverly 

CBD-FORM136 Angela Black 

CBD-FORM137 Angela Eads 

CBD-FORM138 Angela Elniski 

CBD-FORM139 angela Fazzari 

CBD-FORM140 Angela Katsavavakis 

CBD-FORM141 angela porsch 

CBD-FORM142 Angelette Taylor 

CBD-FORM143 Angeline Zalben 

CBD-FORM144 angelo spano 

CBD-FORM145 angus m macdonald 

CBD-FORM146 Angyl Wisemessenger 

529
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM147 Anita Braddock 

CBD-FORM148 Anita Das 

CBD-FORM149 Anita Ilika 

CBD-FORM150 Ann Bartell 

CBD-FORM151 Ann Eppler 

CBD-FORM152 Ann Green 

CBD-FORM153 Ann Hickox 

CBD-FORM154 Ann Kinney 

CBD-FORM155 Ann Little 

CBD-FORM156 Ann McMullen 

CBD-FORM157 Ann Meyette 

CBD-FORM158 Ann Nowicki 

CBD-FORM159 Ann Prentice 

CBD-FORM160 Ann Waller 

CBD-FORM161 Anna Bernath 

CBD-FORM162 Anna Galanos 

CBD-FORM­ anna hill 

163 

CBD-FORM164 Anna Paz 

CBD-FORM165 Anna Rol 

CBD-FORM166 Anna Stone 

CBD-FORM167 Anna Stoudemire 

CBD-FORM168 annalisa ostehout 

CBD-FORM169 Anne Bornholdt 

CBD-FORM170 Anne Campbell 

CBD-FORM171 Anne Ramsey 

CBD-FORM172 Anne White 

CBD-FORM173 Anne-Marie Hewitt 

CBD-FORM174 Annette Grohman 

CBD-FORM175 annette guerrero 

CBD-FORM176 annick baud 

CBD-FORM177 Annie McMahon 

CBD-FORM178 Anthe Chatzidimitriou 

CBD-FORM179 Anthony Antich 

CBD-FORM180 Anthony Capobianco 

CBD-FORM181 Anthony Mendousa 

CBD-FORM182 Anthony Montapert 

CBD-FORM183 Antonella Nielsen 

CBD-FORM184 Anu Garg 

CBD-FORM185 April Atwood 

CBD-FORM186 April Downing 

CBD-FORM187 April Ewaskey 

CBD-FORM188 April Jacob 

CBD-FORM189 April Jean-Baptiste 

CBD-FORM190 april mosen 

CBD-FORM191 Apryl Mefford-Hemauer 

CBD-FORM192 arlene dreste 

CBD-FORM193 Arlene Malkin 

CBD-FORM194 Arlene Naranjo 

CBD-FORM195 arnold martelli 

CBD-FORM- Aron Shevis 

530
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

196 

CBD-FORM197 aron shevis 

CBD-FORM198 aron shevis 

CBD-FORM199 Art Greenwalt 

CBD-FORM200 art shervs 

CBD-FORM201 Arthur Lapite 

CBD-FORM202 Arthur Swers 

CBD-FORM203 Artineh Havan 

CBD-FORM204 Ashley Coburn 

CBD-FORM205 Ashley Falkenstein 

CBD-FORM206 Ashley Tose 

CBD-FORM207 Astrid Keup 

CBD-FORM208 Athena Batsios 

CBD-FORM209 Athena Miller 

CBD-FORM210 Atticus Tayar 

CBD-FORM211 Aubrey Wulfsohn 

CBD-FORM212 Audra Harding 

CBD-FORM213 Audra Moricca 

CBD-FORM214 Audrey Meade 

CBD-FORM215 Audrey Smith 

CBD-FORM216 Audrey Tillinghast 

CBD-FORM217 Austin Frost 

CBD-FORM218 Autumn Skye Rath 

CBD-FORM219 b c 

CBD-FORM- Barbara & Vincent 

220 Smolinski 

CBD-FORM221 Barbara Bennigson 

CBD-FORM222 Barbara Bills 

CBD-FORM223 Barbara Borden 

CBD-FORM224 Barbara Carpenter 

CBD-FORM225 Barbara Carrera 

CBD-FORM226 Barbara Deleebeeck 

CBD-FORM227 Barbara Feild 

CBD-FORM228 Barbara Good 

CBD-FORM- Barbara Holtz 

229 

CBD-FORM230 Barbara Huggins 

CBD-FORM231 Barbara Leland 

CBD-FORM232 Barbara Lester 

CBD-FORM233 Barbara McClain 

CBD-FORM234 Barbara Rosenkotter 

CBD-FORM235 barbara russo-salcines 

CBD-FORM236 Barbara Searles 

CBD-FORM237 barbara simon 

CBD-FORM238 Barbara Tetro 

CBD-FORM239 Barbara Tucker 

CBD-FORM240 Barbara Tucker 

CBD-FORM241 Barbara Ward 

CBD-FORM242 Barry Lerner 

CBD-FORM243 Barry Moore 

CBD-FORM244 Barry Zuckerman 

CBD-FORM245 Basey Klopp 

531
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM246 Beate Nilsen 

CBD-FORM247 Becky Farhar 

CBD-FORM248 Becky REdgrift 

CBD-FORM249 Bela Johnson 

CBD-FORM250 Ben Reiss 

CBD-FORM251 Ben Ruwe 

CBD-FORM252 Ben Thomas 

CBD-FORM253 Benita Crow 

CBD-FORM254 Benjamin Reynolds 

CBD-FORM255 Benjamin Schlumpp 

CBD-FORM256 Bernadette Payne 

CBD-FORM257 bernard hochendoner 

CBD-FORM258 Beth Beck 

CBD-FORM259 Beth Cole 

CBD-FORM260 Beth Patterson 

CBD-FORM261 Beth Prudden 

CBD-FORM- Beth Ryan 

262 

CBD-FORM263 Bettie Paradis 

CBD-FORM264 Betty J. Van Wicklen 

CBD-FORM265 betty kish 

CBD-FORM266 Betty Walters 

CBD-FORM267 Beverlee Goynes 

CBD-FORM268 Beverley Henderson 

CBD-FORM269 Beverly Barth 

CBD-FORM270 Beverly Conway 

CBD-FORM271 Beverly Pott 

CBD-FORM272 Bill Haskins 

CBD-FORM273 Bill Herrera 

CBD-FORM274 bill nierstedt 

CBD-FORM275 bill Slowinski 

CBD-FORM276 Bill Tkach 

CBD-FORM277 Bill Weber 

CBD-FORM- Bob and Carolyn 

278 Primiano 

CBD-FORM279 Bob Brister 

CBD-FORM280 Bob Haugen 

CBD-FORM281 Bobbie Flowers 

CBD-FORM282 bobbie kraft 

CBD-FORM283 Bobbie Murray 

CBD-FORM284 Bonnie Barfield 

CBD-FORM285 bonnie jay 

CBD-FORM286 Bonnie Kelchner-Bunn 

CBD-FORM287 Bonnie Schauer 

CBD-FORM288 bonnie spromberg 

CBD-FORM289 Boyce Sherwin 

CBD-FORM290 brad lagorio 

CBD-FORM291 Brad Martin 

CBD-FORM292 Bradley Eardley 

CBD-FORM293 Brandi McCauley 

CBD-FORM294 Brenda Colbert 

CBD-FORM- Brenda Tarkowski 

532
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

295 

CBD-FORM296 Brenda Troup 

CBD-FORM297 brendan fisher 

CBD-FORM298 Brendan Hughes 

CBD-FORM299 Brent Koenig 

CBD-FORM300 Brent Naylor 

CBD-FORM301 Brian & Rita Cohen 

CBD-FORM302 Brian Cumber 

CBD-FORM303 Brian Fink 

CBD-FORM304 Brian Flores 

CBD-FORM305 Brian Gallagher 

CBD-FORM306 Brian Gong 

CBD-FORM307 Brian Houser 

CBD-FORM308 Brian Krahmer 

CBD-FORM309 Brian Kummer 

CBD-FORM310 brian yanke 

CBD-FORM311 brianna Frachtman 

CBD-FORM312 Brianne Costello 

CBD-FORM313 Bridget Greuel 

CBD-FORM314 Brie Schmidt 

CBD-FORM315 Brittany Allison 

CBD-FORM316 Brittany B 

CBD-FORM317 Brittany Cardon 

CBD-FORM318 Brittany Dolan 

CBD-FORM319 Brittany Porter 

CBD-FORM320 Brooke Harris 

CBD-FORM321 Brookie Judge 

CBD-FORM322 Bruce Fraley 

CBD-FORM323 BRUCE OLIVER 

CBD-FORM324 bruce pedersen 

CBD-FORM325 Bruce Randall 

CBD-FORM326 Bryan Bergstrand 

CBD-FORM327 Bryan Tarbox 

CBD-FORM- Bryan VanDuinen 

328 

CBD-FORM329 C C Churilla 

CBD-FORM330 C E Blower 

CBD-FORM331 C Trumann 

CBD-FORM332 c wesley 

CBD-FORM333 C Ziffer 

CBD-FORM334 C. Cramer 

CBD-FORM335 C.A. Incze 

CBD-FORM336 Cailin Carlton 

CBD-FORM337 cal lash 

CBD-FORM338 Caleb Laieski 

CBD-FORM339 Cameron Barfield 

CBD-FORM340 Camile Kray 

CBD-FORM341 candace batten 

CBD-FORM342 Candace Godfrey 

CBD-FORM343 Candi Ausman 

CBD-FORM344 Candice Lowery 

533
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM345 Candice Lynn 

CBD-FORM346 Candice Paulus 

CBD-FORM347 Candiss Markowsky 

CBD-FORM348 candy rocha 

CBD-FORM349 Capri Starnes 

CBD-FORM350 Cara Gubrud 

CBD-FORM351 Caren Johnson 

CBD-FORM352 Carina Zevely 

CBD-FORM353 carl barton 

CBD-FORM354 Carla L 

CBD-FORM355 Carlene Delegal 

CBD-FORM356 Carlene Petty 

CBD-FORM357 Carlos Cabezud 

CBD-FORM358 Carlos Castro 

CBD-FORM359 Carlos Nunez 

CBD-FORM360 Carlos Oropeza 

CBD-FORM- Carly Clements Owens 

361 

CBD-FORM362 Carmen Bonilla-Jones 

CBD-FORM363 Carmen Druke 

CBD-FORM364 Carmen Ramirez Walker 

CBD-FORM365 Carmen Saenz-Harris 

CBD-FORM366 Carol Ann Sherratt 

CBD-FORM367 carol broll 

CBD-FORM368 Carol Collins 

CBD-FORM369 Carol Curtis 

CBD-FORM370 Carol Haddad 

CBD-FORM371 Carol Halliburton 

CBD-FORM372 Carol Hartzell 

CBD-FORM373 Carol Hatfield 

CBD-FORM374 Carol J Erickson 

CBD-FORM375 Carol Jarvie 

CBD-FORM376 Carol Joan Patterson 

CBD-FORM377 Carol Lake 

CBD-FORM378 Carol Metzger 

CBD-FORM379 Carol Minkus 

CBD-FORM380 Carol Mitchell 

CBD-FORM381 Carol Mortensen 

CBD-FORM382 Carol Patton 

CBD-FORM383 Carol Peterson 

CBD-FORM384 carol prost 

CBD-FORM385 Carol Rusk 

CBD-FORM386 Carol Simon 

CBD-FORM387 Carol Smith 

CBD-FORM388 Carol Steinhart 

CBD-FORM389 Carola Ebertz-Knop 

CBD-FORM390 Carole LaVigne 

CBD-FORM391 carole mark 

CBD-FORM392 Carole Mathews 

CBD-FORM393 Carole Plourde 

CBD-FORM- Carolyn Croom 

534
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

394 

CBD-FORM395 Carolyn Eden 

CBD-FORM396 Carolyn Friedman 

CBD-FORM397 Carolyn Moore 

CBD-FORM398 Carrie Daddow 

CBD-FORM399 Carrie Mack 

CBD-FORM400 Caryn Cowin 

CBD-FORM401 Caryn Graves 

CBD-FORM402 Cassie Holmgren 

CBD-FORM403 Cat Neshine 

CBD-FORM404 Catharine London 

CBD-FORM405 Catherine Berglund 

CBD-FORM406 Catherine Burns 

CBD-FORM407 Catherine Cerqua 

CBD-FORM408 Catherine Gauthier 

CBD-FORM409 catherine melvin 

CBD-FORM410 Catherine Williams 

CBD-FORM411 Cathleen Schmid 

CBD-FORM412 Cathryn Lee 

CBD-FORM413 Cathy Mathias 

CBD-FORM414 Cathy O'Leary Carey 

CBD-FORM415 Cathy Pyle 

CBD-FORM416 Cecelia Samp 

CBD-FORM417 Celeste Anacker 

CBD-FORM418 celeste chase 

CBD-FORM419 Celeste Wernz 

CBD-FORM420 chad mallett 

CBD-FORM421 Chad Zurko 

CBD-FORM422 Chantelle Loper 

CBD-FORM423 Charlene Boydston 

CBD-FORM424 Charlene Rush 

CBD-FORM425 charles & kathleen fitze 

CBD-FORM426 Charles Arnold 

CBD-FORM- Charles Calhoun 

427 

CBD-FORM428 Charles Lawson 

CBD-FORM429 Charles Muehlhof 

CBD-FORM430 Charles O'Keefe 

CBD-FORM431 Charles Schille, LICSW 

CBD-FORM432 Charley Wittman 

CBD-FORM433 Charlotte Sahnow 

CBD-FORM434 Charlotte Stahl 

CBD-FORM435 Charmanie White 

CBD-FORM436 Charmian larke 

CBD-FORM437 Charo Garcia 

CBD-FORM438 chas martin 

CBD-FORM439 Cheri Carlson 

CBD-FORM440 cheryl erb 

CBD-FORM441 Cheryl Fergeson 

CBD-FORM442 Cheryl Greenwald 

CBD-FORM443 Cheryl Pena 

535
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM444 Cheryl Spencer Scher 

CBD-FORM445 Cheryl Vallone 

CBD-FORM446 cHERYL yOUNG 

CBD-FORM447 Chet Thomas 

CBD-FORM448 Chiara Rizzo 

CBD-FORM449 Chiara Testi 

CBD-FORM450 Chris Carlon 

CBD-FORM451 Chris Casper 

CBD-FORM452 Chris Ecker 

CBD-FORM453 Chris Faton 

CBD-FORM454 Chris Jones 

CBD-FORM455 chris koerner 

CBD-FORM456 Chris Munton 

CBD-FORM457 Christa Babst 

CBD-FORM458 Christa Ippoliti 

CBD-FORM459 Christelle REGIS 

CBD-FORM- Christi DeMark 

460 

CBD-FORM461 Christianna Skoczek 

CBD-FORM462 Christie Robnett 

CBD-FORM463 Christina Babst 

CBD-FORM464 Christina Chen 

CBD-FORM465 Christina Faulk 

CBD-FORM466 christina little 

CBD-FORM467 Christina Luberto 

CBD-FORM468 Christina Marcus 

CBD-FORM469 Christina Rainer 

CBD-FORM470 Christina Williams 

CBD-FORM471 Christine Cape 

CBD-FORM472 Christine Engel 

CBD-FORM473 christine krumm 

CBD-FORM474 Christine Roane 

CBD-FORM475 Christine Thomas 

CBD-FORM476 Christine Thomas 

CBD-FORM477 Christophe Ouedec 

CBD-FORM478 Christopher Hopkins 

CBD-FORM479 Christopher Johnson 

CBD-FORM480 Christopher Kirchwey 

CBD-FORM481 Christopher Seymour 

CBD-FORM482 Christopher Walker 

CBD-FORM483 Christopher Warneke 

CBD-FORM484 Chuck Donegan 

CBD-FORM485 Chuck Graver 

CBD-FORM486 Chuck Wieland 

CBD-FORM487 Cigy Cyriac 

CBD-FORM488 Cindy Borske 

CBD-FORM489 Cindy McDaniel 

CBD-FORM490 Cindy Sims 

CBD-FORM491 Cindy Wargo 

CBD-FORM492 CJ Amoraal 

CBD-FORM­ cj jensen 

536
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

493 

CBD-FORM494 cj shafer 

CBD-FORM495 Clair Sweeney 

CBD-FORM496 Claire Chambers 

CBD-FORM497 Claire Kugelman-Kropp 

CBD-FORM498 Claire Marie Stancek 

CBD-FORM499 Claire Mikalson 

CBD-FORM500 claire phillips 

CBD-FORM501 Claire Raffaelli 

CBD-FORM502 Claire Wolfe 

CBD-FORM503 claire zabel 

CBD-FORM504 Clare hooson 

CBD-FORM505 clare mcCollam-Lewis 

CBD-FORM506 Claude Robert 

CBD-FORM507 Claudia Heilke 

CBD-FORM508 Claudia Karll 

CBD-FORM509 claudia parker 

CBD-FORM510 Colin Flood 

CBD-FORM511 colin hebert 

CBD-FORM512 COLLEEN BURKE 

CBD-FORM513 COLLEEN BURKE 

CBD-FORM514 Colleen McMullen 

CBD-FORM515 Collin Hein 

CBD-FORM516 Colonel Meyer 

CBD-FORM517 Connie Chambers 

CBD-FORM518 Connie Curnow 

CBD-FORM519 Connie Delk 

CBD-FORM520 Connie Raper 

CBD-FORM521 connor hocking 

CBD-FORM522 Conor Brian Scott 

CBD-FORM523 Conor Brian Scott 

CBD-FORM524 CONOR SORAGHAN 

CBD-FORM525 Constance A. Stinson 

CBD-FORM- Constance Morse 

526 

CBD-FORM527 Constance Pennington 

CBD-FORM528 Constantine Bogios 

CBD-FORM529 Coralie Benton 

CBD-FORM530 Corey Pane 

CBD-FORM531 Cori Bishop 

CBD-FORM532 Corie Benton 

CBD-FORM533 Corinne Chandless 

CBD-FORM- Corinne Louise 

534 Greenberg 

CBD-FORM535 Cornelia Rueckert 

CBD-FORM536 cort323@yahoo.com 

CBD-FORM537 Courtney Laves-Mearini 

CBD-FORM538 courtney lewis 

CBD-FORM539 Craig Downer 

CBD-FORM540 Cristina Gatti 

CBD-FORM541 Cristina Río Lópezc 

CBD-FORM542 Cristina Sommaruga 

537
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM543 Cristina Tirelli 

CBD-FORM544 Crystal Conklin 

CBD-FORM545 Cy Neu 

CBD-FORM546 Cynthia Arnold 

CBD-FORM547 Cynthia Essig 

CBD-FORM548 Cynthia Nord 

CBD-FORM549 Cynthia Norris 

CBD-FORM550 Cynthia Ortiz 

CBD-FORM551 Cynthia Patterson 

CBD-FORM552 Cynthia Roberson 

CBD-FORM553 Cynthia Upp 

CBD-FORM554 D C Harris 

CBD-FORM555 d.a. roy 

CBD-FORM556 Daire Seaman 

CBD-FORM557 Dale Barclay 

CBD-FORM558 dale riehart 

CBD-FORM- Dan Brook 

559 

CBD-FORM560 Dan Esposito 

CBD-FORM561 Dan Matthews 

CBD-FORM562 Dan Meier 

CBD-FORM563 dan sandman 

CBD-FORM564 Dan Singer 

CBD-FORM565 Dan/Paula Fogarty 

CBD-FORM566 Dana Bleckinger 

CBD-FORM567 dana gurley 

CBD-FORM568 Daniel Arther 

CBD-FORM569 Daniel Belachew 

CBD-FORM570 daniel greider 

CBD-FORM571 Daniel Senic 

CBD-FORM572 Daniel Soulas 

CBD-FORM573 Daniel Tiarks 

CBD-FORM574 Daniel Wiese 

CBD-FORM575 danielle hyatt 

CBD-FORM576 Danielle Jenkins 

CBD-FORM577 Danna Williams 

CBD-FORM578 Dante Brintazzoli 

CBD-FORM579 Dara Gorelick 

CBD-FORM580 Darla Knutson 

CBD-FORM581 Darleen Hogg 

CBD-FORM582 darlene wolf 

CBD-FORM583 Darren Strain 

CBD-FORM584 Darrin Duling 

CBD-FORM585 darya alexandrovna 

CBD-FORM586 Dave & Sue Priest 

CBD-FORM587 Dave Adams 

CBD-FORM588 Dave Loiselle 

CBD-FORM589 Dave Wilson 

CBD-FORM590 David Bell 

CBD-FORM591 David Bigwood 

CBD-FORM- David Birnbaum 

538
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

592 

CBD-FORM593 David Bowman 

CBD-FORM594 David Boyer 

CBD-FORM595 David Brodnax 

CBD-FORM596 David Brunner 

CBD-FORM597 David Burkhart 

CBD-FORM598 David Camp 

CBD-FORM599 David Cayford 

CBD-FORM600 David Cosby 

CBD-FORM601 David Dunkleberger 

CBD-FORM602 David Dvorak Jr. 

CBD-FORM603 David Dyre 

CBD-FORM604 David Enevoldsen 

CBD-FORM605 David Gascon 

CBD-FORM606 David Hind 

CBD-FORM607 david j. lafond 

CBD-FORM608 David Moline 

CBD-FORM609 David Morais 

CBD-FORM610 David Parker 

CBD-FORM611 David Romportl 

CBD-FORM612 David Rosenberg 

CBD-FORM613 David Sanders 

CBD-FORM614 David Schmitt 

CBD-FORM615 David Sherman 

CBD-FORM616 David Snope 

CBD-FORM617 David Taylor 

CBD-FORM618 David Taylor 

CBD-FORM619 David Trask 

CBD-FORM620 David Walker 

CBD-FORM621 Davin Peterson 

CBD-FORM622 Davis Hawkowl 

CBD-FORM623 Dawn Kosec 

CBD-FORM624 Dawn Scott 

CBD-FORM- Dawn Stanko 

625 

CBD-FORM626 Day Denton 

CBD-FORM627 Dean Monroe 

CBD-FORM628 Dean Sherwood 

CBD-FORM629 Dean Webb 

CBD-FORM630 deana graff 

CBD-FORM631 Deanna Allen 

CBD-FORM632 Deanna Homer 

CBD-FORM633 Deb Fritzler 

CBD-FORM634 DEB Johnson 

CBD-FORM635 Deb Kobres 

CBD-FORM636 Deb Szymanski 

CBD-FORM637 Debbie Connery 

CBD-FORM638 Debbie Egan 

CBD-FORM639 Debbie Hood 

CBD-FORM640 Debbie McCarthy 

CBD-FORM641 Debbie Sirois 

539
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM642 Debbie Spahn 

CBD-FORM643 Debbie Woods 

CBD-FORM644 Debby Montero 

CBD-FORM645 Deborah Ahlers 

CBD-FORM646 Deborah Barros 

CBD-FORM647 Deborah Deatherage 

CBD-FORM648 Deborah Fexis 

CBD-FORM649 Deborah Filipelli, Ph.D. 

CBD-FORM650 Deborah Hunter 

CBD-FORM651 Deborah Kearns 

CBD-FORM652 Deborah Klein 

CBD-FORM653 deborah lancman 

CBD-FORM654 Deborah Nudelman 

CBD-FORM655 Deborah Outman 

CBD-FORM656 Deborah Parker 

CBD-FORM657 deborah s Van Damme 

CBD-FORM- Deborah Strohmayer 

658 

CBD-FORM659 Debra Cunningham 

CBD-FORM660 Debra Dunson 

CBD-FORM661 Debra Hoven 

CBD-FORM662 Debra Makoff 

CBD-FORM663 Debra Mucci 

CBD-FORM664 Debra nichols 

CBD-FORM665 Debra Powell 

CBD-FORM666 Debra Saude 

CBD-FORM667 Dee Warenycia 

CBD-FORM668 Delbert Contival 

CBD-FORM669 Delia Volpi 

CBD-FORM670 Della Oliver 

CBD-FORM671 Della Pangborn 

CBD-FORM672 Delores Harshaw 

CBD-FORM673 Dena Garcia 

CBD-FORM674 Denee Scribner 

CBD-FORM675 Deneen Peckinpah 

CBD-FORM676 Denise Conte 

CBD-FORM677 Denise Dunlap 

CBD-FORM678 Denise Espinoza 

CBD-FORM679 Denise Morey 

CBD-FORM680 Denise Neuzil 

CBD-FORM681 Denise Rischel 

CBD-FORM682 Denise Romesburg 

CBD-FORM683 Dennis Hayden 

CBD-FORM684 Dennis Miller 

CBD-FORM685 Dennis Smith 

CBD-FORM686 Dennis Yee 

CBD-FORM687 Derek Andersen 

CBD-FORM688 Derek Stockdale 

CBD-FORM689 Derek Terran 

CBD-FORM690 Derek Young 

CBD-FORM- Desirée Ball 

540
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

691 

CBD-FORM692 Desiree Shaw 

CBD-FORM693 Detrea Moullet 

CBD-FORM694 Devin Henry 

CBD-FORM695 Dewey Fish 

CBD-FORM696 Dewey Odhner 

CBD-FORM697 Dhanjisha Variava 

CBD-FORM698 Dian Berger 

CBD-FORM699 dian wright 

CBD-FORM700 Diana Andres 

CBD-FORM701 Diana Franco 

CBD-FORM702 Diana Guzman 

CBD-FORM703 Diana Kaye 

CBD-FORM704 Diana Parmeter 

CBD-FORM705 Diana Schipperen 

CBD-FORM706 Diane Barham 

CBD-FORM707 Diane Berliner 

CBD-FORM708 Diane Neophytou 

CBD-FORM709 Diane Pacocha 

CBD-FORM710 Diane Paulson 

CBD-FORM711 Diane Reid 

CBD-FORM712 Diane Silverhawk 

CBD-FORM713 Diane Wynne 

CBD-FORM714 Dianna Poling Witucki 

CBD-FORM715 Dianne Ensign 

CBD-FORM716 dick Schoech 

CBD-FORM717 DIMITRIOS DOINAKIS 

CBD-FORM718 Dina Volpe 

CBD-FORM719 dinda evans 

CBD-FORM720 Dirk Beving 

CBD-FORM721 Dirk Obudzinski 

CBD-FORM722 Dirk Rogers 

CBD-FORM723 DL Caisse 

CBD-FORM- Dominick Falzone 

724 

CBD-FORM725 dominique lee 

CBD-FORM726 Don Barnhill 

CBD-FORM727 don crozier 

CBD-FORM728 Don Jacobson 

CBD-FORM729 Dona LaSchiava 

CBD-FORM730 Donald Brockway 

CBD-FORM731 Donald Figge 

CBD-FORM732 Donald Garlit 

CBD-FORM733 Donna Butler 

CBD-FORM734 Donna Clark 

CBD-FORM735 donna hughes 

CBD-FORM736 Donna Parente 

CBD-FORM737 Donna Parr 

CBD-FORM738 Donna Selquist 

CBD-FORM739 Donna Smith 

CBD-FORM740 Donna Watson 

541
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM741 Donna Zappacosta 

CBD-FORM742 Donnette Lafleur 

CBD-FORM743 doris canaday 

CBD-FORM744 Doris Carey 

CBD-FORM745 Doris Lapierre 

CBD-FORM746 Doris Potter 

CBD-FORM747 Doris Vician 

CBD-FORM748 Dorothy Reichardt 

CBD-FORM749 Dorothy Wheeler 

CBD-FORM750 Doug Byron 

CBD-FORM751 Doug Dederich 

CBD-FORM752 Douglas Schleifer 

CBD-FORM753 Douglas Wingeier 

CBD-FORM754 Dr. Helen May 

CBD-FORM755 Drena LaPointe-Meyer 

CBD-FORM756 Duane Choy 

CBD-FORM­ DYLAN GUIDRY 

757 

CBD-FORM758 e thomas 

CBD-FORM759 E. Perkins 

CBD-FORM760 eben futral 

CBD-FORM- Ecology Center of 

761 Southern California 

CBD-FORM762 Eddie Floyd II 

CBD-FORM763 Eddie Konczal 

CBD-FORM764 Edith Borie 

CBD-FORM765 Edna Jamati 

CBD-FORM766 Edna Mullen 

CBD-FORM767 Edward Butler 

CBD-FORM768 Edward Craig 

CBD-FORM769 Edwin Aiken 

CBD-FORM770 edwin skinner 

CBD-FORM771 Edwina Smith 

CBD-FORM772 Edythe Cox 

CBD-FORM773 Eileen Conner 

CBD-FORM774 Eileen Daniels 

CBD-FORM775 Eileen Hampton 

CBD-FORM776 Eileen McCorry 

CBD-FORM777 Elaine Alfaro 

CBD-FORM778 Elaine and John Sartoris 

CBD-FORM779 Elaine Becker 

CBD-FORM780 Elaine Berg 

CBD-FORM781 Elaine Nations 

CBD-FORM782 Elaine Rizzo 

CBD-FORM783 Elaine Saldivar 

CBD-FORM784 Eleanor Liggio 

CBD-FORM785 Elena Moutier 

CBD-FORM786 Elena Myers 

CBD-FORM787 elena tsikala 

CBD-FORM788 Eleni Bousia 

CBD-FORM789 Eleni O'neill 

CBD-FORM­ eliane leva 

542
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

790 

CBD-FORM791 Elisa Edgington 

CBD-FORM792 Elisabeth Collins 

CBD-FORM793 Elisabeth Penitschka 

CBD-FORM794 Elisabeth Richter 

CBD-FORM795 Elizabeth Brown 

CBD-FORM796 Elizabeth Butler 

CBD-FORM797 Elizabeth Cheong 

CBD-FORM798 Elizabeth Long 

CBD-FORM799 Elizabeth Tobier 

CBD-FORM800 Elizabeth Ungar 

CBD-FORM801 elizabeth watts 

CBD-FORM802 Elizabeth Wirtz 

CBD-FORM803 Ellaine Lurie-Janicki 

CBD-FORM804 Ellen Ayres 

CBD-FORM805 Ellen Beschler 

CBD-FORM806 Ellen Dollars 

CBD-FORM807 Ellen Frei 

CBD-FORM808 Ellen Gachesa 

CBD-FORM809 Ellen Goodman 

CBD-FORM810 Ellen McFarland 

CBD-FORM811 Ellen Siciliano 

CBD-FORM812 Ellen Zimmerman 

CBD-FORM813 ellen= dorfman 

CBD-FORM814 Elmo M. Davis 

CBD-FORM815 Eloy Santos 

CBD-FORM816 Elsa Ashelford 

CBD-FORM817 Elsie Hobbins 

CBD-FORM818 Emelia Breña Valle 

CBD-FORM819 emerald diamante 

CBD-FORM820 Emilia boccagna 

CBD-FORM821 Emilia Lausz 

CBD-FORM822 Emilio Andres Araya 

CBD-FORM- Emily Doutre 

823 

CBD-FORM824 Emily Kenny 

CBD-FORM825 Emily Lubahn 

CBD-FORM826 Emily Palmieri 

CBD-FORM827 Emily Smith 

CBD-FORM828 Emily Van Alyne 

CBD-FORM829 Emily Wronski 

CBD-FORM830 Emma Hartung 

CBD-FORM831 Emma Leyburn 

CBD-FORM832 Emma Spurgin Hussey 

CBD-FORM833 enzo mulas 

CBD-FORM- Eric & Armin 

834 Karanjawala 

CBD-FORM835 Eric Edwards 

CBD-FORM836 Eric Fournier 

CBD-FORM837 Eric Hoyer 

CBD-FORM838 Eric Kaplan 

CBD-FORM839 Eric Lambart 

543
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM840 Eric Morris 

CBD-FORM841 Eric Polczynski 

CBD-FORM842 Eric Simpson 

CBD-FORM843 Eric Simpson 

CBD-FORM844 Eric smith 

CBD-FORM845 Eric Stone 

CBD-FORM846 Eric West 

CBD-FORM847 Erica Montague 

CBD-FORM848 erich blengini 

CBD-FORM849 Ericka Camp 

CBD-FORM850 Erik Scott 

CBD-FORM851 Erin Barca 

CBD-FORM852 Erin Enger 

CBD-FORM853 erin reese 

CBD-FORM854 Erin Wallace 

CBD-FORM855 ern yarrobino 

CBD-FORM­ ERNEST SCHOLZ 

856 

CBD-FORM857 Esmeralda Aldrich 

CBD-FORM858 Estefania Aparicio 

CBD-FORM859 Eva Cashdan 

CBD-FORM860 eva figueiredo 

CBD-FORM861 Eva Kristin Eriksen 

CBD-FORM862 Eva Pieroni 

CBD-FORM863 Eva Valencia 

CBD-FORM864 Evan Remash 

CBD-FORM865 Evan Roman 

CBD-FORM866 Evelyn E. Ledesma 

CBD-FORM867 Evelyn McMullen 

CBD-FORM868 Evelyn Verrill 

CBD-FORM869 Evinna Englezou 

CBD-FORM870 Ewa Piasecka 

CBD-FORM871 Fabio Corona 

CBD-FORM872 fairlee gamble 

CBD-FORM873 Faith Conroy 

CBD-FORM874 faith lewis 

CBD-FORM875 Faith Staggs 

CBD-FORM876 Falisha Finke 

CBD-FORM877 faon lewis 

CBD-FORM878 Felicia Tawil 

CBD-FORM879 Fenia Yfandi 

CBD-FORM880 Fernanda Muñoz 

CBD-FORM881 Fernando Cruz de Sousa 

CBD-FORM882 Filipa Lobão 

CBD-FORM883 Fletcher Chouinard 

CBD-FORM884 Fletcher Cossa 

CBD-FORM885 Florence Stanley 

CBD-FORM886 Foster Boone 

CBD-FORM887 Fran Reyes 

CBD-FORM888 Frances Callahan 

CBD-FORM­ frances callahan 

544
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

889 

CBD-FORM890 Frances DeMillion 

CBD-FORM891 Frances Harriman 

CBD-FORM892 frances lightfine 

CBD-FORM893 Frances Patch 

CBD-FORM894 Frances Saykaly 

CBD-FORM895 Frances Tan 

CBD-FORM896 Francesca Mansfield 

CBD-FORM897 Francine Dolins 

CBD-FORM- Francis & Patricia 

898 Gorman 

CBD-FORM899 Francisco Anta 

CBD-FORM900 Francois de la Giroday 

CBD-FORM901 Françoise Bonté 

CBD-FORM902 Frank Aaron 

CBD-FORM903 Frank Biermann 

CBD-FORM904 Frank Hill 

CBD-FORM905 Frank Seewester 

CBD-FORM906 Frank Tehan 

CBD-FORM907 Frank Watson 

CBD-FORM908 Franklin Eventoff 

CBD-FORM­ FRANKLIN 

909 KAPUSTKA 

CBD-FORM910 Fred Lavy 

CBD-FORM911 FRED Mayer 

CBD-FORM912 Fred Oliver 

CBD-FORM913 fred rinne 

CBD-FORM914 Frederick Horn 

CBD-FORM915 Frederick Ruch 

CBD-FORM916 Fulvia Marino 

CBD-FORM917 G. Preuss 

CBD-FORM918 Gabriel Sheets 

CBD-FORM919 Gabriel Sheridan 

CBD-FORM920 Gabriele Reinhart 

CBD-FORM921 Gabrielle Marshall 

CBD-FORM- Gail Adams 

922 

CBD-FORM923 Gail and Rick Konopacki 

CBD-FORM924 Gail Bedinger 

CBD-FORM925 Gail Cartwright 

CBD-FORM926 Gail Matwichuk 

CBD-FORM927 Gail Padalino 

CBD-FORM928 Gale Kelsey 

CBD-FORM929 Galen Davis 

CBD-FORM930 galina heuer 

CBD-FORM931 Gary Brooker 

CBD-FORM932 Gary Evans 

CBD-FORM933 Gary Hoyt 

CBD-FORM934 Gavin Bornholtz 

CBD-FORM935 Gayle B. Rosenberry 

CBD-FORM936 Gayle Sullivan 

CBD-FORM937 Gena Pennington 

CBD-FORM938 Gene Arias 

545
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM939 gene groom 

CBD-FORM940 Gene Ulmer 

CBD-FORM941 Geoff Beasley 

CBD-FORM942 Geoff Bommelaere 

CBD-FORM943 Geoff Hirsch 

CBD-FORM944 Geoffrey Stearns 

CBD-FORM945 Georgann Meadows 

CBD-FORM946 George Latta 

CBD-FORM947 George P. Johnson 

CBD-FORM948 George Squires 

CBD-FORM949 Georgia Braithwaite 

CBD-FORM950 gerald rees 

CBD-FORM951 Geraldine Dickel 

CBD-FORM952 Geri Collecchia 

CBD-FORM953 Gerrit Crouse 

CBD-FORM- Gerritt and Elizabeth 

954 Baker-Smith 

CBD-FORM- Gerry Walsh 

955 

CBD-FORM956 Ghazale Jamsheed 

CBD-FORM957 Gian Andrea Morresi 

CBD-FORM958 Gil Jenkins 

CBD-FORM959 Gina Gatto 

CBD-FORM960 Gina Palmisano 

CBD-FORM961 gina wiese 

CBD-FORM962 Ginger Carter 

CBD-FORM963 Ginger Mira 

CBD-FORM964 Ginger Young 

CBD-FORM965 Gioia Cristalli 

CBD-FORM966 giovanna gramignano 

CBD-FORM967 gitte santini 

CBD-FORM968 Glen Domulevicz 

CBD-FORM969 Glenn Smith 

CBD-FORM970 Gloria Ann Callahan 

CBD-FORM971 Gloria Cameron 

CBD-FORM972 Gloria D'Andrea 

CBD-FORM973 Gloria Diggle 

CBD-FORM974 Gloria Jones 

CBD-FORM975 Gloria Morrison 

CBD-FORM976 Gordon Grant 

CBD-FORM977 Grace Holden 

CBD-FORM978 GRACE NEFF 

CBD-FORM979 greg kareofelas 

CBD-FORM980 Greg Sweel 

CBD-FORM981 Greg Terhune 

CBD-FORM982 Gregory Esteve 

CBD-FORM983 Gregory Robertson 

CBD-FORM984 Gretchen Brewer 

CBD-FORM985 Gretchen Sudlow 

CBD-FORM986 Gunnar Sievert 

CBD-FORM987 Günther Spinnler 

CBD-FORM- Guy Bateman 

546
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

988 

CBD-FORM989 Guy Lusher 

CBD-FORM990 Guy Zahller 

CBD-FORM991 H. Chisholm 

CBD-FORM992 H. Nash 

CBD-FORM993 Hal Trufan 

CBD-FORM994 Hank Mirsky 

CBD-FORM995 Hanna Supeyeva 

CBD-FORM996 Hannah Beadman 

CBD-FORM997 Hannah Harte 

CBD-FORM998 Hannah Osborne 

CBD-FORM999 Harmony Conger 

CBD-FORM1000 Hartson Doak 

CBD-FORM1001 Heather Busse 

CBD-FORM1002 Heather Cross 

CBD-FORM1003 Heather Files 

CBD-FORM1004 Heather Halvorson 

CBD-FORM1005 Heather Holloway 

CBD-FORM1006 Heather John 

CBD-FORM1007 Heather Murawski 

CBD-FORM1008 Heather Petrovsky 

CBD-FORM1009 heidi arp 

CBD-FORM1010 Heidi Buitron 

CBD-FORM1011 heidi doman 

CBD-FORM1012 Heidi Hoffmann 

CBD-FORM1013 Heidi Letzmann 

CBD-FORM1014 Heidi Mayer 

CBD-FORM1015 Heidi Shuler 

CBD-FORM- Heidrun Kordholste1016 Nikander 

CBD-FORM1017 Helen Crabtree 

CBD-FORM1018 Henry Rauchweld 

CBD-FORM1019 Henry Rosenfeld 

CBD-FORM1020 Henry Van Zant 

CBD-FORM- Herman Osorio 

1021 

CBD-FORM1022 Hernry Berkowitz 

CBD-FORM1023 Hervé Bérard 

CBD-FORM1024 Hilary Aquino 

CBD-FORM1025 Holiday Houck 

CBD-FORM1026 Holly Yee 

CBD-FORM1027 HOMER PRICE 

CBD-FORM1028 Hope Gmyrek 

CBD-FORM1029 Hope Holtum 

CBD-FORM1030 Horst Pfand 

CBD-FORM1031 Houston Taylor 

CBD-FORM1032 Howard Cohen 

CBD-FORM1033 Howard Higson 

CBD-FORM1034 Hubert CANCE 

CBD-FORM1035 HUNTER WALLOF 

CBD-FORM1036 Ian Boyle 

CBD-FORM1037 Ian Gonzales 

547
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1038 Ian Rettie 

CBD-FORM1039 Ignazia Daidone 

CBD-FORM1040 Ilse Ziemann 

CBD-FORM1041 Imogen Taylor 

CBD-FORM1042 inga kaminski 

CBD-FORM1043 Internatural Alinement 

CBD-FORM1044 Irene Martinez 

CBD-FORM1045 Irene Tremper 

CBD-FORM1046 Iris Block 

CBD-FORM1047 Irving Shapiro 

CBD-FORM1048 Irwin Dunietz 

CBD-FORM1049 Isabel Araujo 

CBD-FORM1050 Isabella Abbiati 

CBD-FORM1051 isabelle boisgard 

CBD-FORM1052 Isobel Craig 

CBD-FORM1053 Isolina Callegari 

CBD-FORM- Ivailo Dunov 

1054 

CBD-FORM1055 Ivana Grmoja 

CBD-FORM1056 Ivana Rakic 

CBD-FORM1057 Ivana Sesar 

CBD-FORM1058 J Jackson 

CBD-FORM1059 J Noble 

CBD-FORM1060 J Roberts 

CBD-FORM1061 J Stufflebeam 

CBD-FORM1062 J Walby 

CBD-FORM1063 J. Holley Taylor 

CBD-FORM1064 J. K. Fort 

CBD-FORM1065 J. Siska Hjelmgren 

CBD-FORM1066 Jacinda Fenske 

CBD-FORM1067 Jack Barber 

CBD-FORM1068 Jack Runnels 

CBD-FORM1069 Jackie Pomies 

CBD-FORM1070 Jacqueline Baruch 

CBD-FORM1071 Jacqueline Peipert 

CBD-FORM1072 Jacques korte leccia 

CBD-FORM1073 Jamee Warfle 

CBD-FORM- James & Shelley & Elise 

1074 Poston 

CBD-FORM1075 james a hughes 

CBD-FORM1076 James Barnes 

CBD-FORM1077 james button > 

CBD-FORM1078 James Columbia 

CBD-FORM1079 JAMES CONROY 

CBD-FORM1080 James Davies 

CBD-FORM1081 James Fishgold 

CBD-FORM1082 James Grimes 

CBD-FORM1083 James H. Fitch 

CBD-FORM1084 James James 

CBD-FORM1085 James Klein 

CBD-FORM1086 James Kunz 

CBD-FORM- James Manning 

548
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1087 

CBD-FORM1088 James Moran 

CBD-FORM1089 James Mulcare 

CBD-FORM1090 James Plagmann 

CBD-FORM1091 James Robertson 

CBD-FORM1092 James Sullivan 

CBD-FORM1093 james thompson 

CBD-FORM1094 James Wilcox 

CBD-FORM1095 James Woods 

CBD-FORM1096 jamie harrison 

CBD-FORM1097 Jamie Rasmussen 

CBD-FORM1098 Jamie Rosenblood 

CBD-FORM1099 Jamila Garrecht 

CBD-FORM1100 Jan Cool 

CBD-FORM1101 Jane Daniels 

CBD-FORM1102 Jane Drews 

CBD-FORM1103 jane griffiths 

CBD-FORM1104 Jane LeGrow 

CBD-FORM1105 Jane Reynolds 

CBD-FORM1106 Jane So,[spm 

CBD-FORM1107 Janet Barber 

CBD-FORM1108 Janet Cameron 

CBD-FORM1109 Janet Cavallo 

CBD-FORM1110 janet curtis 

CBD-FORM1111 Janet Delaney 

CBD-FORM1112 Janet Duran 

CBD-FORM1113 Janet Fotos 

CBD-FORM1114 janet hACKNEY 

CBD-FORM1115 Janet klecker 

CBD-FORM1116 janet letusick-spear 

CBD-FORM1117 Janet Robbins 

CBD-FORM1118 Janet Smith 

CBD-FORM1119 Janet Standridge 

CBD-FORM- Janice Paik 

1120 

CBD-FORM1121 Janice Rogers 

CBD-FORM1122 janna piper 

CBD-FORM1123 Janna Wiedemann 

CBD-FORM1124 Jannette Ferguson 

CBD-FORM1125 Jaquelyn Chagnon 

CBD-FORM1126 Jared Cornelia 

CBD-FORM1127 Jared Laiti 

CBD-FORM1128 Jared Peace 

CBD-FORM1129 Jason Agnew 

CBD-FORM1130 Jason Chisholm 

CBD-FORM1131 Jason Cooperrider 

CBD-FORM1132 jason lambert 

CBD-FORM1133 jason palmer 

CBD-FORM1134 Jason Perry 

CBD-FORM1135 Jason Walker 

CBD-FORM1136 Jayleen Hatmaker 

549
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1137 Jean Naples 

CBD-FORM1138 jean schwartz 

CBD-FORM1139 Jean Woodman 

CBD-FORM1140 jeanette donato 

CBD-FORM1141 Jean-François Dutto 

CBD-FORM1142 Jeanine Wilder 

CBD-FORM1143 Jeanine Zinno 

CBD-FORM1144 Jeanne Dutto 

CBD-FORM1145 Jeanne Greene 

CBD-FORM1146 jeanne hayes 

CBD-FORM1147 Jeanne Hevener 

CBD-FORM1148 Jeannie Gibbons 

CBD-FORM1149 Jeannie Tyner 

CBD-FORM1150 Jeannine Mendrola 

CBD-FORM1151 Jeene Mance 

CBD-FORM1152 Jeff Hanus 

CBD-FORM- Jeff Hoffman 

1153 

CBD-FORM1154 jeff hopkins 

CBD-FORM1155 Jeff Komisarof 

CBD-FORM1156 Jeff Payne 

CBD-FORM1157 Jeff Thayer 

CBD-FORM1158 Jeffrey Howe 

CBD-FORM1159 Jeffrey Hurwitz 

CBD-FORM1160 Jelica Roland 

CBD-FORM1161 Jenette Champagne 

CBD-FORM1162 Jenn Kirkendall 

CBD-FORM1163 Jennifer Cartwright 

CBD-FORM1164 jennifer ciambrone 

CBD-FORM1165 Jennifer Cochran 

CBD-FORM1166 Jennifer Delker 

CBD-FORM1167 Jennifer Dziedzic 

CBD-FORM1168 Jennifer Everett 

CBD-FORM1169 Jennifer Flood 

CBD-FORM1170 Jennifer Harrison 

CBD-FORM1171 jennifer henderson 

CBD-FORM1172 Jennifer Jayroe 

CBD-FORM1173 Jennifer Johnson 

CBD-FORM1174 jennifer kilgore 

CBD-FORM1175 Jennifer M Weishaar 

CBD-FORM1176 Jennifer Mathers 

CBD-FORM1177 Jennifer Milam 

CBD-FORM1178 Jennifer Miller 

CBD-FORM1179 Jennifer Nitz 

CBD-FORM1180 Jennifer Norman 

CBD-FORM1181 Jennifer Oppenheim 

CBD-FORM1182 Jennifer Place 

CBD-FORM1183 Jennifer Rials 

CBD-FORM1184 Jennifer Sawyer 

CBD-FORM1185 Jennifer Smith 

CBD-FORM­ jennifer st.mary-ledbetter 

550
 
 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1186 

CBD-FORM1187 Jennifer Stamps 

CBD-FORM1188 Jennifer Suzanne Martino 

CBD-FORM1189 Jennifer Taylor 

CBD-FORM1190 Jennifer Willett 

CBD-FORM1191 Jenny Boulton 

CBD-FORM1192 Jenny O'Neil 

CBD-FORM1193 Jenny Ruckdeschel 

CBD-FORM1194 Jere Bowden 

CBD-FORM1195 Jeremiah Podleski 

CBD-FORM1196 Jeremy Chrupka 

CBD-FORM1197 Jeremy Nathan Marks 

CBD-FORM1198 Jeri Rossi 

CBD-FORM1199 jeriP pollock 

CBD-FORM1200 Jerry Bonanno 

CBD-FORM1201 Jerry Golden 

CBD-FORM1202 Jerry Peavy 

CBD-FORM1203 jerry spetsieris 

CBD-FORM1204 Jesse Miller 

CBD-FORM1205 Jesse Williams 

CBD-FORM1206 Jessica Arnold 

CBD-FORM1207 jessica barley 

CBD-FORM1208 Jessica Cox 

CBD-FORM1209 jessica gunnells 

CBD-FORM1210 Jessica Kraskian 

CBD-FORM1211 Jessica Macomber 

CBD-FORM1212 Jessica Ramirez 

CBD-FORM1213 Jessica Rocheleau 

CBD-FORM1214 jessica sargent 

CBD-FORM1215 Jessica Tellez 

CBD-FORM1216 Jessie Edwards 

CBD-FORM1217 Jessie Osborne 

CBD-FORM1218 Jessika Kiel 

CBD-FORM- Jie Wei Tan 

1219 

CBD-FORM1220 Jill Brothers 

CBD-FORM1221 Jill Gleeson 

CBD-FORM1222 jill nord 

CBD-FORM1223 Jill Tierney 

CBD-FORM1224 Jim and Virginia Wagner 

CBD-FORM1225 JIM HEAD 

CBD-FORM1226 Jim Rettig 

CBD-FORM1227 Jim Thomas 

CBD-FORM1228 Jim Yarbrough 

CBD-FORM1229 Jimmie Wolfe 

CBD-FORM1230 Jimmy Pearson 

CBD-FORM1231 JK Kibler 

CBD-FORM1232 jo wiest 

CBD-FORM1233 joan ciccarone 

CBD-FORM1234 Joan Denman 

CBD-FORM1235 Joan DeVagno 

551
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1236 joan milford 

CBD-FORM1237 joan scott 

CBD-FORM1238 Joan Walker 

CBD-FORM1239 Joan Ward 

CBD-FORM1240 Joan Weaver 

CBD-FORM1241 Joan Zawaski 

CBD-FORM1242 Joann Maier 

CBD-FORM1243 jOANN Ramos 

CBD-FORM1244 Joanna Bonnheim 

CBD-FORM1245 Joanna Welch 

CBD-FORM1246 Joanne Burke 

CBD-FORM1247 Joanne Calash 

CBD-FORM1248 Joanne Cockerill 

CBD-FORM1249 Joanne Colson 

CBD-FORM1250 joanne reisch 

CBD-FORM1251 Jodeen J 

CBD-FORM- Jodi Roberts 

1252 

CBD-FORM1253 Jodie Schossow 

CBD-FORM1254 Jody Gibson 

CBD-FORM1255 Joe Calabrese 

CBD-FORM1256 Joe Futterer 

CBD-FORM1257 Joe Krein 

CBD-FORM1258 Joe Phillips 

CBD-FORM1259 Joe Shabaduh 

CBD-FORM1260 Joel Page 

CBD-FORM1261 Joel Page 

CBD-FORM1262 Joel Trupin 

CBD-FORM1263 johanna isaacs 

CBD-FORM1264 Johannes Siebke 

CBD-FORM1265 John Albertini 

CBD-FORM1266 John Blalock 

CBD-FORM1267 john brinkman 

CBD-FORM1268 John Davis 

CBD-FORM1269 John DonaldsonII 

CBD-FORM1270 John Dulik 

CBD-FORM1271 John Edman 

CBD-FORM1272 John Essman 

CBD-FORM1273 John Estes 

CBD-FORM1274 John Farver 

CBD-FORM1275 John Feissel 

CBD-FORM1276 John Harris 

CBD-FORM1277 John Heyneman 

CBD-FORM1278 John Jenkins 

CBD-FORM1279 john kegler 

CBD-FORM1280 John Kesich 

CBD-FORM1281 John L. Keiser 

CBD-FORM1282 John Lemmon 

CBD-FORM1283 John Lewis 

CBD-FORM1284 JOHN MARSHALL 

CBD-FORM- John Mullan 

552
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1285 

CBD-FORM1286 John Nettleton 

CBD-FORM1287 John Orsini 

CBD-FORM1288 john pasqua 

CBD-FORM1289 John Pritchard 

CBD-FORM1290 John Pye 

CBD-FORM1291 John R Jackson 

CBD-FORM1292 John Rokas 

CBD-FORM1293 John Schumacher 

CBD-FORM1294 John Shannon 

CBD-FORM1295 John Shiffler 

CBD-FORM1296 John Spitale 

CBD-FORM1297 John Varga 

CBD-FORM1298 John Wolfe 

CBD-FORM1299 Joline Gitis 

CBD-FORM1300 Jon Zielinski 

CBD-FORM1301 Jonathan Eden 

CBD-FORM1302 Jonathan Kaufman Scher 

CBD-FORM1303 Jonathan Nash 

CBD-FORM1304 Jonathan Wieder 

CBD-FORM1305 Jordan Pakaki 

CBD-FORM1306 Jordan Yeatts 

CBD-FORM1307 Jordana H. 

CBD-FORM1308 Jorge De Cecco 

CBD-FORM1309 Jori Davison 

CBD-FORM1310 Josefina Vidal 

CBD-FORM1311 Joseph A. Mungai 

CBD-FORM1312 Joseph Alfano 

CBD-FORM1313 Joseph Kress 

CBD-FORM1314 Joseph Phillips 

CBD-FORM1315 Josephine Niemann 

CBD-FORM1316 josh kaye-carr 

CBD-FORM1317 Josh Kaye-Carr 

CBD-FORM- Joshua Hart 

1318 

CBD-FORM1319 Joshua Mahurin 

CBD-FORM1320 Joshua Maizel 

CBD-FORM1321 Joy Loyd 

CBD-FORM1322 Joy Murphy 

CBD-FORM1323 Joy Puder 

CBD-FORM1324 Joyce and Bill Bryson 

CBD-FORM1325 Joyce Coombs 

CBD-FORM1326 Joyce Frohn 

CBD-FORM1327 Joyce Grajczyk 

CBD-FORM1328 joyce schwartz 

CBD-FORM1329 Joyce Terwilliger 

CBD-FORM1330 JR Summers 

CBD-FORM1331 JT Adams 

CBD-FORM1332 Juan Murcia 

CBD-FORM1333 Juanita Montano 

CBD-FORM1334 Judith Fruge 

553
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1335 Judith Gordon 

CBD-FORM1336 Judith Mitchell 

CBD-FORM1337 Judith Pelletier 

CBD-FORM1338 Judith Swain 

CBD-FORM1339 Judy Boone 

CBD-FORM1340 Judy Boone 

CBD-FORM1341 Judy Cato 

CBD-FORM1342 Judy de Groot 

CBD-FORM1343 Judy ericson 

CBD-FORM1344 Judy Kahkonen 

CBD-FORM1345 Judy Landress 

CBD-FORM1346 Judy Shively 

CBD-FORM1347 Judy W. Soffler 

CBD-FORM1348 Julia Brandner 

CBD-FORM1349 julia Broome 

CBD-FORM1350 Julia Burwell 

CBD-FORM- Julia Griparic 

1351 

CBD-FORM1352 Julia Thompson 

CBD-FORM1353 juliana MARQUES 

CBD-FORM1354 Julianna Riley 

CBD-FORM1355 Julianne Ramaker 

CBD-FORM1356 Julie Amato 

CBD-FORM1357 Julie Anderson 

CBD-FORM1358 Julie Beer 

CBD-FORM1359 Julie Brickell 

CBD-FORM1360 Julie du Bois 

CBD-FORM1361 Julie Figueroa 

CBD-FORM1362 Julie Ford 

CBD-FORM1363 Julie Leavenworth 

CBD-FORM1364 Julie Lewey 

CBD-FORM1365 julie rodgers 

CBD-FORM1366 Julie Smith 

CBD-FORM1367 Julie Talcott-Fuller 

CBD-FORM1368 Julie Wilson 

CBD-FORM1369 julien Massol 

CBD-FORM1370 Juliet Stratton 

CBD-FORM1371 Julija Merljak 

CBD-FORM1372 June Attarian 

CBD-FORM1373 June Maselli 

CBD-FORM1374 Justine Jackson-Ricketts 

CBD-FORM1375 k danowski 

CBD-FORM1376 k hipkins 

CBD-FORM1377 K Riggs 

CBD-FORM1378 k thomas 

CBD-FORM1379 K. Burns 

CBD-FORM1380 KA Castle 

CBD-FORM1381 Kaila Estrada 

CBD-FORM1382 kale haggard 

CBD-FORM1383 Kamila Szuberla 

CBD-FORM­ karab hughes 

554
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1384 

CBD-FORM1385 Kareem Talhouni 

CBD-FORM1386 Karen Bartell 

CBD-FORM1387 karen brant 

CBD-FORM1388 Karen Given 

CBD-FORM1389 Karen Graham 

CBD-FORM1390 Karen H. Loughmiller 

CBD-FORM1391 Karen Kravcov Malcolm 

CBD-FORM1392 karen linarez 

CBD-FORM1393 Karen Luce 

CBD-FORM1394 Karen Mosser 

CBD-FORM1395 Karen Romano 

CBD-FORM1396 Karen Stevens 

CBD-FORM1397 Karen Tucker 

CBD-FORM1398 Karen Vasily 

CBD-FORM1399 karen wible 

CBD-FORM1400 Kari Wouk 

CBD-FORM1401 Karin Lundkvist 

CBD-FORM1402 Karina Soerensen 

CBD-FORM1403 Karine Ferreira Strazisar 

CBD-FORM1404 Karl Hunting 

CBD-FORM1405 Karyn Gil 

CBD-FORM1406 Karyn Sederberg 

CBD-FORM1407 Karyon Owen 

CBD-FORM1408 Kasia Richer-Juraszek 

CBD-FORM1409 Kassandra Levay 

CBD-FORM1410 Kat Raisky 

CBD-FORM1411 Katarzyna Kubzdela 

CBD-FORM1412 Kate Jamal 

CBD-FORM1413 Kate Robinson 

CBD-FORM1414 Kate Wenzell 

CBD-FORM1415 katerina alexandrovna 

CBD-FORM1416 Katharine Retherford 

CBD-FORM- Kathe Garbrick 

1417 

CBD-FORM1418 Katherine Bommarito 

CBD-FORM1419 Katherine Mouzourakis 

CBD-FORM1420 Katherine Nelson 

CBD-FORM1421 Katherine Roberts 

CBD-FORM1422 Katherine Whitson 

CBD-FORM1423 Kathleen Clark 

CBD-FORM1424 Kathleen Curl 

CBD-FORM1425 Kathleen Eaton 

CBD-FORM1426 Kathleen Kiselewich 

CBD-FORM1427 Kathleen Kliese 

CBD-FORM1428 Kathleen Mohning 

CBD-FORM1429 Kathleen Morris 

CBD-FORM1430 Kathleen Resnick 

CBD-FORM1431 Kathleen Templeton 

CBD-FORM1432 Kathleen View 

CBD-FORM1433 kathleen wissenz 

555
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1434 Kathryn Cagle 

CBD-FORM1435 Kathryn Droubi 

CBD-FORM1436 kathryn klecan 

CBD-FORM1437 Kathryn Lemoine 

CBD-FORM1438 Kathryn McDermott 

CBD-FORM1439 Kathryn Morgan 

CBD-FORM1440 Kathryn Parke 

CBD-FORM1441 Kathryn Richardson 

CBD-FORM1442 Kathryn Rose 

CBD-FORM1443 Kathryn Vestal 

CBD-FORM1444 Kathy Bentley 

CBD-FORM1445 Kathy Britt 

CBD-FORM1446 Kathy Galligan 

CBD-FORM1447 Kathy Hanson 

CBD-FORM1448 Kathy LoPresti 

CBD-FORM1449 Kathy Popoff 

CBD-FORM- Kathy Silvey 

1450 

CBD-FORM1451 kathy watts 

CBD-FORM1452 Katie Kaiser 

CBD-FORM1453 Katie Sirk 

CBD-FORM1454 Katie Whittaker 

CBD-FORM1455 Katrien Vandevelde 

CBD-FORM1456 Kay Westby 

CBD-FORM1457 Kayla Ev 

CBD-FORM1458 Kayleen Gubrud 

CBD-FORM1459 Keely Jared 

CBD-FORM1460 Keely Parr 

CBD-FORM1461 Keeta Beaubien 

CBD-FORM1462 Keiko Ishida 

CBD-FORM1463 Keiko Martinez 

CBD-FORM1464 Keith Hiestand 

CBD-FORM1465 Keith Teeter 

CBD-FORM1466 Kelli Baker 

CBD-FORM1467 Kelly Jacobson 

CBD-FORM1468 Kelly Levans 

CBD-FORM1469 Kelly Lombardi 

CBD-FORM1470 Kelly Popp 

CBD-FORM1471 Kelly Riley 

CBD-FORM1472 Kelsey Parkins 

CBD-FORM1473 Ken Green 

CBD-FORM1474 ken gunther 

CBD-FORM1475 Ken Hedges 

CBD-FORM1476 Ken Johnston 

CBD-FORM1477 KEN MOORE 

CBD-FORM1478 Ken Strothkamp 

CBD-FORM1479 Ken Ward Jr. 

CBD-FORM1480 Ken Wong 

CBD-FORM1481 Kenna Fowler 

CBD-FORM1482 Kenneth Barnes 

CBD-FORM- Kenneth Douglas 

556
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1483 

CBD-FORM1484 Kenneth Gibson 

CBD-FORM1485 Kenneth Kolanko 

CBD-FORM1486 Kenneth Kron 

CBD-FORM1487 Kenneth Tabachnick 

CBD-FORM1488 Kermit Cuff 

CBD-FORM1489 kerry burkhardt 

CBD-FORM1490 Kerry Campbell 

CBD-FORM1491 Kerry Dorsey 

CBD-FORM1492 kerry Kittrell 

CBD-FORM1493 Kessley Truman 

CBD-FORM1494 Kevin Gallagher 

CBD-FORM1495 Kevin Reel 

CBD-FORM1496 Kevin Ryan 

CBD-FORM1497 Khalil Kinge 

CBD-FORM1498 kim bauer 

CBD-FORM1499 kim cameron 

CBD-FORM1500 kim english 

CBD-FORM1501 kim groom 

CBD-FORM1502 Kim Johnson 

CBD-FORM1503 Kim McCoy 

CBD-FORM1504 Kim Moreno 

CBD-FORM1505 Kim Mott 

CBD-FORM1506 Kim O'Bryan 

CBD-FORM1507 Kim Pham 

CBD-FORM1508 Kim Sandholdt 

CBD-FORM1509 Kim Stern 

CBD-FORM1510 kim winter 

CBD-FORM1511 Kimberley Buckley 

CBD-FORM1512 Kimberly Locke 

CBD-FORM1513 Kimberly Ray 

CBD-FORM1514 Kimberly Simms 

CBD-FORM1515 kimberly skrobiza 

CBD-FORM- Kimberly Tilley 

1516 

CBD-FORM1517 Kimberly Wiley 

CBD-FORM1518 Kimberly Wyke 

CBD-FORM1519 Kinney Evitt 

CBD-FORM1520 kip marlow 

CBD-FORM1521 Kirk Rhoads 

CBD-FORM1522 KJ Herson 

CBD-FORM1523 Kreen L 

CBD-FORM1524 Krissy Hughes 

CBD-FORM1525 Kristen Allbritton 

CBD-FORM1526 Kristen Bossard 

CBD-FORM1527 Kristen Magno 

CBD-FORM1528 Kristi Hendrickson 

CBD-FORM1529 Kristi Hutchison 

CBD-FORM1530 Kristian Glover 

CBD-FORM1531 Kristiana Dahl 

CBD-FORM- Kristin Anne Conrad1532 Antoville 

557
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1533 kristin erbach 

CBD-FORM1534 Kristin Williams 

CBD-FORM1535 Kristin Womack 

CBD-FORM1536 Kristina Fukuda-Schmid 

CBD-FORM1537 Kristina Gravette 

CBD-FORM1538 Kurt Emmanuele 

CBD-FORM1539 Kurt Fratzke 

CBD-FORM1540 Kyle Buss 

CBD-FORM1541 Kyle Calcagno 

CBD-FORM1542 Kylie Cullen 

CBD-FORM1543 L Bxx 

CBD-FORM1544 L cummings 

CBD-FORM1545 L G 

CBD-FORM1546 l Irwin 

CBD-FORM1547 l TOMKO 

CBD-FORM1548 L. D. Pratt 

CBD-FORM­ L. Kruger 

1549 

CBD-FORM1550 L. Peterson 

CBD-FORM1551 L.S. Wanner 

CBD-FORM1552 Lacey Levitt 

CBD-FORM1553 Laci Branch 

CBD-FORM1554 Laina Shockley 

CBD-FORM1555 Laken Pugsley 

CBD-FORM1556 Lara Michele 

CBD-FORM1557 LARISSA RODRIGUEZ 

CBD-FORM1558 Larry Wood 

CBD-FORM1559 launa prince 

CBD-FORM1560 Laura Baldwin 

CBD-FORM1561 Laura Bernsstein 

CBD-FORM1562 laura cosentino 

CBD-FORM1563 Laura De Maria 

CBD-FORM1564 Laura Dicus 

CBD-FORM1565 Laura Feld 

CBD-FORM1566 Laura Gleason 

CBD-FORM1567 laura hedlund 

CBD-FORM1568 Laura Herndon 

CBD-FORM1569 Laura Lieberman 

CBD-FORM1570 Laura Napoleon 

CBD-FORM1571 laura semboli 

CBD-FORM1572 laura Shepard 

CBD-FORM1573 Laura Sholtz 

CBD-FORM1574 Laura Ziegler 

CBD-FORM1575 Laurel Cohen 

CBD-FORM1576 Laurel E. Tate 

CBD-FORM1577 lauren basalla 

CBD-FORM1578 Lauren Kramer 

CBD-FORM1579 Lauren Murdock 

CBD-FORM1580 Lauren Ranz 

CBD-FORM1581 lauren smith 

CBD-FORM- Lauren Yarrish 

558
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1582 

CBD-FORM1583 Laurie Carr 

CBD-FORM1584 Laurie Hein 

CBD-FORM- Laurie Lindemulder1585 Harris 

CBD-FORM1586 laurie sudol 

CBD-FORM1587 Lawrence Carbary 

CBD-FORM1588 Lawrence Magliola 

CBD-FORM1589 Lawrence McTigue 

CBD-FORM1590 Lawrence Thompson 

CBD-FORM1591 Lawrence Turk 

CBD-FORM1592 Leah Ray 

CBD-FORM1593 Leah Stavish 

CBD-FORM1594 Leah Travaline 

CBD-FORM1595 Leanne Civiletti 

CBD-FORM1596 Leanne Vines 

CBD-FORM1597 Lee and Charlotte Terbot 

CBD-FORM1598 Lee Baron 

CBD-FORM1599 Lee Winslow 

CBD-FORM1600 Leeann French 

CBD-FORM1601 Leigh Begalske 

CBD-FORM1602 Leila Gill 

CBD-FORM1603 Leo Ashton 

CBD-FORM1604 leon clingman 

CBD-FORM1605 Leon Muhudinov 

CBD-FORM1606 Leonard Bruckman 

CBD-FORM1607 Leonard Marcus 

CBD-FORM1608 Leonardo Benucci 

CBD-FORM1609 Lesa Pond 

CBD-FORM1610 Lesia Mills 

CBD-FORM1611 leslie bald 

CBD-FORM1612 Leslie Billings 

CBD-FORM1613 Leslie Cummings 

CBD-FORM1614 Leslie Gaye Price 

CBD-FORM- Leslie MacKay 

1615 

CBD-FORM1616 Leslie Powell 

CBD-FORM1617 leslie schriener 

CBD-FORM1618 Leslie Tawnamaia 

CBD-FORM1619 Leslie Wingerath 

CBD-FORM1620 Lesly Vick 

CBD-FORM1621 Leticia Bayona 

CBD-FORM1622 Lhasa Compton 

CBD-FORM1623 Liam Gray 

CBD-FORM1624 Libby Haycock 

CBD-FORM1625 LILLY LETUSICK 

CBD-FORM1626 Lily Maisky 

CBD-FORM1627 lily mast 

CBD-FORM1628 Lina Easom 

CBD-FORM1629 Linda Bruner 

CBD-FORM1630 Linda Cabanban 

CBD-FORM1631 Linda Downer 

559
 
 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1632 Linda Fair 

CBD-FORM1633 Linda Falcone 

CBD-FORM1634 Linda Gall 

CBD-FORM1635 Linda Gazzola 

CBD-FORM1636 Linda Luke 

CBD-FORM1637 Linda McVarish 

CBD-FORM1638 LINDA NORRIS 

CBD-FORM1639 Linda Schermer 

CBD-FORM1640 Linda Sessine 

CBD-FORM1641 Lindsay Holeman 

CBD-FORM1642 Lindsay Johnson 

CBD-FORM1643 Lindsay Ramos 

CBD-FORM1644 Lindsay Rayner 

CBD-FORM1645 Lisa Dadgar 

CBD-FORM1646 Lisa Douglass 

CBD-FORM1647 lisa gilling 

CBD-FORM- Lisa Gosnell 

1648 

CBD-FORM1649 Lisa Jablow 

CBD-FORM1650 Lisa Jacobson 

CBD-FORM1651 Lisa Leutheuser 

CBD-FORM1652 Lisa Long 

CBD-FORM1653 Lisa Matejka 

CBD-FORM1654 lisa norman 

CBD-FORM1655 Lisa Piner 

CBD-FORM1656 Lisa Provident 

CBD-FORM1657 Lisa Rae 

CBD-FORM1658 Lisa Reeves 

CBD-FORM1659 Lisa Rubin 

CBD-FORM1660 lisa salazar 

CBD-FORM1661 Lisa Sood 

CBD-FORM1662 Lisa Stone 

CBD-FORM1663 Lisa Vana 

CBD-FORM1664 Lisa Williamson 

CBD-FORM1665 Lisa Zarafonetis 

CBD-FORM1666 Lisette Fabian 

CBD-FORM1667 Liz Kessler 

CBD-FORM1668 Liz Sigel 

CBD-FORM1669 Lloyd Hebert 

CBD-FORM1670 Lois Clymer 

CBD-FORM1671 Lois Kendall 

CBD-FORM1672 Lois Yuen 

CBD-FORM1673 lonna richmond 

CBD-FORM1674 Loraine Puryear 

CBD-FORM1675 Loralee Clark 

CBD-FORM1676 Lorali Wyant 

CBD-FORM1677 Loretta Marmor 

CBD-FORM1678 Lori Albee 

CBD-FORM1679 Lori Kegler 

CBD-FORM1680 Lori Sherry 

CBD-FORM- Lori Triggs 

560
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1681 

CBD-FORM1682 Lorne Beatty 

CBD-FORM1683 Lorraine Millard 

CBD-FORM1684 lorraine petro 

CBD-FORM1685 Louis Bubala 

CBD-FORM1686 Louis Pontillo 

CBD-FORM1687 Louis Reginato Jr 

CBD-FORM1688 Louise J Bowles 

CBD-FORM1689 Louise Slattery 

CBD-FORM1690 Lowell Eliason 

CBD-FORM1691 luana costanzini 

CBD-FORM1692 Luanne Alomair 

CBD-FORM1693 Luanne Serrato 

CBD-FORM1694 Lucette Lahaye 

CBD-FORM1695 Luci Ungar 

CBD-FORM1696 Luci Ungar, Artist 

CBD-FORM1697 Lucille Trujillo 

CBD-FORM1698 LUCINDA BRISBANE 

CBD-FORM1699 Lucy Gray 

CBD-FORM1700 Lucy Hadl 

CBD-FORM1701 Lucy Starbuck 

CBD-FORM1702 Luke Keller 

CBD-FORM1703 Lura Irish 

CBD-FORM1704 Lydia Rogers 

CBD-FORM1705 Lydia Skloven 

CBD-FORM1706 Lyn Berling 

CBD-FORM1707 Lynn Barnes 

CBD-FORM1708 Lynn Ledgerwood 

CBD-FORM1709 Lynn Locke 

CBD-FORM1710 Lynn Lytton 

CBD-FORM1711 Lynn Markert 

CBD-FORM1712 Lynn Minneman 

CBD-FORM1713 Lynn Pitney 

CBD-FORM- Lynn Powers 

1714 

CBD-FORM1715 Lynn Sajdak 

CBD-FORM1716 Lynn Sovell 

CBD-FORM1717 Lynn Wiliiamson 

CBD-FORM1718 Lynnda Strong 

CBD-FORM1719 Lynne Banta 

CBD-FORM1720 Lynnette Lane 

CBD-FORM1721 M Epton 

CBD-FORM1722 m rossi 

CBD-FORM1723 M Starr 

CBD-FORM1724 M. Alice DeAngelis 

CBD-FORM1725 m. canter 

CBD-FORM1726 M. Renee Taylor 

CBD-FORM1727 M. RIVERA 

CBD-FORM1728 MA Kruse 

CBD-FORM1729 Madeleine Brumley 

CBD-FORM1730 Madeline Banschbach 

561
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1731 madeline moroff 

CBD-FORM1732 Madiha Hussaini 

CBD-FORM1733 madonna lennon 

CBD-FORM1734 maggie hunter depaulo 

CBD-FORM1735 Mairi Meredith 

CBD-FORM- Malcolm MacPherson, 

1736 PhD 

CBD-FORM1737 Malva McIntosh 

CBD-FORM1738 mana hideki 

CBD-FORM1739 Mandy Stone 

CBD-FORM1740 Maneesh Pangasa 

CBD-FORM- Manolo Segura 

1741 MacDonald 

CBD-FORM1742 Marc Gregory 

CBD-FORM1743 marchez shurn 

CBD-FORM1744 Marci McCartney 

CBD-FORM1745 Marcia Bonta 

CBD-FORM1746 Marcia Cohen 

CBD-FORM- Marcia McDuffie 

1747 

CBD-FORM1748 Marcia Ostrowski 

CBD-FORM1749 marcia ritz 

CBD-FORM1750 Marcus Lanskey 

CBD-FORM1751 Marcy Andersen 

CBD-FORM1752 Margaret Herten 

CBD-FORM1753 margaret lohr 

CBD-FORM1754 Margaret Silver 

CBD-FORM1755 Margaret Welke 

CBD-FORM1756 Margaret Wood 

CBD-FORM1757 Margean Kastner 

CBD-FORM1758 Margie Culbertson 

CBD-FORM1759 Margit Meissner-Jackson 

CBD-FORM1760 Marguerite Cambria 

CBD-FORM1761 Marguery Lee Zucker 

CBD-FORM1762 mari betancur 

CBD-FORM1763 Mari T. Echevarria 

CBD-FORM1764 Maria Alicandu-Thurman 

CBD-FORM1765 MARIA ALONSO 

CBD-FORM1766 Maria Borges 

CBD-FORM1767 Maria Deliou 

CBD-FORM1768 maria edlund 

CBD-FORM1769 Maria Luongo 

CBD-FORM1770 Maria Nasif 

CBD-FORM1771 maria nazzaro 

CBD-FORM1772 Maria van Dingenen 

CBD-FORM1773 Maria Williamson 

CBD-FORM1774 Marian Baker Gierlach 

CBD-FORM1775 Marian Cooley 

CBD-FORM1776 Marian Donovan 

CBD-FORM- Marianna Delinck 

1777 Manley 

CBD-FORM- Marianne Brettell1778 Vaughn 

CBD-FORM1779 Marie Harding 

CBD-FORM- Marie Louise Morandi 

562
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1780 Long Zwicker 

CBD-FORM1781 Marie Morrissey 

CBD-FORM1782 Marie Nickell 

CBD-FORM1783 Marie Wadman 

CBD-FORM1784 Marie-Gabrielle Claudot 

CBD-FORM1785 Marija Minic 

CBD-FORM1786 marijo ahnger 

CBD-FORM1787 Marika Wilde 

CBD-FORM1788 Mariko Powers 

CBD-FORM1789 Marilee Urban 

CBD-FORM­ MARILYN & TOM 

1790 FINNELLI 

CBD-FORM1791 Marilyn Katherine Coats 

CBD-FORM1792 Marilynn Smith 

CBD-FORM1793 Marin Xiques 

CBD-FORM1794 marina jelicic 

CBD-FORM1795 marina krikunova 

CBD-FORM- Marine Loos 

1796 <mlcourrielCBD-FORM1797 Marinell Daniel 

CBD-FORM1798 mario giannone 

CBD-FORM1799 Marion Ehrlich 

CBD-FORM1800 Marion Kraus 

CBD-FORM1801 Marisa Ferreira 

CBD-FORM1802 marisa landsberg 

CBD-FORM1803 Marissa Dupont 

CBD-FORM1804 Marissa Weber 

CBD-FORM1805 Marit Mussche 

CBD-FORM1806 Marjorie Lev 

CBD-FORM1807 Mark Chudzik 

CBD-FORM1808 Mark Donaldson 

CBD-FORM1809 Mark Hallett 

CBD-FORM1810 Mark Hein 

CBD-FORM1811 Mark Helman 

CBD-FORM1812 Mark Hotchkiss 

CBD-FORM- Mark J. Fiore 

1813 

CBD-FORM1814 Mark Larsen 

CBD-FORM1815 Mark M Giese 

CBD-FORM1816 mark noethen 

CBD-FORM1817 mark porter 

CBD-FORM1818 MARK SALAMON 

CBD-FORM1819 Mark Sentesy 

CBD-FORM1820 Mark Sousa 

CBD-FORM1821 Mark Waltzer 

CBD-FORM1822 Mark Weinberger 

CBD-FORM1823 Marlena Lange 

CBD-FORM1824 Marlene Bruce 

CBD-FORM1825 Marlowe Mager 

CBD-FORM1826 Marrk Elman 

CBD-FORM1827 Marsha Penner 

CBD-FORM1828 Marsha Talifarro 

CBD-FORM1829 Marsha Wheaton 

563
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1830 Marsha Wilson 

CBD-FORM­ MARTA DE LA 

1831 FUENTE 

CBD-FORM1832 Marta Zamora 

CBD-FORM1833 Martha Eberle 

CBD-FORM1834 Martha Izzo 

CBD-FORM1835 Martha Land 

CBD-FORM1836 Martha Spencer 

CBD-FORM1837 Martha Stopa 

CBD-FORM1838 Martha Thompson 

CBD-FORM1839 martin Antuna 

CBD-FORM1840 Martin Ferwerda 

CBD-FORM1841 martin kerrigan 

CBD-FORM1842 Martina Lerede 

CBD-FORM1843 Martina Patterson 

CBD-FORM1844 Mary Alexander 

CBD-FORM- Mary Ann and Frank 

1845 Graffagnino 

CBD-FORM- Mary Ann Burke 

1846 

CBD-FORM1847 Mary Barbezat 

CBD-FORM1848 Mary Barkalow 

CBD-FORM1849 MARY BAYSINGER 

CBD-FORM1850 mary berges 

CBD-FORM1851 Mary Carrick 

CBD-FORM1852 mary costello 

CBD-FORM1853 Mary Eldredge 

CBD-FORM1854 Mary Fineran 

CBD-FORM1855 Mary Hoffmann 

CBD-FORM1856 Mary Hood 

CBD-FORM1857 Mary Levitt 

CBD-FORM1858 Mary Lou Finley 

CBD-FORM1859 Mary Lou Pierron 

CBD-FORM1860 Mary Lou Rynkiewicz 

CBD-FORM1861 Mary Metcalf 

CBD-FORM1862 Mary Reed 

CBD-FORM1863 mary rivas 

CBD-FORM1864 mary rojeski 

CBD-FORM1865 Mary Savoia 

CBD-FORM1866 Mary Schor 

CBD-FORM1867 mary stark 

CBD-FORM1868 Mary Wiebe 

CBD-FORM1869 maryalice carroll 

CBD-FORM1870 Maryalice Webb 

CBD-FORM1871 Maryann Emery 

CBD-FORM1872 maryg green 

CBD-FORM1873 maryg green 

CBD-FORM1874 maryke petruzzi 

CBD-FORM1875 marylou eastes 

CBD-FORM1876 Mathew Christianson 

CBD-FORM1877 Mathew Wilson 

CBD-FORM1878 Matt Burgess 

CBD-FORM- Matt Mabee 

564
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1879 

CBD-FORM1880 Matt Maras 

CBD-FORM1881 Matt Otto 

CBD-FORM1882 Matthew Boruta 

CBD-FORM1883 Matthew Finch 

CBD-FORM1884 Matthew Flores 

CBD-FORM1885 Matthew Iskra 

CBD-FORM1886 Matthew James 

CBD-FORM1887 Matthew Stainton 

CBD-FORM1888 Maura O'Connor 

CBD-FORM1889 Maurice Rosenstraus 

CBD-FORM1890 Max Jewett 

CBD-FORM1891 Maya Robinson 

CBD-FORM1892 Meaghan Leavitt 

CBD-FORM1893 Meda Jo Glover 

CBD-FORM1894 Megan Brodie 

CBD-FORM1895 Megan Horn 

CBD-FORM1896 MEGAN LEHMAN 

CBD-FORM1897 Megan McEachern 

CBD-FORM1898 Megan Richardson 

CBD-FORM1899 Megan Roemer 

CBD-FORM1900 Megan Vohs 

CBD-FORM1901 Meghan Prior 

CBD-FORM1902 mel jordan 

CBD-FORM1903 Melanie Alexander 

CBD-FORM1904 Melanie Andrus 

CBD-FORM1905 Melanie McCormick 

CBD-FORM1906 Melinda Bashen 

CBD-FORM1907 Melinda McComb 

CBD-FORM1908 Melissa Allen 

CBD-FORM1909 Melissa Britton 

CBD-FORM1910 Melissa Cathcart 

CBD-FORM1911 Melissa Conrad 

CBD-FORM- Melissa Hanmer 

1912 

CBD-FORM1913 Melissa Kasch 

CBD-FORM1914 Melissa Migliore 

CBD-FORM1915 Melissa Sharp 

CBD-FORM1916 Melissa Stimpfle 

CBD-FORM1917 Melissa Tomaszewski 

CBD-FORM1918 Melissa White 

CBD-FORM1919 Mercedes Castro Pita 

CBD-FORM1920 Mercedes Lackey 

CBD-FORM1921 Mercedes Smith 

CBD-FORM1922 Meredith Wade 

CBD-FORM1923 meri dreyfuss 

CBD-FORM1924 Merrill Kramer 

CBD-FORM1925 Mervi Rantala 

CBD-FORM1926 Meyer Jordan 

CBD-FORM1927 Meyer Scharlack 

CBD-FORM1928 Mica McCall 

565
 
 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM1929 michael albrecht 

CBD-FORM1930 Michael Allen 

CBD-FORM1931 Michael Ambroszewski 

CBD-FORM1932 michael chase 

CBD-FORM1933 Michael Cloud 

CBD-FORM1934 michael corbin 

CBD-FORM1935 Michael Denton 

CBD-FORM1936 Michael Deuell 

CBD-FORM1937 Michael Dophn 

CBD-FORM1938 Michael Dulock 

CBD-FORM1939 Michael Feran 

CBD-FORM1940 Michael Fine 

CBD-FORM1941 Michael Guckian 

CBD-FORM1942 Michael Hamburger 

CBD-FORM1943 Michael Harrington 

CBD-FORM1944 Michael Haskell 

CBD-FORM­ michael hazynski 

1945 

CBD-FORM1946 Michael Kavanaugh 

CBD-FORM1947 Michael King 

CBD-FORM1948 Michael Kutilek 

CBD-FORM1949 Michael Lawrence 

CBD-FORM1950 michael levitt 

CBD-FORM1951 Michael Martin 

CBD-FORM1952 Michael Masley 

CBD-FORM1953 michael Miller 

CBD-FORM1954 Michael Neil 

CBD-FORM1955 Michael Oaks 

CBD-FORM1956 Michael Ott 

CBD-FORM1957 Michael Rotcher 

CBD-FORM1958 Michael Stuart 

CBD-FORM1959 michael szymanski 

CBD-FORM1960 Michael Tackett 

CBD-FORM1961 Michael Terry 

CBD-FORM1962 Michael Wagner 

CBD-FORM1963 michael waters 

CBD-FORM1964 Michael Wisti 

CBD-FORM1965 Michael Woelfel 

CBD-FORM1966 Michael Wood 

CBD-FORM1967 Michalis Theodosiou 

CBD-FORM1968 Michele Nihipali 

CBD-FORM1969 michele Ozuna 

CBD-FORM1970 Michele Rae 

CBD-FORM1971 Michele Remenar 

CBD-FORM1972 Michele Rozga 

CBD-FORM1973 Michele Shimizu 

CBD-FORM1974 Michele von Kampen 

CBD-FORM1975 Michelle Bafik-Vehslage 

CBD-FORM- Michelle Bogden 

1976 Muetzel 

CBD-FORM1977 Michelle Buerger 

CBD-FORM- Michelle Cook 

566
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

1978 

CBD-FORM1979 Michelle D. 

CBD-FORM1980 Michelle Dudeck 

CBD-FORM1981 Michelle G 

CBD-FORM1982 Michelle Hoff 

CBD-FORM1983 Michelle Jones 

CBD-FORM1984 Michelle Kofler 

CBD-FORM1985 Michelle Pavcovich 

CBD-FORM1986 MICHELLE SOULE 

CBD-FORM1987 Michelle Wilkes 

CBD-FORM1988 Micky Mars 

CBD-FORM1989 Mieke Fay 

CBD-FORM1990 Miguel Godinez 

CBD-FORM1991 Miiru Lex 

CBD-FORM1992 Mijanou Bauchau 

CBD-FORM1993 Mike Hansen 

CBD-FORM1994 mike hlat 

CBD-FORM1995 mike mcginn 

CBD-FORM1996 Mike Seeber 

CBD-FORM1997 Mike VanLandingham 

CBD-FORM1998 Mike Weyand 

CBD-FORM1999 Milada Lee 

CBD-FORM2000 Millard Farr 

CBD-FORM2001 Milton Nelson 

CBD-FORM2002 ming ong 

CBD-FORM2003 Miranda Rumpf 

CBD-FORM2004 Mircea Nita 

CBD-FORM2005 Mirella Ostrec 

CBD-FORM2006 Misako Hill 

CBD-FORM2007 Mollie Thomas 

CBD-FORM2008 Molly McCormick 

CBD-FORM2009 Molly Mendez 

CBD-FORM2010 Molly Monroe 

CBD-FORM- Mona Mehas 

2011 

CBD-FORM2012 Monica Gilman 

CBD-FORM2013 monica russo 

CBD-FORM2014 Monica Salazar 

CBD-FORM2015 Monika Gosteli-Gyger 

CBD-FORM2016 Monique Agia 

CBD-FORM2017 moo Niemeyer 

CBD-FORM2018 Morgan Clark 

CBD-FORM- Mr and Mrs James 

2019 Denison 

CBD-FORM- Mr and Mrs Richard N 

2020 Huff 

CBD-FORM­ MR. & MRS. BRUCE 

2021 REVESZ 

CBD-FORM2022 Mr. David Barker 

CBD-FORM2023 Mrs. G F Lull 

CBD-FORM- Mrs. Marie Russell2024 Barker 

CBD-FORM2025 Ms. M L Beckham 

CBD-FORM2026 MURLIN GOEKEN 

CBD-FORM2027 Mylee Khristoforov 

567
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2028 Myles Robertson 

CBD-FORM2029 myra berario 

CBD-FORM2030 Myra Dremeaux 

CBD-FORM2031 Mytzi Rudolph 

CBD-FORM2032 n riley 

CBD-FORM2033 Nadezhda Peneva 

CBD-FORM2034 Nadine Bierwirth 

CBD-FORM2035 nadine chatel 

CBD-FORM2036 Nahid Varjavand 

CBD-FORM2037 Nancy Adams 

CBD-FORM2038 Nancy Alexander 

CBD-FORM2039 Nancy Bergey 

CBD-FORM2040 nancy booth 

CBD-FORM2041 Nancy Bristow 

CBD-FORM2042 Nancy Davlantes 

CBD-FORM2043 Nancy Donker 

CBD-FORM- Nancy Grimes 

2044 

CBD-FORM2045 Nancy Herlinger 

CBD-FORM2046 Nancy Hoffman 

CBD-FORM2047 Nancy Kohut 

CBD-FORM2048 Nancy Ledgerwood 

CBD-FORM2049 Nancy Meadows 

CBD-FORM2050 Nancy Neumann 

CBD-FORM2051 nancy passarelli 

CBD-FORM2052 Nancy Sagatelian 

CBD-FORM2053 Nancy Widman 

CBD-FORM2054 Naomi Fatouros 

CBD-FORM2055 Naomi Korner 

CBD-FORM2056 Naomi Lee-Hood 

CBD-FORM2057 Naomi Weinstein 

CBD-FORM2058 Napapon Preechastien 

CBD-FORM2059 Natalie Corkran 

CBD-FORM2060 Natalie Duleba 

CBD-FORM2061 Natalie Hodapp 

CBD-FORM2062 Natalie Martinez 

CBD-FORM2063 Natalie Meadows 

CBD-FORM2064 natalie oshin 

CBD-FORM2065 Natalie Van Leekwijck 

CBD-FORM2066 Natalie Zarchin 

CBD-FORM2067 Natascha Israel 

CBD-FORM2068 Natasha Shpiller 

CBD-FORM2069 nayana teixe 

CBD-FORM2070 Nayda Cruz Harris 

CBD-FORM2071 Neil Narbonne 

CBD-FORM2072 Neill Adhikari 

CBD-FORM2073 Nelly Benko-Hakim 

CBD-FORM2074 Netta Kausalik 

CBD-FORM2075 Nezka Pfeifer 

CBD-FORM2076 Nhelson Jaramillo 

CBD-FORM- Niall Carroll 

568
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2077 

CBD-FORM2078 Nicholas Esser 

CBD-FORM2079 Nichole Ebel-Bailey 

CBD-FORM2080 Nick Hood 

CBD-FORM2081 Nick Maniatis 

CBD-FORM2082 Nick Rodin 

CBD-FORM2083 Nicole Capizzi 

CBD-FORM2084 Nicole Lugo 

CBD-FORM2085 Nicole Pollock 

CBD-FORM2086 Nicole Porco 

CBD-FORM2087 Nicole Reicher 

CBD-FORM2088 Nicole Strathmann 

CBD-FORM2089 nicole zaban 

CBD-FORM2090 nicolette ludolphi 

CBD-FORM2091 Nicory Madia 

CBD-FORM2092 Nikhil Rau 

CBD-FORM2093 nikki Ayres 

CBD-FORM2094 Nikki Wojtalik 

CBD-FORM2095 Nina Fry 

CBD-FORM2096 NINA GONDOS 

CBD-FORM2097 Nina Kornstein 

CBD-FORM2098 Noel Hutchings 

CBD-FORM2099 Noel Parenti 

CBD-FORM2100 Nolan Farkas 

CBD-FORM2101 Norbert Nitsch 

CBD-FORM2102 Norma McNeill 

CBD-FORM2103 Olivia Lim 

CBD-FORM2104 Olivier Lapeyre 

CBD-FORM2105 Oscar Revilla Alguacil 

CBD-FORM­ OSKAR & MATHIAS 

2106 OBRIST 

CBD-FORM2107 ovadia moshe 

CBD-FORM2108 P D 

CBD-FORM2109 P Greatrix 

CBD-FORM- Pam Alleman 

2110 

CBD-FORM2111 Pam Niedermayer 

CBD-FORM2112 pam polcyn 

CBD-FORM2113 pam roth 

CBD-FORM2114 Pam Shaouy 

CBD-FORM2115 Pam York 

CBD-FORM2116 pamela a 

CBD-FORM2117 pamela Curtis 

CBD-FORM2118 Pamela Fausty 

CBD-FORM2119 Pamela Kjono 

CBD-FORM2120 Pamela McCall 

CBD-FORM2121 Pamela Meade 

CBD-FORM2122 Pamela Miko 

CBD-FORM2123 Pamela Reckers 

CBD-FORM2124 Pamela Scoville 

CBD-FORM2125 Panagiotis Rigopoulos 

CBD-FORM2126 Pat Arnone 

569
 
 

 

 

 

 

 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2127 Pat Barnes 

CBD-FORM2128 pat mace 

CBD-FORM2129 Patrice Cole 

CBD-FORM2130 Patricia Alejandro 

CBD-FORM2131 Patricia Chang 

CBD-FORM2132 Patricia Clements 

CBD-FORM2133 patricia daniels 

CBD-FORM2134 Patricia Gracian 

CBD-FORM2135 PATRICIA GRAZIANO 

CBD-FORM2136 patricia herpich 

CBD-FORM2137 Patricia Lauer 

CBD-FORM2138 Patricia Lessard 

CBD-FORM2139 Patricia Morgan 

CBD-FORM2140 Patricia Nickles 

CBD-FORM2141 patricia o'shaughnessy 

CBD-FORM2142 Patricia Rodgers 

CBD-FORM- Patricia Sikora 

2143 

CBD-FORM2144 Patricia Smith 

CBD-FORM2145 Patrick Aubuchon 

CBD-FORM2146 PATRICK COSGROVE 

CBD-FORM2147 Patrick Deming 

CBD-FORM2148 Patrick Murphy 

CBD-FORM2149 Patrick O'Neil 

CBD-FORM2150 Patrick Rhea 

CBD-FORM2151 patrick romain 

CBD-FORM2152 Patrick Ryel 

CBD-FORM2153 Patrick Studt 

CBD-FORM2154 Patrick Wojahn 

CBD-FORM2155 patti kerkhoff 

CBD-FORM2156 Patti Packer 

CBD-FORM2157 Paul Bechtel 

CBD-FORM2158 paul damian 

CBD-FORM2159 Paul Grohman 

CBD-FORM2160 Paul Grove 

CBD-FORM2161 Paul Haseman 

CBD-FORM2162 Paul Kazmercyk 

CBD-FORM2163 Paul Keables 

CBD-FORM2164 Paul Komishock 

CBD-FORM2165 Paul Mayer 

CBD-FORM2166 Paul Moss 

CBD-FORM2167 paul nitsch 

CBD-FORM2168 Paul Sinacore 

CBD-FORM2169 paul slapinski 

CBD-FORM2170 paul smith 

CBD-FORM2171 paul smith 

CBD-FORM2172 Paul Waybrant 

CBD-FORM2173 Paul West 

CBD-FORM2174 Paula Cox 

CBD-FORM2175 Paula Minklei 

CBD-FORM- Paula Pruner 

570
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2176 

CBD-FORM2177 Paulette Zimmerman 

CBD-FORM2178 Pauline Lee 

CBD-FORM2179 Pauline Schmidt 

CBD-FORM2180 Peg LeClair 

CBD-FORM2181 Peg Parham 

CBD-FORM2182 Peggy England 

CBD-FORM2183 Peggy Heisel 

CBD-FORM2184 pete childs 

CBD-FORM2185 Peter Collins 

CBD-FORM2186 Peter Curia 

CBD-FORM2187 Peter F. Schultz 

CBD-FORM2188 Peter Frieary 

CBD-FORM2189 Peter J. Callizo 

CBD-FORM2190 Peter Karlsson 

CBD-FORM2191 Peter Klosterman 

CBD-FORM2192 peter morrow 

CBD-FORM2193 Peter Paraskevopoulos 

CBD-FORM2194 Peter Pray 

CBD-FORM2195 peter rubin 

CBD-FORM2196 Peter Stone 

CBD-FORM2197 Peter Sweeny 

CBD-FORM2198 Petra Tippersma 

CBD-FORM2199 Philip De Rosa 

CBD-FORM2200 Philip Heinlein 

CBD-FORM2201 Philip Hult 

CBD-FORM2202 Philip Madruga 

CBD-FORM2203 Philip Ratcliff 

CBD-FORM2204 Philipp Reining 

CBD-FORM2205 Phillip Kehn 

CBD-FORM2206 Phoebe Oaks 

CBD-FORM2207 Phyllis Mollen 

CBD-FORM2208 Phyllis Murdoch 

CBD-FORM­ PI Norton 

2209 

CBD-FORM2210 Pier Giorgio Nicoletti 

CBD-FORM2211 pinky jain pan 

CBD-FORM2212 PK Doyle 

CBD-FORM2213 Polly Lavery 

CBD-FORM2214 Potsy Brothag 

CBD-FORM2215 Prem Mulberry 

CBD-FORM2216 Quentin Fischer 

CBD-FORM2217 R Belsher 

CBD-FORM2218 R D 

CBD-FORM2219 R Espoz 

CBD-FORM2220 r springer 

CBD-FORM2221 R Webber 

CBD-FORM2222 R Wells 

CBD-FORM2223 R. Fitzgerald 

CBD-FORM2224 R. M. St. Angelo 

CBD-FORM2225 R. Stoddard 

571
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2226 r.a. schumal 

CBD-FORM2227 Rachael Montague 

CBD-FORM2228 Rachel Ford 

CBD-FORM2229 Rachel Griffith 

CBD-FORM2230 rachel myers 

CBD-FORM2231 Rachel Usher 

CBD-FORM2232 Rachelle Greene 

CBD-FORM- Rafael Horowitz 

2233 Friedman 

CBD-FORM2234 Ragen Tilzey, CPA 

CBD-FORM2235 Ralph Tanner 

CBD-FORM2236 Ralph Tuscher 

CBD-FORM2237 Ran Zirasri 

CBD-FORM2238 Randy Kessler 

CBD-FORM2239 Randy Lloyd 

CBD-FORM2240 randy sailer 

CBD-FORM2241 Rastic Samela 

CBD-FORM- Raul Arribas 

2242 

CBD-FORM2243 Raven Wilkins 

CBD-FORM2244 Raymond Mlynczak 

CBD-FORM2245 Reba Stone 

CBD-FORM2246 Rebecca Ballard 

CBD-FORM2247 Rebecca Crowder 

CBD-FORM2248 rebecca ferrell 

CBD-FORM2249 Rebecca Finley 

CBD-FORM2250 Rebecca Gray 

CBD-FORM2251 Rebecca Kosar 

CBD-FORM2252 Rebecca Lippa 

CBD-FORM2253 Rebecca Ryan 

CBD-FORM2254 Rebecca Safron 

CBD-FORM2255 Rebecca Stover 

CBD-FORM2256 Rebecca Summer 

CBD-FORM2257 Reed Hanson 

CBD-FORM2258 Reesha tuomi 

CBD-FORM2259 Regina Barth 

CBD-FORM2260 Regina DeFalco Lippert 

CBD-FORM2261 Regina Dickerson 

CBD-FORM2262 Regina Marino 

CBD-FORM2263 Regina Minniss 

CBD-FORM2264 Reiner Siebke 

CBD-FORM2265 Rejane Souza 

CBD-FORM2266 Renae Bowman 

CBD-FORM2267 Renae Thompson 

CBD-FORM- Rev Crow Swimsaway 

2268 PhD 

CBD-FORM2269 Rev Curt Miner 

CBD-FORM2270 Rhonda Bradley 

CBD-FORM2271 Rhonda Kohl 

CBD-FORM2272 Rhonda Lynn 

CBD-FORM2273 Ricardo U. Berg 

CBD-FORM2274 Rich Smith 

CBD-FORM- Richard Curtis 

572
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2275 

CBD-FORM2276 RICHARD ELLIOTT 

CBD-FORM2277 Richard Glassberg 

CBD-FORM2278 Richard Han 

CBD-FORM2279 Richard Heaning 

CBD-FORM2280 RICHARD HERKALO 

CBD-FORM2281 Richard Hunt 

CBD-FORM2282 richard jackson 

CBD-FORM2283 Richard Lee 

CBD-FORM2284 Richard Leonard 

CBD-FORM2285 Richard Norman Talley 

CBD-FORM2286 Richard Quinones 

CBD-FORM2287 Richard Robinson 

CBD-FORM2288 Richard Schwartz 

CBD-FORM2289 Richard Shepard 

CBD-FORM2290 Richard Spotts 

CBD-FORM2291 Rick Hammel 

CBD-FORM2292 Rick LaPorte 

CBD-FORM2293 Ricki Newman 

CBD-FORM2294 Rikje Maria Ruiter 

CBD-FORM2295 Rina Hudson 

CBD-FORM2296 Rita Buckhannon 

CBD-FORM2297 Rita Casolari 

CBD-FORM2298 Rita Ryan 

CBD-FORM2299 RJ Bordelon 

CBD-FORM2300 Rob Gonzalez 

CBD-FORM2301 Rob Nash 

CBD-FORM2302 Robb Cavanagh 

CBD-FORM2303 Robert Allen 

CBD-FORM2304 Robert Bausch 

CBD-FORM2305 Robert Cierlitsky 

CBD-FORM2306 robert du Rivage 

CBD-FORM2307 Robert Duffy 

CBD-FORM- Robert Ellis 

2308 

CBD-FORM2309 Robert Fitzgerald 

CBD-FORM2310 Robert Hicks 

CBD-FORM2311 Robert Honish 

CBD-FORM2312 Robert Houskeeper 

CBD-FORM2313 Robert Jacobson 

CBD-FORM2314 Robert Joll 

CBD-FORM2315 robert levitt 

CBD-FORM2316 Robert Liedike 

CBD-FORM2317 Robert Lombardi 

CBD-FORM2318 Robert McCombs 

CBD-FORM2319 ROBERT MORGAN 

CBD-FORM2320 Robert Nickerson 

CBD-FORM2321 Robert Peterson 

CBD-FORM2322 robert Puca 

CBD-FORM2323 Robert Roberto 

CBD-FORM2324 Robert Roman 

573
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2325 Robert Sargent 

CBD-FORM2326 Robert Tafanelli 

CBD-FORM2327 Robert Webster 

CBD-FORM2328 Robert Weingart 

CBD-FORM2329 Robert Weld 

CBD-FORM2330 Robert Williams 

CBD-FORM2331 roberta claypool 

CBD-FORM2332 Roberta Froome 

CBD-FORM2333 Roberta Heita 

CBD-FORM2334 Roberta Zenz 

CBD-FORM2335 Roberto Angarita Vargas 

CBD-FORM2336 Roberto de Angelis 

CBD-FORM2337 robin lim 

CBD-FORM2338 Robin Lindheimer 

CBD-FORM2339 Robin Poppe 

CBD-FORM2340 Robin Stalbaum 

CBD-FORM- Robin Steudle 

2341 

CBD-FORM2342 robin vogler 

CBD-FORM2343 rodney hemmila 

CBD-FORM2344 Roger Hannah 

CBD-FORM2345 roger schmidt 

CBD-FORM2346 Rolf Stuber 

CBD-FORM2347 Ron Avila 

CBD-FORM2348 Ron Kloberdanz 

CBD-FORM2349 ron rediger 

CBD-FORM2350 Ron Tuason 

CBD-FORM2351 Ronald Brown 

CBD-FORM2352 Ronald D. McVeigh 

CBD-FORM2353 Ronald H. Silver, C.E.P. 

CBD-FORM2354 Ronald Kestler 

CBD-FORM2355 Ronald Smith 

CBD-FORM2356 Rosa Barragan 

CBD-FORM2357 Rosa Perez 

CBD-FORM2358 Rosalie Schneider 

CBD-FORM2359 Rosamund Downing 

CBD-FORM2360 Rose Bertrand 

CBD-FORM2361 Rose Marie Stef 

CBD-FORM2362 Rose Ogorzaly 

CBD-FORM- Rosemarie Chinni2363 Edwards 

CBD-FORM- Rosemary Graham2364 Gardner 

CBD-FORM2365 Rosiris Paniagua 

CBD-FORM2366 Ross Hammersley 

CBD-FORM2367 Ross Kelsonpetit 

CBD-FORM2368 Rowena Wyckoff 

CBD-FORM2369 Roxann Shadrick 

CBD-FORM2370 roxie schliesmann 

CBD-FORM2371 Roxy Gray 

CBD-FORM2372 Roy Buchanan 

CBD-FORM2373 roy fuller 

CBD-FORM- Ruaidhri Crofton 

574
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2374 

CBD-FORM2375 Russell Landau 

CBD-FORM2376 Russell Naylor 

CBD-FORM2377 Russell Weisz 

CBD-FORM2378 Ruth Barrett 

CBD-FORM2379 Ruth Gedge 

CBD-FORM2380 Ruth Johnston 

CBD-FORM2381 Ruth Lombard 

CBD-FORM2382 Ruth Mendelson 

CBD-FORM2383 Ruth Miller 

CBD-FORM2384 RuthAnne Dayton 

CBD-FORM2385 Ryan McIntyre 

CBD-FORM2386 S Logan 

CBD-FORM2387 s Pryputniewicz 

CBD-FORM2388 s woodruff 

CBD-FORM2389 S. Julie Tankenson 

CBD-FORM2390 s. owens 

CBD-FORM2391 S.Christopher Jacobs 

CBD-FORM2392 S.S. Shaw 

CBD-FORM2393 sabine greger 

CBD-FORM2394 Sadira Tash 

CBD-FORM2395 Sallie Rose Sandler 

CBD-FORM2396 sam asseff 

CBD-FORM2397 Sam Child 

CBD-FORM2398 Sammy Low 

CBD-FORM2399 SANDRA ALBO 

CBD-FORM2400 Sandra Beatty 

CBD-FORM2401 Sandra Cobb 

CBD-FORM2402 Sandra Couch 

CBD-FORM2403 Sandra Franz 

CBD-FORM2404 Sandra Johnson 

CBD-FORM2405 Sandra Joos 

CBD-FORM2406 Sandra Stock 

CBD-FORM- Sandra Weisman 

2407 

CBD-FORM2408 Sandy Brooks 

CBD-FORM2409 Sandy Levine 

CBD-FORM2410 sandy liu 

CBD-FORM2411 Sandy Lynch 

CBD-FORM2412 Sandy McNeal 

CBD-FORM2413 Sandy Sagitto 

CBD-FORM2414 Sara breakfield 

CBD-FORM2415 Sara CA Rafter 

CBD-FORM2416 Sara Esteves 

CBD-FORM2417 Sara I Kennedy 

CBD-FORM2418 Sara Miller 

CBD-FORM2419 Sara Schroeder 

CBD-FORM2420 sara shaw 

CBD-FORM2421 Sara Thomas 

CBD-FORM2422 Sarah Alvarez 

CBD-FORM2423 Sarah B Stewart 

575
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2424 Sarah Bassuk 

CBD-FORM2425 Sarah Bloom 

CBD-FORM2426 Sarah Estes 

CBD-FORM2427 Sarah Hafer 

CBD-FORM2428 SARAH HAMILTON 

CBD-FORM2429 Sarah McNaull 

CBD-FORM2430 Sarah Rademacher 

CBD-FORM2431 SARAH SELPH 

CBD-FORM2432 Sarah Weller 

CBD-FORM2433 Sarah Woods 

CBD-FORM2434 Saran Kirschbaum 

CBD-FORM2435 Sasha Abrahamson 

CBD-FORM2436 Sasha Kay 

CBD-FORM2437 Saskia Oskam 

CBD-FORM2438 Saskia Santos 

CBD-FORM2439 Scott Baker 

CBD-FORM- Scott Cecile 

2440 

CBD-FORM2441 Scott Gibson 

CBD-FORM2442 Scott Gray 

CBD-FORM2443 Scott Heinze 

CBD-FORM2444 Scott Korman 

CBD-FORM2445 Scott McNeely 

CBD-FORM2446 Scott Species 

CBD-FORM2447 Scott Steiner 

CBD-FORM2448 Scott White 

CBD-FORM2449 Sean Kilpatrick 

CBD-FORM2450 Sean O'Keeffe 

CBD-FORM2451 September Jazzborne 

CBD-FORM2452 serge vantalon 

CBD-FORM2453 Seth Laursen 

CBD-FORM2454 Shanna Cardea 

CBD-FORM2455 Shanna Goetz 

CBD-FORM2456 Shannon Hillary 

CBD-FORM- Shannon Mayfield2457 Chapin 

CBD-FORM2458 Shannon Pippin 

CBD-FORM2459 Shannon Saldana 

CBD-FORM2460 Shannon Sudderth 

CBD-FORM2461 Shannon Teper 

CBD-FORM2462 Sharon Cappuccio 

CBD-FORM2463 Sharon Cox 

CBD-FORM2464 sharon frank 

CBD-FORM2465 Sharon Jacoby 

CBD-FORM2466 Sharon Koogler 

CBD-FORM2467 SHARON LAMPI 

CBD-FORM2468 Sharon Morris 

CBD-FORM2469 Sharon Moss 

CBD-FORM2470 Sharon Stockman 

CBD-FORM­ sharron laplante MD, 

2471 MPH 

CBD-FORM2472 Sharyn Shubert 

CBD-FORM­ shashi light 

576
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2473 

CBD-FORM2474 Shauna Sparlin 

CBD-FORM­ shawn blaesing2475 thompson 

CBD-FORM2476 Shawn Williamsons 

CBD-FORM2477 Shawn Wozniak 

CBD-FORM2478 Shawn Wright 

CBD-FORM2479 Shay Forstrom 

CBD-FORM­ sheacraver@yahoo.com 

2480 Craver 

CBD-FORM2481 Shelby Haukos 

CBD-FORM2482 shelley Caballero 

CBD-FORM2483 shelley frazier 

CBD-FORM2484 Sheri Bresson 

CBD-FORM2485 Sheri Varner-Munt 

CBD-FORM2486 Sherri Fryer 

CBD-FORM2487 Sherri Hawkins 

CBD-FORM2488 Sherry Chance 

CBD-FORM2489 Sherry Marsh 

CBD-FORM2490 Sherry Smith 

CBD-FORM2491 Sherry Thompson 

CBD-FORM2492 Sheryl Mariani 

CBD-FORM2493 Shirley Gilbreath 

CBD-FORM2494 Shirley Harris 

CBD-FORM2495 Shirley Nicholas 

CBD-FORM2496 Shirley Wodtke 

CBD-FORM2497 Siamak Vossoughi 

CBD-FORM2498 Siddharth Mehrotra 

CBD-FORM2499 Sierra Bingham 

CBD-FORM2500 Signe Wetteland 

CBD-FORM2501 silvia bioli 

CBD-FORM2502 Simin Nomani 

CBD-FORM2503 Simon Teolis 

CBD-FORM2504 simone leiss 

CBD-FORM2505 Sina Gulder 

CBD-FORM- Sonia Richart 

2506 

CBD-FORM2507 Sonja Malmuth 

CBD-FORM2508 Sonja Siebke 

CBD-FORM2509 Sophi Zimmerman 

CBD-FORM2510 Sophie Miranda 

CBD-FORM2511 Sophie Teitelbaum 

CBD-FORM2512 Spencer Selander 

CBD-FORM2513 Stacey Bishop 

CBD-FORM2514 STACIE CHARLEBOIS 

CBD-FORM2515 Stan Shappell 

CBD-FORM2516 Stanley Charles 

CBD-FORM2517 Stanley Naftaly 

CBD-FORM2518 stefania perotti 

CBD-FORM2519 Stefano Fragasso 

CBD-FORM2520 Steph Klingele 

CBD-FORM2521 Stephan Donovan 

CBD-FORM2522 Stephanie Aston 

577
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2523 Stephanie Avant 

CBD-FORM2524 Stephanie Corona 

CBD-FORM2525 Stephanie Fraissl 

CBD-FORM2526 Stephanie Jackson 

CBD-FORM2527 Stephanie Johnson 

CBD-FORM2528 Stephanie Kaplan 

CBD-FORM2529 Stephanie Malara 

CBD-FORM2530 Stephanie Proctor 

CBD-FORM2531 Stephanie Sweas 

CBD-FORM2532 Stephanie Williams 

CBD-FORM2533 Stephanie Winchester 

CBD-FORM2534 Stephen Blakely 

CBD-FORM2535 Stephen Canning 

CBD-FORM2536 Stephen Dreher 

CBD-FORM2537 Stephen Ekholm 

CBD-FORM2538 Stephen Hunts 

CBD-FORM- Stephen La Serra 

2539 

CBD-FORM2540 Stephen Lubin 

CBD-FORM2541 Stephen Nong 

CBD-FORM2542 Stephen Paddock 

CBD-FORM2543 Stephen Sleeper 

CBD-FORM2544 Stephen Woodard 

CBD-FORM2545 Stephen Zerefos 

CBD-FORM2546 Steve Donoso 

CBD-FORM2547 Steve Friedman 

CBD-FORM2548 Steve Kokol 

CBD-FORM2549 steve lucas 

CBD-FORM2550 Steve Olson 

CBD-FORM2551 Steve Overton 

CBD-FORM2552 steve simmons 

CBD-FORM2553 Steven Campbell 

CBD-FORM2554 Steven Carter 

CBD-FORM2555 Steven Federman 

CBD-FORM2556 Steven Fenster 

CBD-FORM2557 Steven Mineck 

CBD-FORM2558 Stewart Lone 

CBD-FORM2559 Stoyan Dimitrov 

CBD-FORM2560 stu phillip 

CBD-FORM­ SUBRATTY Abdool 

2561 Karrimbaccus 

CBD-FORM2562 Sue and John Morris 

CBD-FORM2563 Sue DiCocco 

CBD-FORM2564 Sue D'Onofrio 

CBD-FORM2565 sue gries 

CBD-FORM2566 Sue Halligan 

CBD-FORM2567 sue hurley 

CBD-FORM2568 Sue Knight 

CBD-FORM2569 Sue Shimer 

CBD-FORM2570 Sue White 

CBD-FORM2571 Suey Sivula 

CBD-FORM- Susaan Aram 

578
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2572 

CBD-FORM2573 susan biggs 

CBD-FORM2574 susan brown 

CBD-FORM2575 Susan Conway 

CBD-FORM2576 susan damato 

CBD-FORM2577 Susan Emily 

CBD-FORM2578 Susan Garcia 

CBD-FORM2579 Susan Gardner 

CBD-FORM2580 Susan Grimwood 

CBD-FORM2581 Susan Higgins 

CBD-FORM2582 Susan Hill 

CBD-FORM2583 Susan Holmes 

CBD-FORM2584 Susan Hutko 

CBD-FORM2585 Susan Inman 

CBD-FORM2586 Susan Joshua 

CBD-FORM2587 Susan King 

CBD-FORM2588 Susan Lopez-Embury 

CBD-FORM2589 Susan Meiers 

CBD-FORM2590 Susan Noyes 

CBD-FORM2591 Susan Ocopnick 

CBD-FORM2592 susan peirce 

CBD-FORM2593 Susan Reid 

CBD-FORM2594 susan sauls 

CBD-FORM2595 Susan Schuchard 

CBD-FORM2596 Susan Stout 

CBD-FORM2597 Susan Thompson 

CBD-FORM2598 Susan Thurairatnam 

CBD-FORM2599 Susan Valdivia 

CBD-FORM2600 Susan Watts 

CBD-FORM2601 susan zalon 

CBD-FORM2602 Susan Zega 

CBD-FORM2603 susanna nylander 

CBD-FORM2604 Susie & Jimmy Foot 

CBD-FORM- Suzanna Hagglof 

2605 

CBD-FORM2606 Suzanna Mast 

CBD-FORM2607 Suzanne a'Becket 

CBD-FORM2608 Suzanne Capowich 

CBD-FORM2609 Suzanne Hall 

CBD-FORM2610 Suzanne Roberson 

CBD-FORM2611 Sydney Miller 

CBD-FORM2612 Sydney Pratt 

CBD-FORM2613 sylvia anderson 

CBD-FORM2614 Sylvia De Baca 

CBD-FORM2615 Syreeta Batiste 

CBD-FORM2616 T.K. Wang 

CBD-FORM2617 Tahlia Chamberlain 

CBD-FORM2618 Taina Diaz-Reyes 

CBD-FORM2619 Tamadhur Al-Aqeel 

CBD-FORM2620 Tami Palacky 

CBD-FORM2621 Tami Velasco 

579
 
 

 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2622 Tammi Newell 

CBD-FORM2623 Tammy Jones 

CBD-FORM2624 Tamsen Benson 

CBD-FORM2625 Tanja Lehmann 

CBD-FORM2626 Tanya Lewis 

CBD-FORM2627 Tara Braithwaite 

CBD-FORM2628 Tara Kokesch 

CBD-FORM2629 tasha isolani 

CBD-FORM2630 Tatiana Knotts 

CBD-FORM2631 Tawny Sherrill 

CBD-FORM2632 Ted Fishman 

CBD-FORM2633 Teresa Beutel 

CBD-FORM2634 Teri Wilson 

CBD-FORM2635 Terrance Hutchinson 

CBD-FORM2636 terrence ward 

CBD-FORM2637 terri armao 

CBD-FORM- Terri Ybarbo 

2638 

CBD-FORM2639 Terrie C. Williams 

CBD-FORM2640 terry andrews 

CBD-FORM2641 Terry Ellen Robinson 

CBD-FORM2642 Terry McAnaney 

CBD-FORM2643 Terry Pitt 

CBD-FORM2644 Terry Schaedig 

CBD-FORM2645 Tez Cabrera 

CBD-FORM2646 Thane Harpole 

CBD-FORM2647 the wojos 

CBD-FORM2648 thea surrey 

CBD-FORM2649 Thelma McDaniel 

CBD-FORM2650 Theresa Hauser 

CBD-FORM2651 Theresa Shiels 

CBD-FORM2652 Therese DeBing 

CBD-FORM2653 Thomas Aber 

CBD-FORM2654 thomas alexander 

CBD-FORM2655 Thomas Boyd 

CBD-FORM2656 Thomas Foster 

CBD-FORM2657 Thomas Garrett 

CBD-FORM2658 Thomas Giblin 

CBD-FORM2659 Thomas Kiernan 

CBD-FORM2660 Thomas Kindle 

CBD-FORM- Thomas Lindsey 

2661 Hooppaw 

CBD-FORM2662 Thomas Linell 

CBD-FORM2663 Thomas Littelmann 

CBD-FORM2664 Thomas Nieland 

CBD-FORM2665 Thomas Scott 

CBD-FORM2666 Thomas Zissu 

CBD-FORM2667 Thor Alvarez 

CBD-FORM2668 Tiffaney Derreumaux 

CBD-FORM2669 Tiffany Adams 

CBD-FORM2670 tiffany formilan 

CBD-FORM- Tiffany Hutchins 

580
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2671 

CBD-FORM2672 Tihana Pusic 

CBD-FORM2673 Tim Boelke 

CBD-FORM2674 Tim Duda 

CBD-FORM2675 Tim Werner 

CBD-FORM2676 Timothy Beckman 

CBD-FORM2677 Timothy Brennan 

CBD-FORM2678 Timothy Johnston 

CBD-FORM2679 Timothy Lawnicki 

CBD-FORM2680 Timothy Mullen 

CBD-FORM2681 Timothy Strong 

CBD-FORM2682 Tina Jaime 

CBD-FORM2683 Toby Cooper 

CBD-FORM2684 Tod Jones 

CBD-FORM2685 Todd Berliner 

CBD-FORM2686 TODD ENGLEMAN 

CBD-FORM2687 Todd Ramsey 

CBD-FORM2688 Todd Snyder 

CBD-FORM2689 Tom Finholt 

CBD-FORM2690 Tom Fuller 

CBD-FORM2691 Tom Johnson 

CBD-FORM2692 Tom Nulty Jr 

CBD-FORM2693 Toni Ganshert 

CBD-FORM2694 Toni Lubofsky 

CBD-FORM2695 Toni McCalley 

CBD-FORM2696 Toni Siegrist 

CBD-FORM2697 Tonya Cockrell 

CBD-FORM2698 Tonya Graney 

CBD-FORM2699 Tonya Hodge 

CBD-FORM2700 Tooba Syeda Hussaini 

CBD-FORM2701 Tori Thorpe 

CBD-FORM2702 Torunn Sivesind 

CBD-FORM2703 Toty García 

CBD-FORM- Tracey Ahring 

2704 

CBD-FORM2705 Tracey Mangus 

CBD-FORM2706 Tracey Zimmerman 

CBD-FORM2707 Tracy Eve 

CBD-FORM2708 Tracy Fleming 

CBD-FORM2709 Tracy Johnson 

CBD-FORM2710 tracy mclarnon 

CBD-FORM2711 Tracy Vasquez 

CBD-FORM2712 TRAVIS HARVEY 

CBD-FORM- Tressa 

2713 Gilliland=McEnerney 

CBD-FORM2714 Trevor Good 

CBD-FORM2715 Tricia Macke 

CBD-FORM2716 Tricia Mattiello 

CBD-FORM2717 Trista Crook 

CBD-FORM2718 Tuesday Hoffman 

CBD-FORM2719 ulla schmid 

CBD-FORM2720 Uta Cortimilia 

581
 
 

 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

CBD-FORM2721 v walson 

CBD-FORM2722 V. Alexander 

CBD-FORM2723 Val DeGrace 

CBD-FORM2724 Val Price 

CBD-FORM2725 Valerie Friedman 

CBD-FORM2726 valerie gilbert 

CBD-FORM2727 Valerie Hildebrand 

CBD-FORM2728 Valerie Hill 

CBD-FORM2729 valerie rice 

CBD-FORM2730 Vanessa Favero 

CBD-FORM2731 Vanessa Porrata 

CBD-FORM2732 vanessa russo 

CBD-FORM2733 vera kauffman 

CBD-FORM2734 verfaillie claudine 

CBD-FORM2735 veronica hayes 

CBD-FORM2736 Veronique Mariën 

CBD-FORM- Vic Bostock 

2737 

CBD-FORM2738 Vic Burton 

CBD-FORM2739 Vicki Johnson 

CBD-FORM2740 Vicki Kruschwitz 

CBD-FORM2741 Victor Siemon 

CBD-FORM2742 Victoria Brennan 

CBD-FORM2743 Vika babakova 

CBD-FORM2744 Vikki Orlando 

CBD-FORM2745 Vince Cheap 

CBD-FORM2746 Vince Mendieta 

CBD-FORM2747 Vince Snowberger 

CBD-FORM2748 vincenzo mortolini 

CBD-FORM2749 Virgene Link 

CBD-FORM2750 Virginia Bennett 

CBD-FORM2751 Virginia Douglas 

CBD-FORM2752 VIRGINIA GOMEZ 

CBD-FORM2753 virginia robertson 

CBD-FORM2754 virginie romain 

CBD-FORM2755 Vivian Hood 

CBD-FORM2756 Vivian Valtri 

CBD-FORM­ vivianhood@sbcglobal.n 

2757 et 

CBD-FORM2758 Vivianne Mosca-Clark 

CBD-FORM2759 Vladimir Strugatsky 

CBD-FORM2760 vladislav dzambic 

CBD-FORM2761 W Haas 

CBD-FORM2762 walter connelly 

CBD-FORM2763 Walter Kloefkorn 

CBD-FORM2764 Walter Koch 

CBD-FORM2765 Walter Terrell 

CBD-FORM2766 Warren Hageman 

CBD-FORM2767 Wayne B. Peters 

CBD-FORM2768 Wayne MacDonald 

CBD-FORM2769 Wayne Person 

CBD-FORM- Wayne Sieck 

582
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

2770 

CBD-FORM2771 wendy breiby 

CBD-FORM2772 wendy elkins 

CBD-FORM2773 Wendy Li 

CBD-FORM2774 wendy nan paul 

CBD-FORM2775 wendy walters 

CBD-FORM2776 wendy wamser 

CBD-FORM2777 Wendy Wiener 

CBD-FORM2778 wes weaver 

CBD-FORM2779 Whitney Hawks 

CBD-FORM2780 whitney schutt 

CBD-FORM2781 wilford stevens 

CBD-FORM2782 Will Martin 

CBD-FORM2783 Will Retzloff 

CBD-FORM2784 William C. Briggs, Jr. 

CBD-FORM2785 William Davis 

CBD-FORM2786 William Eichinger 

CBD-FORM2787 William Folsom 

CBD-FORM2788 William Frayer 

CBD-FORM2789 William G. Gonzalez 

CBD-FORM2790 William Goggin 

CBD-FORM2791 William Lerner 

CBD-FORM2792 William Lewis 

CBD-FORM2793 William Nolan 

CBD-FORM2794 William Nolan 

CBD-FORM2795 William Still Jr. 

CBD-FORM2796 William Waters 

CBD-FORM2797 Willliam Brown 

CBD-FORM2798 Wilson Ross 

CBD-FORM2799 Wolfgang Rougle 

CBD-FORM2800 Y York 

CBD-FORM2801 Yasiu Kruszynski 

CBD-FORM2802 Yogesh Angrish 

CBD-FORM- Yovonne Autrey-Schell 

2803 

CBD-FORM2804 Yoyi Steele 

CBDFORM-2805 Yvette Irwin 

CBDFORM-2806 Yvonne Allen 

CBDFORM-2807 Yvonne Hansen 

CBDFORM-2808 Yvonne Neal 

CBDFORM-2809 Yvonne van de Looij 

CBDFORM-2810 Zach Colatch 

CBDFORM2811 Zoë Parker 

CBDFORM2812 `soodle burke 

583
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Hobby Gem and Minerals Collectors Form Letter 

Comment Code Commenter 

HGMC-FORM01 Bobby Lai 

HGMC-FORM02 Carol Eggleston 

HGMC-FORM03 Cheryl Taylor 

HGMC-FORM04 Cynthia Ramsey 

HGMC-FORM05 George Silva 

HGMC-FORM06 Gilbert Schreiner 

HGMC-FORM- Heather 

07 Kammerdiener 

HGMC-FORM08 Ken Lai 

HGMC-FORM09 Marshall Havner 

HGMC-FORM10 Mike Eggleston 

HGMC-FORM11 Randy Herrera 

Hernandez Valley Property Owners Form Letter 

Comment Code Commenter 

HVPO-FORM-01 Acevedo 

HVPO-FORM-02 Aguilar 

HVPO-FORM-03 Angel 

HVPO-FORM-04 Arosas 

HVPO-FORM-05 Arreola 

HVPO-FORM-06 Balboa 

HVPO-FORM-07 Barmudez 

HVPO-FORM-08 Bengen 

HVPO-FORM-09 Blancas 

HVPO-FORM-10 Bosio 

HVPO-FORM-11 Brown 

HVPO-FORM-12 Burgen 

HVPO-FORM-13 Carrera 

HVPO-FORM-14 Cassanova 

HVPO-FORM-15 Cassanova 

HVPO-FORM-16 Cerda 

HVPO-FORM-17 Charras 

HVPO-FORM-18 Chavez 

HVPO-FORM-19 Cortez 

HVPO-FORM-20 Crouch 

HVPO-FORM-21 Cumorlinga 

HVPO-FORM-22 Cunningham 

HVPO-FORM-23 Delgadillo 

HVPO-FORM-24 Delgadillo 

HVPO-FORM-25 Dencker 

HVPO-FORM-26 Diaz 

HVPO-FORM-27 Dorrough 

HVPO-FORM-28 Doughour 

HVPO-FORM-29 Doushgounian 

HVPO-FORM-30 Doushgounian 

HVPO-FORM-31 Effend 

584
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

HVPO-FORM-32 Engle 

HVPO-FORM-33 Eryu 

HVPO-FORM-34 Fin 

HVPO-FORM-35 Flores 

HVPO-FORM-36 Fuentes 

HVPO-FORM-37 Gamboa 

HVPO-FORM-38 Gamboa 

HVPO-FORM-39 Garcia 

HVPO-FORM-40 Gutierez 

HVPO-FORM-41 Gutierrez 

HVPO-FORM-42 Guzman 

HVPO-FORM-43 Haman 

HVPO-FORM-44 Heal 

HVPO-FORM-45 Henze 

HVPO-FORM-46 Hernandez 

HVPO-FORM-47 Hernandez 

HVPO-FORM-48 Herrera 

HVPO-FORM-49 Hicks 

HVPO-FORM-50 Higaveda 

HVPO-FORM-51 Johnston 

HVPO-FORM-52 Jordan 

HVPO-FORM-53 Jordan 

HVPO-FORM-54 Kaley 

HVPO-FORM-55 Kari 

HVPO-FORM-56 Laporte 

HVPO-FORM-57 LaRue 

HVPO-FORM-58 Lazo 

HVPO-FORM-59 Lee 

HVPO-FORM-60 Lejes 

HVPO-FORM-61 Leslie 

HVPO-FORM-62 Llanos 

HVPO-FORM-63 Lopez 

HVPO-FORM-64 Lorkett 

HVPO-FORM-65 Lucas 

HVPO-FORM-66 Maas 

HVPO-FORM-67 Madinaveitia 

HVPO-FORM-68 Margy 

HVPO-FORM-69 Martinez 

HVPO-FORM-70 Martinez 

HVPO-FORM-71 Martinez 

HVPO-FORM-72 Martinez 

HVPO-FORM-73 Martinez 

HVPO-FORM-74 Martinez 

HVPO-FORM-75 McKechorie 

HVPO-FORM-76 Medina 

HVPO-FORM-77 Medrano 

HVPO-FORM-78 Menedez 

HVPO-FORM-79 Mercado 

HVPO-FORM-80 Miller 

HVPO-FORM-81 Mironda 

HVPO-FORM-82 Moore 

HVPO-FORM-83 Morales 

HVPO-FORM-84 Morgila 

HVPO-FORM-85 Morris 

HVPO-FORM-86 Murillo 

HVPO-FORM-87 Nelli 

HVPO-FORM-88 Norrby 

HVPO-FORM-89 Olachea 

HVPO-FORM-90 Orantes 

HVPO-FORM-91 Ortega 

HVPO-FORM-92 Ortiz 

HVPO-FORM-93 Otsuki 

HVPO-FORM-94 Patterson 

HVPO-FORM-95 Patterson 

HVPO-FORM-96 Peno 

HVPO-FORM-97 Perez 

HVPO-FORM-98 Plons 

HVPO-FORM-99 Pourkashef 

HVPO-FORM-100 Powers 

HVPO-FORM-101 Prado 

HVPO-FORM-102 Presnell 

HVPO-FORM-103 Proctor 

HVPO-FORM-104 Quevedo 

HVPO-FORM-105 Ramez 

HVPO-FORM-106 Ramirez 

HVPO-FORM-107 Raymundo 

HVPO-FORM-108 Reese 

HVPO-FORM-109 Renf 

HVPO-FORM-110 Rey 

HVPO-FORM-111 Reyes 

HVPO-FORM-112 RioJas 

HVPO-FORM-113 Romella 

585
 
 

Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

HVPO-FORM-114 Romero 

HVPO-FORM-115 Sallinger 

HVPO-FORM-116 Sanchez 

HVPO-FORM-117 Sanchez 

HVPO-FORM-118 Sandys 

HVPO-FORM-119 Stapleton 

HVPO-FORM-120 Stepovich 

HVPO-FORM-121 Vazquez 

HVPO-FORM-122 Vega 

HVPO-FORM-123 Velador 

HVPO-FORM-124 Vidales 

HVPO-FORM-125 Villegas 

HVPO-FORM-126 Viscioni 

HVPO-FORM-127 Walker 

HVPO-FORM-128 Wilkinson 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Table X-6; Form Letter Comment Summary & Responses 

Extend Public Comment Period Form Letter 

I would like to request that the Hollister Field Office grant the public a 90 day extension to the 

Clear Creek Management Area Draft Resource Management Plan/ Draft Environmental Impact 

Statement comment period, which is slated to end March 5, 2010. 

The Clear Creek Management Area has been closed since May of 2008, and the BLM released a
 

Draft Environmental Impact Statement on December 4,
 

2009.
 

It is unreasonable for the public to comment on a 700+ page document that took 18 months to 

write in only 90 days. 

Further more the document was released right before the Christmas holiday when BLM 

employees in the Hollister Field Office went on vacation and were unavailable for questions and 

comments. Furthermore, the BLM didn't hold any Public meetings for over 30 days, and only 

recently on February 22, 2010 held a meeting with business owners and land owners affected by 

the closure. 

The public needs a reasonable amount of time to comment on this document. 

Response: The public comment period for the Draft CCMA RMP/EIS was extended for an 

additional 45 days in response to requests. 

Save the Trails Form Letter 

The BLM should grant a 90-day extension because the local and regional business community 

was largely unaware of DEIS planning process. Many shop owners attended the recent DEIS 

socioeconomic public meeting in San Jose and those proprietors need the extra time so they can 

properly articulate and document the fiscal hardships they have experienced by the current 

interim closure and, more importantly, illustrate the future monetary impacts of a permanent 

closure of CCMA to OHV recreation. 

The DEIS is fatally flawed because it does not analyze the socioeconomic impacts to local and 

regional businesses including restaurants, motorcycle shops, hotels, sporting goods stores, gas 

stations, and grocery stores. The omission must be addressed in the FEIS/ROD. 

The EPA's 2008 CCMA Asbestos Exposure and Human Health Risk Assessment is a fatally 

flawed study that should not be considered significant new information. A primary fatal flaw is in 

the study design. The EPA's sample collection script states: "The distance between riders varied 

depending on visibility, terrain, and safety considerations, with the ultimate objective to 

realistically simulate the behavior of recreational riders. The second and third trailing riders rode 

in the dust cloud of the lead rider, to the extent safe and practical." That narrative does not match 

the BLM's ongoing 20 year educational outreach that instructs riders to not ride in another rider's 

dust cloud. Most, if not all, riders avoid riding in a dust cloud. 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

The Purpose and Need in the DEIS notes the; "Changes in social and economic conditions in San 

Benito County, the San Joaquin Valley, and the entire State of California have led to increased 

demand for use of public lands for recreation and energy production as well as an increased 

awareness and social value placed on the cultural and natural resources in the Planning 

Area." Recent public testimony at the February 25, OHMVR Commission meeting illustrated 

that displaced CCMA OHV riders are overcrowding the regional OHV areas that include, 

Jawbone OHV Area, Hollister and Carnegie SVRAs, and Metcalf Cycle Park A Cumulative 

Effect analysis must be included in this planning process. 

The EPA Risk Assessment is fatally flawed because a majority of the samples were collected 

during dry periods when Clear Creek was closed to the public. That information was gleaned via 

a FOIA request that showed a personal communication from Daniel Stralka, EPA. The FOIA 

information also showed BLM toxicologists raised questions about the validity of the EPA 

study. The EPA study should be redone or at least reviewed by a qualified independent body. 

The OHV community cannot rely on the BLM "finding" another OHV area to replace 

CCMA. The BlueRibbon Coalition submitted formal comments on the Hollister Field Office's 

2007 Draft RMP/EIS petitioning the agency to consider OHV opportunity on lands outside of 

CCMA. However, BRC found the BLM has used a manner of reverse or circular logic to develop 

Alternative C which effectively banned OHV use on lands outside of CCMA. CCMA must be 

reopened for OHV use since the BLM has functionally eliminated motorized recreation on its 

other lands. 

The BLM/EPA has used inaccurate visitor use scenarios regarding time spent traveling on routes 

in the ACEC. They have based the human risk analysis on flawed assumptions such as stating the 

average speed dirt bikes on single track trails is 15-20 mph. Unless you are a national caliber 

rider you know speeds on single track trails average no more than 12 mph. The planning process 

must address this issue. 

The DEIS is fatally flawed because it ignored the scientific work in process at the EPA's Office of 

Solid Waste and Emergency Response to create a new risk analysis methodology for chrysotile 

since there is a growing body of scientific opinion that chrysotile is not a significant public health 

risk. This runs counter to EPA's Region 9 hypothesis that a "single fiber of chrysotile asbestos is 

as dangerous as a billion fibers of chrysotile asbestos." The BLM must analyze all current 

science before permanently closing CCMA to OHV recreation. 

In the DEIS, the BLM makes a false assumption that OHV users would not be willing to use a 

wash rack at the agency's new Decontamination Center at the entrance of CCMA. Most riders 

would jump at the chance to wash off the infamous CCMA mud/dust off their vehicles before 

leaving the area. If needed, a study should be done to analyze user compliance with a wash rack 

before assuming and incorporating that theory into an alternative. 

I support the No Action Alternative that restores historic OHV use on up to 270 miles of routes 

and approximately 450 acres of barrens. Permitted OHV events should be allowed. 

If some small health risk is identified by a new risk assessment or a review of the EPA's 2008 

report, the BLM should use signs and educational outreach as a way to inform the public rather 

than closing this important OHV area on a permanent basis. 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Response: Refer to Common Responses Section 1C, 1D, 1F(i), 2A, 2C, 3A, 3C, 3D, 4A, 4B, and 

4D. 

Blue Ribbon Coalition Form Letter 

The Environmental Study for Clear Creek Management Area failed to take into account the many 

studies showing Chrysotile should not be grouped in with other types of asbestos fibers when 

looking at potential carcinogenic properties. 

The DEIS does not contain the Cumulative Effects of the impact on other local OHV 

recreation. This must be added to the DEIS with supporting documentation. 

80% of the past visitors at Clear Creek Management Area were motorcyclists. The preferred 

alternative has no provisions for off-road motorcycle recreation. This is a total reversal of the 

current and historical use at CCMA. The preferred alternative should include a similar 

motorcycle trail mileage to what was available before the emergency closure. 

The DEIS does not contain any Economic Effects of the huge impact to regional economy like 

gas stations, restaurants, lodging, camping supplies, etc. This must be added to the DEIS with 

supporting documentation. 

The BLM has offered only one Alternative (D) proposing new singletrack trails. However the 

BLM did not choose this alternative and needs to provide the reason why. 

There is additional BLM land adjacent to the CCMA that could be opened for OHV 

recreation. Considering the drastic measures the DEIS proposes this possibility must be 

considered and added to the DEIS. 

The studies used to justify the closure of Clear Creek Management Area are based on 40 hour 

work week occupational exposure to asbestos. The visitors at CCMA are recreational users with 

possible exposure of only a couple of hours to a couple of days at a time. The BLM needs to 

consider the vastly lesser exposure of recreational visitors compared to the studies daily 

workplace exposure. 

The BLM used an EPA report based mostly on theoretical analysis of potential asbestos exposure 

hazards. There have been no documented cases of lung cancer or any other asbestos related health 

problems related to recreational exposure at Clear Creek. The BLM should not cite reports which 

are not supported by actual health cases at Clear Creek. 

There appear to be no documented cases of BLM employees diagnosed with cancer due to 

exposure at CCMA to the Chrysotile form of asbestos. These employees spend far more time in 

the area than recreational visitors, so if the employees are not experiencing related asbestos health 

problems then there must not be any real health risk. 

In the alternatives, only the ones that would allow OHV use in the CCMA call out for user 

fees. This is discriminatory double taxation. The DEIS must be changed to either eliminate all 

user fees or apply them to all users. 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

Actual health risks could be much lower than those estimated in the CCMA assessment since the 

recreation area doesn’t have the same exposure times as the studied occupational examples. The 

DEIS must consider the uncertainty rather than using worst case scenarios. 

The EPA report is flawed and should not be relied upon for the agency’s decision to enact a 

closure of the CCMA to all public use. 

Response: Refer to Common Responses Section 1F(i), 2A, 3A, 3C, and 3D. 

Center for Biological Diversity Form Letter 

Please keep Clear Creek Management Area closed to vehicles. The EPA's Asbestos Exposure and 

Human Health Risk Assessment shows that any vehicle use will exceed the EPA's acceptable 

asbestos risk levels. Clear Creek Management Area is no place for vehicles. They simply kick up 

too much carcinogenic dust. 

Maintaining a closure to vehicles will also help ensure that threats to the area's suite of rare 

plants, including the federally threatened San Benito evening primrose, will be substantially 

reduced. 

Response: Please refer to Common Responses Section 2B and 3D. 

Hobby Gem and Minerals Collectors Form Letter 

We realize that management of the Clear Creek area is a complex issue. We realize that the BLM 

is required to submit a RMP/EIS after the EPA has determined the area to be hazardous. As 

concerned citizens, we are interested in only the truth. We know that under this current 

administration, the EPA has political agendas that use science that may be flawed. We suggest 

that the BLM and the EPA recognize the publication by Geologist E.J. Fowkes, PhD published 

June 20, 2008, titles “Geological Creek Management Area, San Benito County, California”. We 

at the Coalinga Rockhounds Society have discussed this and we have come the conclusion that 

“Alternative A” is the only alternative that we prefer along with these following 

recommendations: 

XI.	 There may be some health hazards in the Clear Creek area. The magnitude of which has 

not been firmly established. Therefore we suggest that an independent laboratory be 

charged with doing a serious, scientific study, concerning the possible dangers of 

Coalinga Chrysotile asbestos.* 

D.	 Let the study “precisely delineate” all dangerous asbestos areas. 

E.	 Let roads through all dangerous areas be sealed. 

F.	 Let the study include a case study of the many past employees of the asbestos mines and 

mills that were once in operation many years ago. Many of these employees still reside in 

the Coalinga area 

4.	 Were they disabled because of asbestosis? 

5.	 Were they hospitalized with asbestosis? 

6.	 Are they now suffering ill effects of their work environment?
 

(b.) Explain their ill effect, if any.
 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

XII.	 If there be mercury processing mills where amphibole asbestos was used for insulating 

pipes or boilers, let that area be closed with fences or thoroughly cleaned up. 

XIII.	 Let rock hounds make the choice. They have read the reports and understand the risks. 

Let them decide if they are willing to accept the risk of rock hounding in the Clear Creek 

area. 

*Guidebook to Geological Resources of the Coalinga District California, Second Edition 

by E.J. Fowkes, PhD, page 52. 

XIV.	 Waver-of-Liability forms may be acceptable for rock hounds. 

XV.	 Let the Condon Peak area, the Joaquin Rock area, the east slope of the CCMA, and many 

other obviously unindustrialized areas be opened with access roads, trails, camping, and 

toilet facilities. 

C.	 Let rock hounds be permitted 24/7. 

D.	 Access restricted, by appointment only, to certain times or dates are not conducive to 

good public relations and are not acceptable. 

XVI.	 Let the public lands with grazing rights leased to local ranchers be completely open for 

rock hound use with points of access at nearest public road. 

D.	 Los Gatos Road from the Condon Peak access area to Wright Mountain with no locked 

gates. 

E.	 The roads that lead to Black Mountain/Joaquin Rocks that are gated by grazing lease 

holders be opened. 

F.	 No longer let the grazing lease holders lock out the public so that they may control said 

lands for their own personal recreational benefits. 

XVII. Let areas with endangered species be fenced off. 

XVIII.	 Archeological or sites of historical significance should be viewable but protected from 

vandals. 

C.	 This will include hieroglyphics, engravings, paintings, or other artifacts. 

D.	 High fences, posting signs, and signs explaining the artifacts significance may be 

required. 

XIX.	 Caves and mine shafts should be posted as “closed” to all visitors to the CCMA. 

XX.	 The CCMA has been used for family activity for decades. Now is a times when “family” 

is more important than ever. Do not exclude people 18 years old and younger. This 

exclusion policy is generational discrimination. 

B.	 Allow the youngest of campers, infant through 18, use of campgrounds in and around the 

CCMA to camp in areas deemed safe for camping (ie: Condon Peak, Black Mountain, 

Lion Canyon, and many others). 

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Clear Creek Management Area Appendix X 

Proposed RMP and Final EIS – Volume II 

The social and economic impact of opening this area as suggested herein would be phenomenal. 

The Clear Creek area would soon become the most used and sought after place for family 

recreation in the state of California. The BLM would receive much applause and appreciation 

from everyone for their straight forward management of this complex area. 

Response: 

Refer to BLM response to Coalinga Rockhound Society comments and/or Common Responses 

Sections 1C, 1D, 1F, 3A, 3D, and 4D. 

Hernandez Valley Property Owners Form Letter 

BLM should not select any alternative plan for the CCMA which involves the sale of any BLM 

land in the Tucker Zone, or the construction of any new roads or off highway vehicle trails in the 

area. To do so would devastate a wonderful wildlife habitat resource. It would also jeopardize 

Cane Canyon, which is eligible for inclusion in the Wild and Scenic River Inventory and must be 

protected by the BLM. 

The Tucker Zone should be used as a wildlife conservation and wilderness study area to mitigate 

the loss of wildlife habitat elsewhere in the CCMA. My family, friends and I fully support the 

East Hernandez Valley Property Owners’ February 20, 2010 Public Access Proposal for the 

Tucker Zone and encourage the BLM to adopt such Proposal. I also incorporate by reference all 

of the comments set forth in the discussion outline entitled Hemandez Valley Property Owners 

Discussion Topics for BLM Meeting submitted to BLM on February 22, 2010 in Hollister, 

California. 

Response: 

BLM received numerous comments from a consortium of private landowners and other interested 

parties concerned about the potential for disposal of public lands identified in the CCMA Draft 

RMP/EIS. Particularly, the public lands that BLM proposed to make available for disposal in the 

Tucker management zone were identified as valuable wildlife habitat and an important 

component of a successful partnership that’s being developed between private landowners and the 

California Department of Fish and Game (CDFG) in the Hernandez Valley. The HFO proposed 

disposal of the public lands surrounding Baker, Byles, and Cane Canyons in the CCMA Draft 

RMP/EIS citing the lack of administrative access and the potential to develop opportunities for 

public use and enjoyment in the Tucker management zone. However, due to the issues and 

concerns associated with disposal of these lands, they would be retained in public ownership 

under the Proposed Action and BLM would pursue partnerships with local private landowners, 

non-profit organizations, and CDFG to develop public easements to BLM public lands in the 

Tucker management zone. 

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ATTACHMENT 1 – CCMA Draft RMP/EIS Public Meetings Report
 
 

 

 

PUBLIC MEETINGS REPORT 

CLEAR CREEK MANAGEMENT AREA
 

RESOURCE MANAGEMENT PLAN & ENVIRONMENT IMPACT STATEMENT
 

MAY 2010 

PREPARED BY:
 

TETRA TECH, INC.
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

C 

TABLE OF CONTENTS 

Section Page 

1. INTRODUCTION.................................................................................................................1
 

2. BACKGROUND ..................................................................................................................1
 

3. PUBLIC INVOLVEMENT PROCESS .......................................................................................2
 

3.1 Public Meetings .....................................................................................................4
 

4. SUMMARY OF THE PUBLIC MEETINGS ON THE DRAFT CCMA RMP/EIS..............................5
 

4.1 Coalinga Public Meeting .........................................................................................5
 

4.2 Hollister Public Meeting..........................................................................................8
 

4.3 Santa Clara Public Meeting....................................................................................11
 

5. CONCLUSION..................................................................................................................16
 

LIST OF TABLES 

Table Page 

Table 1 Organizations and Affiliations Represented during the Public Meeting in Coalinga.................................. 5
 

Table 2 Speakers during the Public Meeting in Coalinga ................................................................................. 6
 

Table 3 Organizations and Affiliations Represented during the Public Meeting in Hollister .................................. 8
 

Table 4 Speakers during the Public Meeting in Hollister.................................................................................. 9
 

Table 5 Organizations and Affiliations Represented during the Public Meeting in Santa Clara ............................ 12
 

Table 6 Speakers during the Public Meeting in Santa Clara............................................................................ 12
 

APPENDICES
 

A Notice of Availability 

B List of Attendees 

Meeting Materials 

May 2010 CCMA RMP/EIS - Public Meetings Report i 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1. INTRODUCTION 

The Bureau of Land Management (BLM) Hollister Field Office, in cooperation with the 

Environmental Protection Agency (EPA), prepared a Draft Resource Management 

Plan/Environmental Impact Statement (RMP/EIS) from 2007 to 2009 to provide direction 

for managing public lands in the Clear Creek Management Area (CCMA). The Draft 

RMP/EIS was released for public review and comment on December 4, 2009. This report 

summarizes the results of three public meetings hosted by the BLM’s Hollister Field 

Office. These meetings were desgined to provide general information and gather public 

comments on the range of management alternatives considered in the Draft RMP/EIS, 

and the analysis of potential impacts on the human environment from BLM’s proposed 

management actions. 

Public involvement is an important part of the National Environmental Policy Act 

(NEPA) process. The Council on Environmental Quality (CEQ) regulations require that 

agencies will: 

•	 Make diligent efforts to involve the public in preparing and implementing their 

NEPA procedures and 

•	 Provide public notice of NEPA-related hearings, public meetings, and the 

availability of environmental documents so as to inform those persons and 

agencies who may be interested or affected. 

2. BACKGROUND 

The CCMA is in central California in the southern portion of San Benito County and the 

western portion of Fresno County. It encompasses approximately 75,000 acres, 63,000 of 

which are public land managed by the Hollister Field Office and 12,000 acres are state 

and private lands. 

Within the CCMA boundary is the Serpentine Area of Critical Environmental Concern 

(ACEC) covering approximately 30,000 acres. It was designated an ACEC with the 

approval of the 1984 Hollister RMP, which addressed the BLM’s land use decisions for 

CCMA public lands. The designation was based on the human health risk associated with 

the naturally occurring asbestos and the occurrence of special status plant species 

endemic to the area. Within the ACEC is the 450-acre Atlas Mine Site, which is listed on 

the EPA Superfund program’s National Priorities List (NPL) of hazardous waste sites 

potentially posing the greatest long-term threat to health and the environment. The ACEC 

also includes 4,147 acres of the San Benito Mountains designated as a Research Natural 

Area (RNA) because of the unique forest assemblage and vegetation communities 

associated with its serpentine soils. The RNA’s primary purpose is to provide research 

and educational opportunities, while maintaining and protecting a unique assembly of 

vegetation in as natural condition as possible. 

The Hollister RMP Record of Decision, approved in 2007, did not address land use 

decisions in the CCMA because the EPA was preparing an asbestos exposure and human 

health risk assessment to provide the BLM and the general public with information on the 

exposure levels from various types of activities in the CCMA. The study was prepared in 

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connection with the Atlas Asbestos Mine Superfund, located within the CCMA, and 

technical deficiencies of a 1992 health risk assessment that the BLM used to evaluate 

CCMA visitor’s exposure to airborne asbestos fibers in the area. The EPA released the 

CCMA Asbestos Exposure and Human Health Risk Assessment on May 1, 2008. The 

authors of the study concluded that visiting CCMA more than once per year can put 

adults and children above the EPA’s acceptable risk range for exposure to carcinogens. 

They found an increased long-term cancer risk from engaging in many of the typical 

recreational activities at the CCMA. In order to reduce risk to public land users from 

exposure to airborne asbestos, the BLM Hollister Field Office published a notice in the 

Federal register announcing the temporary closure of the CCMA to all forms of entry and 

public use. The notice stated that the order will be in effect while the BLM prepares a 

RMP/EIS for the CCMA to determine appropriate measures to minimize and reduce 

excess health risks from, visitor use on public lands in the Serpentine ACEC. 

The CCMA Draft RMP/EIS presents a range of management alternatives to address 

emerging issues in the region and evaluates the environmental consequences of these 

management alternatives, as well as the BLM’s current management of the area. The 

result of this land use planning process will be a stand-alone RMP that allocates resources 

in the CCMA area to establish the following: 

•	 Areas of limited, restricted, or exclusive use and special designations; 

•	 Allowable resource uses and related levels of production or use; 

•	 Resource condition goals and objectives; 

•	 Program constraints and general management practices needed to achieve the 

above items; 

•	 Support actions, including resource protection and public health and safety 

measures, access development, and realty actions as necessary to achieve the 

above; 

•	 General implementation sequences, where carrying out a planned action depends 

on prior accomplishment of another planned action; and 

•	 Intervals and standards for monitoring and evaluating the plan to determine its 

effectiveness and the need for amendment or revision.1 

3. PUBLIC INVOLVEMENT PROCESS 

On September 6, 2007, the BLM published the Notice of Intent (NOI) to prepare an 

RMP/EIS for the CCMA. The same day, the BLM issued a news release announcing 

three public scoping workshops. The purpose of the scoping meetings was to raise public 

awareness about the impending release of the risk assessment prepared by EPA, and to 

gather comments on appropriate management alternatives and environmental issues to be 

analyzed in the EIS. The dates and locations of each public meeting were: 

BLM. 2010. Frequently Asked Questions Concerning BLM Planning. Internet Web site: 

http://www.blm.gov/wo/st/en/prog/planning/frequently_asked_questions.html. Site Accessed April 13, 2010. 

May 2010 	 CCMA RMP/EIS - Public Meetings Report 2 

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•	 September 27, 2007, in Hollister; 

•	 October 4, 2007, in Coalinga; and 

•	 October 11, 2007, in San Jose. 

Following the release of the EPA’s Asbestos Exposure and Human Health Risk 

Assessment and the temporary closure of CCMA on May 1, 2008, the BLM announced 

three more public scoping meetings for the CCMA RMP/EIS, one of which included a 

presentation by EPA staff to explain the results of its study. The dates and location of 

each meeting were: 

•	 May 8, 2008, in Santa Clara; 

•	 May 19, 2008, in Hollister; 

•	 May 21, 2008, in San Jose. 

During these six scoping meetings, over 1,000 members of the public, mainly offhighway vehicle (OHV) users, discussed the future management of the CCMA. The 

CCMA scoping report, prepared by the BLM’s Hollister Field Office and released in 

August 2008, details the specific comments and results of the public scoping period, 

which closed on June 21, 2008. 

Based on the discussions and the comments and concerns collected during the scoping 

period, the following key themes and priorities were analyzed in the CCMA RMP/EIS, in 

addition to preliminary issues identified by BLM personnel, cooperating agencies, and 

public user groups: 

•	 Questions about chrysotile asbestos and EPA risk assessment; 

•	 Impacts on human health from asbestos exposure; 

•	 Measures to reduce and minimize risk to public health and safety; 

•	 Suitable areas for motorized and nonmotorized recreation uses; 

•	 Desired outcome for areas with high scenic and cultural values; 

•	 Protection of special status species; 

•	 Potential land tenure adjustments (acquisition and disposal); 

•	 Wildfire management strategy to protect private and public lands and resources; 

•	 Limits established for season of use, number of visitor use days/years, vehicle 

types, riding areas and trail types, and minimum age requirements; 

•	 Fluid and solid mineral development; 

•	 Impacts on watershed resources and water quality; and 

•	 Impacts on air quality in nonattainment areas. 

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On December 4, 2009, the BLM published the Notice of Availabity (see Appendix A) for 

the Draft RMP/EIS for the CCMA that announced the beginning of a 90-day public 

review period (December 4, 2009, to March 5, 2010), during which written comments are 

accepted. During the public review period the BLM Hollister Field Office hosted three 

public meetings to gather comments on the Draft RMP/EIS. All public meetings took 

place from 5:30 to 8:30 PM in the following dates and locations: 

• January 13, 2010, in Coalinga; 

• January 14, 2010, in Hollister; and, 

• January 20, 2010, in Santa Clara. 

The public comment period for the CCMA Draft RMP/EIS was extended by 45 days by 

the BLM. The end of the public review period was April 19, 2010. 

The BLM’s Hollister Field Office also hosted a Social and Economic Workshop on 

February 22, 2010 to discuss potential social and economic impacts of alternatives 

analyzed in the Draft RMP/EIS. The goal of the workshop was to provide business 

leaders, private landowners and local government representatives information about the 

draft plan and to gather their comments on social and economic impacts of public land 

use planning decisions for CCMA. The results of the social and economic workshoip will 

be summarized in a separate report and incorporated into the CCMA Proposed RMP and 

Final EIS. 

3.1	 PUBLIC MEETINGS 

The purpose of the public meetings described in this report was to gather general public 

comments on the CCMA Draft RMP/EIS. Each public meeting began with an open 

house, where the public was offered the opportunity to gather information, talk with 

BLM specialists, and provide written comments on the Draft RMP/EIS. Following the 

open house, the BLM provided a brief overview of the RMP alternatives and opened the 

verbal comment sessions. Public speakers were allowed approximately three minutes 

each to provide their comments to BLM decision-makers and the general audience 

regarding CCMA public lands and the information provided in the Draft RMP/EIS. 

Verbal comments were noted on a flipchart to capture public concerns and help 

identifying common themes. As part of the NEPA process, the BLM assesses and 

considers all comments. Public comments could influence the decision makers to: 

­ Modify alternatives including the proposed plan; 

­ Develop and evaluate alternatives not previously given serious consideration; 

­ Supplement, improve, or modify analysis; or 

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­ Make factual corrections.2 

This document provides an overview of the three public meetings held for the CCMA 

Draft RMP/EIS and summarizes the verbal comments stated during the meetings. To 

ensure that the true intent of the comment is captured, participants were asked to submit 

their comments in writing. 

Following public review and comment on the CCMA Draft RMP/EIS, the Hollister Field 

Office will prepare a Proposed RMP and Final EIS that incorporates public comments 

and other agencies’ input. A summary of all the public comments received official 

responses will be included in the CCMA Proposed RMP and Final EIS. As a result, the 

final alternative identified in the proposed RMP may be different from the Preferred 

Alternative, or any of the alternatives analyzed in the Draft RMP/EIS, and may include 

elements incorporated after public review of the Draft RMP/EIS. The proposed RMP and 

final EIS will identify any major changes to the Preferred Alternative. 

4. SUMMARY OF THE PUBLIC MEETINGS ON THE DRAFT CCMA RMP/EIS 

4.1 COALINGA PUBLIC MEETING 

The public meeting in Coalinga took place at the Harris Ranch on January 13, 2010. Over 

125 members of the public attended the meeting. Organizations and affliations 

represented during the public meeting are listed in Table 1. 

Table 1 


Organizations and Affiliations Represented during the Public Meeting in Coalinga 


AMA District 36 

American Land Aaccess Association 

America, Land of the Free 

Avenal Chimes News 

Bay Area Riders Forum 

BlueRibbon Coalition 

California Association of Four-Wheel Drive Clubs 

(Cal4) 

California OHV Commission 

California State Parks 

Central Coast Racing 

CERA 

California Federation of Mineralogical Socitey 

Coalinga Rockhound Society 

CORE Group 

Esprit de Four 

Friends of Clear Creek Area Organization 

Four-Wheel Drive South Bay Riders 

Foxshox 

Fremont Honda Kawasaki 

Fresno Gems and Mineral Society 

Ghost Riders 

GPSports 

Granite Bandits 

Hopkins and Carley 

Invisible Team of Zero 

Junnila Mines 

Leemore Gems and Mineral Club 

Los Altos Dirt Bike Riders 

Los Gatos Motorcycle Club 

OHMLRC Commission 

Racers Under the Sun 

Ridge Runners 

RMD 

Salinas Valley Rock and Gems Club 

San Francisco Gems and Mineral Society 

Santa Clara Valley Gems and Mineral Society 

Santa Cruz Gems and Mineral Society 

South Bay Riders 

Salinas Ramblers Motorcycle Club 

Timekeepers Motorcycle Club 

Three Rocks Research 

Tule Gems and Mineral Club 

US Forest Service 

Valley Trail Riders 

Viewfinders 

Zoom Cycle Accessories 

2 BLM. 2005. Land Use Planning Handbook. BLM Handbook H-1601-1. March 11, 2005. 

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The meeting started with a one-hour open house, during which personnel from the BLM 

Hollister Field Office and EPA were present to answer questions on the Draft RMP/EIS. 

At the end of the open-house session, Rick Cooper, Manager of the BLM Hollister Field 

Office, summarized the preparation of the Draft RMP/EIS and the alternatives analyzed. 

The comments session following the presentation was facilitated by a team from Tetra 

Tech, Inc., a BLM contractor. 

The number of public speakers, as presented in Table 2, was 18 and included individual 

citizens and representatives from the following organizations: Tule Gem and Mineral 

Society, Blue Ribbon Coalition, Junnila Mines, Coalinga Rockhound Society, Fresno 

Gem and Mineral Society, Lemoore Gem and Mineral Club, Avenal Chimes News, Three 

Rocks Research, AMA District 36, and California Association of Four-Wheel Drive 

Clubs. 

Table 2 


Speakers during the Public Meeting in Coalinga
 

Name Organization 

Marshal Hauner Tule Gem and Mineral Society 

Anthony Lane Tule Gem & Mineral Society 

Don Amador Blue Ribbon Coalition 

Leza Junnila Junnila Mines/Tule Gem & Mineral Society 

Gilbert Schreiner Coalinga Rockhound Society 

Bob Coates Fresno Gem and Mineral Society 

Justin Kulikov -

Judy Burson -

Jean Schrum Coalinga Rockhound Society 

Christopher L. Wertewberger Lemoore Gem and Mineral Club 

Cheryl Taylor Avenal Chimes News 

Roger Tiffin Three Rocks Research 

Scott Spencer -

John Pereira Lemoore Gem and Mineral Club 

Dave Pickett AMA District 36 

Nick Haris AMA 

Robert Adams California Association of Four Wheel Drive Clubs 

Don Colby -

The comments were mostly focused on CCMA temporary closure and inaccessibility to 

OHVs and gem collectors, validity of the risk assessment study, impacts of the closure on 

gem collectors, and the limited review period of the Draft RMP/EIS. 

CCMA Temporary Closure and Inaccessibility to Public Lands 

Most of the speakers asked for the reopening of the CCMA to the public. They described 

the temporary closure as a premature or “Why would the BLM close parks 

incorrect decision. The speakers expressed when we suffer so much from over 

their attachment to and appreciation of the crowded OHV?” Michael Soberanes 

CCMA and noted that people had more 

access to the area 20 years ago. Speakers noted that several generations in their families 

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have been visiting the CCMA. Jean Schrum, representing the Coalinga Rockhound 

Society, suggested signing a waiver that notifies users of health risks incurred from 

visiting the CCMA and indemnifies the BLM. Bob Coates, from the Fresno Gem and 

Mineral Society, also suggested using a waiver and compared it to the state health 

advisory for fish caught in San Francisco Bay or to the health warning labels on 

cigarettes packages. 

Scott Spencer noted that the CCMA is unique for off-road sports. It allows for technical 

riding, which is not available in other off-road areas in the region, such as Hollister Hills 

State Vehicular Recreation Area (SVRA). Robert Adams, from the California 

Association of Four Wheel Drive Clubs, mentioned the impacts on other recreational 

areas in the region resulting from the temporary closure of the CCMA. He noted that 

most of the riding areas in the region are under pressure and if the CCMA becomes 

restricted, it should not be restricted to one group of users. John Pereira, from Lemoore 

Gem and Mineral Club, mentioned that restrictions are increasing on other recreational 

areas in the deserts, mountains, and coastal areas within the region. 

Jean Schrum, from the Coalinga Rockhound Society, also noted the importance of the 

CCMA as a recreation resource to alleviate stress and secondary effects of the current 

economic crisis. He noted that those living in surrounding counties, such as Merced, San 

Benito, and Kern, are undergoing substantive stress due to the unfavorable economic 

climate. 

Validity of the Risk Assessment Study 

Speakers presented their concerns with the results and integrity of the asbestos exposure 

and health risk assessment prepared by the EPA. Robert Adams, from the California 

Association of Four Wheel Drive Clubs, questioned why the BLM relies on only one 

study and asked who is reviewing and confirming the results of this study. Gilbert 

Schreiner, from the Coalinga Rockhound Society, noted that the EPA has made previous 

wrong decisions, such as evacuating a town in Missouri for health concerns from 

dangerous levels of dioxin contamination. Minimum age requirements to reduce asbestos 

exposure to children, as analyzed in the Draft RMP/EIS was also a concern. Judy Burson 

questioned the validity of this type of limitation, and others concerned with the integrity 

of the study asked why the CCMA was not closed when other mines were closed, such as 

the Atlas mine. 

“I would like some tangible proof that 

the asbestos in Clear Creek has Jean Schrum also stated that the chrysotile harmed anyone ” Cheryl Taylor – asbestos at the CCMA is not harmful, and Avenal Chimes Newspapers smoking cigarettes could cause more health 

damage. They noted that there is no proof of disease related to this type of asbestos or 

associated with the CCMA. Roger Tiffin, from Three Rock Research, indicated that his 

family has been visiting the CCMA for over 27 years with no respiratory ailments. 

Cheryl Taylor, from Avenal Chimes News, noted that, despite the health risk factor, most 

often the BLM has four or five trucks in the area, while in the past only one BLM truck 

could be seen visiting the CCMA. 

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Impacts of the Temporary Closure and Restriction Use on Gem Collectors 

Jean Schrum, from the Coalinga Rockhound Society, expressed concerns with the 

economic and social impacts of the CCMA temporary closure. Leza Junnila, from the 

Junnila Mines and Tule Gem and Mineral Society, indicated that the CCMA is a vast 

resource of gems and minerals, with such gems as benitoite and fresnoite. Several 

speakers indicated that rockhounding is their 

source of income for their families. They “I support application of an alternate 

pointed to the need for vehicular access in action that would allow access in a 

limited manner keeping safety and CCMA because most rockhounds are older 

access as viable solutions. I support and cannot hike several miles carrying the application proposed under materials to and from rockhounding Alternative B” Anthony Lane – Tule locations, so restricting vehicles in CCMA Gem Club 

would make it impossible for them to 


continue rockhounding there.
 

Roger Tiffin, from Three Rocks Research, noted that miners had a court rule in their 

favor and they should be allowed into the CCMA. 

Public Involvement 

Roger Tiffin, from Three Rocks Research, noted his concerns with the size of the CCMA 

Draft RMP/EIS and the relatively short public review period. He also noted that a portion 

of the public review period occurred during the holiday season. Don Colby said that 

interested groups, such as motorcycle dealers, were not notified about the release of the 

Draft RMP/EIS. Nick Haris, from AMA, stated that the information presented during the 

scoping meeting in San Jose was more elaborate that presented during the public meeting. 

Don Amador, from the Blue Ribbon Coalition, noted that comments and information 

provided during the scoping process were not considered in the EIS analysis. Dave 

Pickett, from AMA District 36, noted the importance of providing good and substantive 

comments. 

4.2	 HOLLISTER PUBLIC MEETING 

The public meeting in Hollister took place at the Veterans Memorial Hall on January 14, 

2010. Over 290 members of the public attended. Organizations and affliations 

represented during the public meeting are listed in Table 3 below. 

Table 3 


Organizations and Affiliations Represented during the Public Meeting in Hollister
 

AMA District 36 Hollister Motorsports 

Bay Area Mineralogists Jolly Roger Racing 

BC BOYZ Los Altos Dirt Bike Riders 

California Association of Four-Wheel Drive Clubs Mountaineers Foundation 

(Cal4) Motion Pro 

California Motorcycle Company Motorcycle Touring Association 

California Native Plant Society Phantom Duck 

California State Parks - Hollister Hills State Vehicular Pinit Motorsports 

Recreational Area Salinas Ramblers Motorcycle Club 

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California Off-Road Vehicle Association Salinas Valley Rock and Gem Club 

Center for Off-Highway Land Recovery and Readiness San Benito County 

Engines Only Santa Clara Riders unlimited 

El Scorcho Motorcycle Club Santa Clara Valley Gems and Mineral Society 

Faultline Powersports Save Clear Creek Group 

Friends of Clear Creek Management Area South Bay Riders 

High Gear San Benito Couty Parks and Recreation 

Hollister Honda Team Beefy 

Hollister Hills Off-Road Association Timekeepers Motorcycle Club 

Hollister Hills Volunteers Patrol Three Rocks Research 

Similar to the Coalinga meeting, the meeting in Hollister started with a one-hour open 

house during which personnel from the BLM Hollister Field Office and EPA answered 

questions on the Draft RMP/EIS. At the end of the open-house session, Rick Cooper, 

Manager of the BLM Hollister Field Office, summarized the Draft RMP/EIS and the 

alternatives analyzed. The verbal comment session following the presentation was 

facilitated by a team from Tetra Tech. 

The number of public speakers, as presented in Table 4, was 21 and included individual 

citizens and representatives from the following organizations: Timekeepers Motorcycle 

Club, Friends of Clear Creek Management Area, Three Rocks Research, Salinas 

Ramblers Motorcycle Club, California Association of Four-Wheel Drive Clubs, Salinas 

Valley Rock and Gem Club, and Salinas Ramblers Motorcycle Club. 

Table 4 


Speakers during the Public Meeting in Hollister
 

Name Organization 

Ross Ross Timekeepers Motorcycle Club
 

Ed Tobin Friends of Clear Creek Management Area
 

Ray Iddings Three Rocks Research
 

Ron Dashazer Salinas Ramblers Motorcycle Club
 

Jim Strenfel Timekeepers Motorcycle Club
 

Lowell Webb ­

Eric Overeem ­

Jay Jacobson Adobe Ranch 

Amy Granat California Association of Four-Wheel Drive Clubs 

Jeff Holmbeck ­

John Loreur ­

William Borst ­

Ron Berzemen -

Jeret Shuck ­

Sam Bryantino ­

Tyler Pim ­

Jennifer Shreck ­

Randy Beremen ­

Gary Beck Salinas Valley Rock and Gem Club 

Benny King Salinas Ramblers Motorcycle Club
 

Miguel Flores ­

Brian LeNeve ­

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The comment topics were mostly focused on CCMA temporary closure and 

inaccessibility to OHVs, OHV use of the CCMA, validity of the risk assessment, public 

involvement, cultural value of the CCMA, deer hunting, and economic impacts. 

CCMA Temporary Closure and Inaccessibility to Public Lands 

Ed Tobin, from the Friends of the CCMA, asked for the reopening of the CCMA and 

noted that it is better to continue using the CCMA than to allow the use of undisturbed 

areas. Ray Iddings, from Three Rocks Research, noted that Congress guaranteed a rightof-way on all public lands. Ron Deshazer, from the Salinas Ramblers Motorcycle Club, 

and Sam Bryantino indicated that access to the area should be regulated in a way to the 

way alcohol and cigarettes are regulated, by notifying users about the health risks on the 

product labels. 

Jim Strenfel, from Timekeepers, and Lowell Webb noted the scarcity of available public 

lands and parks in the area near the CCMA. Lowell Webb noted that, as a result of lands 

designated as wilderness and buffer areas, no public land is left. William Borst stated that 

the BLM has been looking for reasons to close the CCMA for 15 years. Ron Berzeman 

and Tyler Pim noted that it is the public’s right to recreate in this land and asked for a 

way to protect their rights. “I still believe that OHV and the 

environment can coexist and both use 

Ron Berzeman said that they are doing their the same land, provided that the OHV 

part to maintain and preserve the CCMA community lives by the rules set 

area. Jay Jacobson, from Adobe Ranch, noted down” Brian LeNeve 

that many illegal activities are happening at 

the CCMA and the presence of people would help in reducing those activities. 

OHV Use of the CCMA 

Brian LeNeve, from the California Native Plant Society, noted in a letter read by Ed 

Tobin, that OHV users and environmental communities can coexist at the CCMA, and 

asked for the allowance of some sort of riding. Most of the speakers noted the importance 

and the uniqueness of the CCMA as a world class OHV area. Ron Deshazer, from the 

Salinas Ramblers Motorcycle Club, stated that 12 motorcycle shops will be closing as a 

result of the CCMA permanent closure. 

Validity of the Risk Assessment Study 

Many speakers were concerned about the adequacy of the EPA health risk assessment 

study. Amy Granat from the California Association of Four Wheel Drive Clubs, asked 

about the scientific evidence stated in the EPA document and the method used in the 

analysis. Ray Iddings, from the Three Rocks Research, noted that no illness related to 

asbestos has been identified yet. Ron Deshazer, from the Salinas Ramblers Motorcycle 

Club, and Sam Bryantino asked to approach this health-risk issue in the same way as 

tobacco and alcohol products, where a notification on each product warns about the 

health risk danger. 

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Public Involvement 

Ross Ross, from the Timekeepers, noted his preference for a public question and answer 

session during the public meeting, as compared to the open house session, where the 

discussions with the BLM personnel were on a person-to-person basis. 

Jeff Holmbeck said that comments provided during the scoping period were not 

considered in the Draft RMP/EIS. John Loreur noted that his comments were not 

considered in the process of alternatives selection. Miguel Flores was concerned that the 

Draft RMP/EIS does not include input on the EPA health risk assessment report from the 

public and the BLM. Ron Deshazer, from the Salinas Ramblers Motorcycle Club, noted 

that the BLM should listen to the taxpayers and questioned the BLM’s partnership goals. 

Eric Overeem questioned the process and noted that the document is extremely 

complicated. He noted that the executive summary referred to other documents and 

requested to review the reference materials. Ron Berzeman stated that none of the 

alternatives in the Draft RMP/EIS would allow for organized OHV events in the CCMA. 

Ron Deshazer, from the Salinas Ramblers Motorcycle Club, expressed his concern with 

the Draft RMP/EIS size and the time allocated for the review period. Amy Granat, from 

the California Association of Four Wheel Drive Clubs, said that 30 percent of the review 

period was during the holidays. She offered help to other community members in writing 

comments and encouraged participation in the comment process. 

Cultural Value of the CCMA 

Ray Iddings, from Three Rocks Research, noted that the CCMA is a part of California 

heritage and is home to many civilizations, such as Indian, German, and Irish. He noted 

the importance of people’s continuing presence at the CCMA in relation to the heritage. 

He said that the CCMA has historic roads under the county’s jurisdiction that were 

previously public roads. 

Deer Hunting 

A local landowner with property adjacent to CCMA expressed concerns about the lack of 

opportunities for deer hunters anymore at the CCMA, and requested that BLM consider 

this recreational resource be included in the CCMA land use plan. 

Economic Impacts 

John Loreur noted that the Draft RMP/EIS does not address the economic impacts on 

small business owners within the region. He said that organizations such as the Salinas 

Valley Rock and Gem Club include approximately 400,000 people. 

4.3	 SANTA CLARA PUBLIC MEETING 

The public meeting in Santa Clara took place at the Santa Clara Convention Center on 

January 20, 2010. Over 400 members of the public attended the meeting. Organizations 

and affliations represented during the public meeting are listed in Table 5. 

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Table 5
 

Organizations and Affiliations Represented during the Public Meeting in Santa Clara
 

American Land Access Association GP Sports 

AMA District 36 Granite Bandits 

America, Land of the Free Hopkins and Carley 

Bay Area Mineralogists Invisable Team of Zero 

Bay Area Riders Forum Los Gatos Motorcycle Club 

Blue Ribbon Coalition Los Altos Dirt Bike Riders 

California Association of Four-Wheel Drive Clubs Over the Hill Gang Bay Area Chapter 

California Federation of Mineralogical Societies, Inc. Racers Under the Sun Central Coast 

California State Parks—Hollister Hills SVRA Ridge Runners Motorcycle 

California Off-Highway Motor Vehicle Recreation Salinas Ramblers Motorcycle Club 

Commission Salinas Valley Rock and Gem Club 

Central Coast Racing San Francisco Gem and Mineral Society 

California Enduro Riders Association Santa Clara Valley Gem and Mineral Society 

Carnegie Off-Road Enthusiasts Santa Cruz Gem and Mineral Society 

DirtDogs South Bay Riders Forum 

Earth Treasures Timekeepers Motorcycle Club 

Esprit de Four US Forest Service 

Fox Shox Valley Trail Riders 

Fremont Honda Kawasaki Viewfinders Motorcycle Club 

Friends of Clear Creek Management Area Zoom Cycle Accessories 

Ghostriders, Inc. 

Similar to the previous two meetings in Coalinga and Hollister, the meeting in Santa 

Clara started with a one-hour open house, during which personnel from the BLM 

Hollister Field Office and EPA answered questions on the Draft RMP/EIS. At the end of 

the open house, Rick Cooper, Manager of BLM Hollister Field Office, summarized the 

Draft RMP/EIS and the alternatives analyzed. The verbal comment session following the 

presentation was facilitated by a team from Tetra Tech. 

There were 26 public speakers, as presented in Table 6, including citizens and 

representatives from the following organizations: BlueRibbon Coalition, American Land 

Access Association, California Federation of Mineralogical Societies, Carnegie Off-Road 

Enthusiasts, Salinas Ramblers Motorcycle Club, Timekeepers Motorcycle Club, Friends 

of Clear Creek Management Area, Bay Area Riders Forum, Los Altos Dirt Bike Riders, 

and California Association of Four Wheel Drive Clubs. 

Table 6
 

Speakers during the Public Meeting in Santa Clara
 

Name Organization 

Don Amador BlueRibbon Coalition 

Dan Brown ALAA/CFMS 

Dave Duffin Carnegie Off-Road Enthousiasts 

Allan Diehr Save Clear Creek 

Ron DeShazer Salinas Ramblers Motorcycle Club 

Gary Willard -

Ross Ross Timekeepers Motorcycle Club 

Justin Hensley -

Mark Rael -

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Table 6
 

Speakers during the Public Meeting in Santa Clara
 

Name Organization 

Ed Tobin Friends of Clear Creak Management Area 

Terry Pederson Timekeepers Motorcycle Club 

Butch Meyner Bay Area Riders Forum 

Bruce Brazil Carnegie Off-Road Enthusiasts 

Kevin Murphy -

Josephine Marriner -

Jim Strenfel -

David Doudna -

Kane Silverberg -

Charles Luhrman -

Elsa Claire Williams -

Kendra Williams -

Lowell Webb -

Ben Ellis Los Altos Dirt Bike Riders 

Steven Alebo -

Amy Granat -

Rena Bettran -

The comments topics were mostly focused on CCMA temporary closure and 

inaccessibility to OHVs and gem collectors, validity of the risk assessment study, OHV 

riding at the CCMA, importance of the CCMA as a mineral resource, public involvement, 

socioeconomic impacts, and consultations. 

CCMA Temporary Closure and Inaccessibility to Public Lands 

Speakers expressed their strong concern about the temporary closure of the CCMA. They 

described this closure as a political process that is not related to health risks. Don 

Amador, from the Blue Ribbon Coalition, read a letter from a Vietnam Veteran who 

noted that his family is devastated with this closure. His daughter’s wish, upon return 

from the Desert Storm Mission, was to ride in the CCMA. Those attending unanimously 

supported the reopening of the CCMA as one of the speakers requested a show of hands. 

Ron Deshazer, from the Salinas Ramblers Motorcycle Club, and Justin Hensley called for 

a protest near the CCMA on May 2. Justin Hensley asked the audience to fight for the 

freedom of using public lands. 

Dave Duffin, from the Carnegie Off Road Enthousiasts, described the CCMA as a good 

solid form of recreation. Allan Diehr noted that other recreation areas in the region, such 

as national forests, are also going through a route designation process that could 

substantially reduce the available recreation areas. Kendra Williams emphasized the 

connection between outdoor recreation and current social issues, such as obesity. Two 

children, Elsa Williams and Josephine Marriner, asked for the reopening of the CCMA 

and encouraged others to join the effort for the purpose of restoring access to the CCMA. 

Ross Ross, from the Timkeepers, noted that the CCMA temporary closure is enabling 

illegal activities in the area, such as the cultivation of marijuana. 

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Validity of the Risk Assessment Study 

The speakers noted their concern with the EPA health risk assessment and the 

conclusions presented in the Draft RMP/EIS. Terry Pederson, from Timekeepers, Amy 

Granat, from the California Association of Four Wheel Drive Clubs, and Dan Brown, 

from ALAA, said that the conclusions of the EPA analysis are faulty and do not consider 

the variation in health risks in relation to the different groups of asbestos fibers. The 

speakers said that the type of asbestos in the CCMA is chrysotile, and neither the EPA 

document nor the Draft RMP/EIS account for the different types of asbestos fibers. Ed 

Tobin, from the Friend of the CCMA, noted that the short-term exposure to the chrysotile 

asbestos fiber is not harmful. Dan Brown, from ALAA, also indicated that this type of 

asbestos is not carcinogenic, according to several medical societies. Allan Diehr stated 

that no history of illness in relation to asbestos exposure at the CCMA has been proved. 

He noted that hundreds of visitors have been coming to the CCMA for over 40 years, 

with no reported diseases. He asked for epidemiological reports that document diseases 

linked to the asbestos in the CCMA. David Doudna said that the risk of a fatal vehicle 

accident driving along Highways 101 and 25 are far greater than the health risk from 

asbestos exposure in the CCMA. 

Ross Ross said that the risk assessment model used in the EPA document is flawed and 

illogical. Bruce Brazil, from the Carnegie Off Road Enthusiasts, said that previous 

discussions showed uncertainty in the toxicity of asbestos, and Kane Silverberg asked for 

a peer entity to conduct a risk assessment study and assess the analysis provided in the 

EPA document. Steven Alebo asked for sampling to be conducted during wet periods 

when less dust is present in the air. He said that the BLM was collecting asbestos samples 

during a very dusty month, and the resulting analysis concluded that asbestos levels are 

very high. Amy Granat, from the California Association of Four Wheel Drive Clubs, 

noted that the risk estimate pertains to heavy industrial exposure to asbestos and not to 

the type of asbestos found in the CCMA and not the kind of exposure of visitors to this 

area. 

Kane Silverberg expressed his concerns with the interpretation of the EPA report in the 

Draft RMP/EIS. He asked why the BLM is relying on only one report. He said that the 

EPA has made other statements about short-term and long-term exposure to asbestos that 

were not included in the Draft RMP/EIS. Speakers noted their concerns with the selection 

of the preferred alternative and its lack of OHV opportunities. They asked to consider 

another way to limit the risk, such as encapsulation or remediation. 

OHV Use of the CCMA 

Speakers noted the importance of OHV recreation in California. Allan Deihr from Save 

Clear Creek stated that 14.2 percent of California households are OHV users and 80 

percent of the CCMA visitors are OHV riders. He added that there are no OHV recreation 

opportunities on the other public lands administered by the Hollister Field Office. Jim 

Strenfel, from Timekeepers, noted that Santa Clara County alone has 26,000 registered 

OHV riders. Don Amador from the Blue Ribbon Coalition read a letter from a Vietnam 

veteran colleague, who noted that his daughter’s wish, upon returning from Desert Storm, 

was to ride in the CCMA once again. Most of those attending indicated that they have 

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been riding for 20, 30, or 40 years and described the uniqueness of the CCMA and their 

attachment to this land and the OHV sport. Speakers also noted their continuous care and 

attention in preserving the CCMA and keeping it clean. 

Gary Willard said that the OHV program is under a lot of pressure, and the CCMA has a 

great importance to this program. Jim Strenfel, from Timekeepers, stated that only 4 out 

of 13,000 acres of BLM land are for OHV use. He asked those in attendance for their 

opinion on the CCMA temporary closure. The unanimous opinion was to reopen the 

CCMA. Children were present among the speakers and noted their interest in riding at a 

very young age (4 years) and the importance of this sport on the parent-child relation and 

family values. Speakers, including the children, noted that riding is healthier than 

watching TV. They noted that children cannot play outside their homes freely and need 

open spaces such as the CCMA to play and learn about nature. 

Ron Deshazer, from the Salinas Ramblers Motorcycle Club, expressed his will to work 

with the BLM toward a resolution. He indicated that OHV riders cooperated with the 

BLM when they started closing the CCMA for certain days and when they added a fee to 

ride in the CCMA. He is concerned with the continuous increase in restrictions. He noted 

that health risks associated with dust could be reduced by enforcing a speed limit in the 

CCMA. 

Ed Tobin, from Friends of the CCMA, stated that a toxicologist suggested an alternative 

of OHV access to the CCMA during weekends instead of five weekdays. This alternative 

was not analyzed in the Draft RMP/EIS. Terry Pederson, from Timekeepers, noted that 

the EPA report is overestimating the ration of time with speed average. He added that the 

report uses 20 miles per hour during 6 hours per day. He stated that the average speed 

during a race is 15 miles per hour and that a person would ride at the CCMA an average 

of 3 to 4 hours a day at a 12 miles per hour. 

Bruce Brazil, from the OHV community, noted that the Draft RMP/EIS is biased and 

against OHV riding. He said the only alternative presented in the Draft RMP/EIS that 

does not propose access fees does not include OHV use, and that the conclusion of the 

Draft RMP/EIS should be the result of a thorough analysis of the data and the sources and 

methods used to get these data. David Doudna asked for the definition of “full-sized” 

vehicles, as used in the Draft RMP/EIS. He noted that they had to ask about the definition 

during the open house session of the public meeting. He felt that the BLM definition 

really means “no motorcycles”, and there is no justification in the document for 

restricting the use of this type of vehicle. 

Speakers noted the impacts of the CCMA temporary closure. Gary Willard stated that it 

is increasing the impacts on other areas. Ben Ellis, from Los Altos Dirt Bike Riders, 

called for the support of an alternative that would allow OHV use. 

Importance of the CCMA as a mineral resource 

Speakers representing rockhounds stressed the importance of the CCMA as a unique 

mineral resource. Dan Brown, from ALAA, stated the CCMA is the most mineralized 

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area in the California, containing over 500 minerals, and that the Draft RMP/EIS does not 

include any alternative that suits the rockhounders needs. He asked for a balanced 

alternative that addresses all the needs. 

Public Involvement 

Dave Duffin from Core Carnegie Off Road Enthusiasts noted that the best comment 

made during the scoping meeting was that BLM and EPA did not answer any of the 

questions. Gary Willard and Charles Luhrman asked for an extension of the review 

period. Amy Granat, from the California Association of Four Wheel Drive Clubs, and 

Ross Ross, from Timekeepers, encouraged the participants to engage in the 

environmental review process and to provide comments on the Draft RMP/EIS. Ed 

Tobin, from the Friend of CCMA, and Ross Ross, from Timekeepers, encouraged 

participants to donate to the CCMA organizations to help protest the temporary closure 

and file lawsuits if needed. Amy Granat offered help in drafting comments and provided 

guidance on substantive comments. 

Gary Willard, of the California OHV Commission, expressed his personal 

disappointment with the process and said that there should have been a more detailed 

overview of the alternatives during the public meeting. 

Socioeconomic Impacts 

Terry Pederson, from Timekeepers, noted “When Clear Creek closed our gross that the Draft RMP/EIS does not include an sales plummeted 40 percent. We alternative that is economically viable. catered to hundreds of Clear Creek 

riders who purchased gear, tires, Kevin Murphy, from America Land of the number for races, clothing, etc ” 

Free, stated that the Draft RMP/EIS does not Danny Danning – Zoom Cycles 

consider impacts on families and children. He Accessories. 

asked why the BLM would prohibit one of 

the healthiest ways for a family to spend a weekend. 

Consultation Process 

Bruce Brazil, from CERA, expressed his concern with the socioeconomic meeting that 

the BLM had scheduled during February and noted that this meeting with local 

governments should have been done long ago. 

5. CONCLUSION 

The public meetings served to gather the public comments and concerns regarding the 

alternatives analyzed in the Draft RMP/EIS. Most of the comments were related to the 

temporary closure of the CCMA, validity of the health risk assessment, and public 

involvement in the NEPA process. In general, the comments reflected local social and 

economic impacts of the temporary closure. 

As noted above, the Hollister Field Office will prepare a Proposed RMP and Final EIS 

that incorporates public comments and other agencies’ input. A summary of all the 

written public comments received and official responses will be included in the CCMA 

May 2010 CCMA RMP/EIS - Public Meetings Report 16 
 

 

 

 

Proposed RMP and Final EIS. As a result, the final land use decision for the CCMA may 

be different from the Preferred Alternative analyzed in the Draft RMP/EIS. The proposed 

RMP and final EIS will identify any major changes to the Preferred Alternative. 

May 2010 CCMA RMP/EIS - Public Meetings Report 17 
 

APPENDIX A 

NOTICE OF AVAILABILITY 
           

             

                

     

     

  

                                   

                                                 

                                   

                           

                                                 

                                           

                               

                               

                       

   

                                           

                                             

                           

                               

                                             

                                           

                                     

                                       

       

     

                                           

                                           

                                                 

                                           

   

     

                                       

                                               

                                       

                    

                                                   

   

   

           

             

   

                                               

                                             

Notice of Availability of Draft Resource Management Plan and Draft Environmental Imp ... Page 1 of1 

U.S. DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT

California

Print Page

[Federal Register: December 4, 2009 (Volume 74, Number 232)]
 

[Notices]
 

[Page 63764­63765]
 

DEPARTMENT OF THE INTERIOR
 

Bureau of Land Management
 

[LLCAC09000 L16100000.DP0000]
 

Notice of Availability of Draft Resource Management Plan and Draft Environmental Impact Statement for the Clear Creek Management Area, CA

SUMMARY: In accordance with the National Environmental Policy Act of 1969 and the Federal Land Policy and Management Act of 1976, the Bureau of Land

Management (BLM) has prepared a Draft Resource Management Plan and Draft Environmental Impact Statement (RMP/EIS) for the Clear Creek Management

Area (CCMA), and by this notice, announces the opening of the public comment period.

DATES: To ensure that comments will be considered, the BLM must receive written comments on the Draft RMP/EIS within 90 days following the date the

Environmental Protection Agency publishes its Notice of Availability in the Federal Register. The BLM will announce future meetings or hearings and any other

public involvement activities at least 15 days in advance through public notices, media news releases, and/or mailings.

ADDRESSES: You may submit comments at the public meetings or by any of the following methods:

Mail Address: BLM Hollister Field Office, 20 Hamilton Court, Hollister, California 95023.
 

E­mail: cahormp@ca.blm.gov.
 

Fax: (831) 630­5055.
 

The CCMA Draft RMP/EIS is available on­line at: http://www.ca.blm.gov/hollister. Compact discs (CDs) of the CCMA Draft RMP/EIS are available at the Hollister

Field Office at the above address; CD copies are also available at the BLM California State Office, 2800 Cottage Way, Sacramento, California 95825.

FOR FURTHER INFORMATION CONTACT: Sky Murphy, BLM Hollister Field Office, 20 Hamilton Court, Hollister, California 95023, (831) 630­5039.

SUPPLEMENTARY INFORMATION: The planning area covers approximately 75,000 surface acres and approximately 3,500 acres of subsurface mineral

estate in San Benito and Fresno counties, California. The CCMA RMP, when completed, will provide management guidance for use and protection of the

resources managed by the Hollister Field Office. The CCMA Draft RMP/EIS has been developed through a collaborative planning process among local, State,

and Federal agencies and considers seven alternatives. The primary issues addressed include public health and safety, recreation, protection of sensitive

natural and cultural resources, livestock grazing, guidance for energy and mineral development, land tenure adjustments, and other planning issues raised

during the scoping process.

The Draft RMP/EIS also designates an Area of Critical Environmental Concern (ACEC). The preferred alternative would carry forward the designation of the

existing 30,200­acre Clear Creek Serpentine ACEC to protect public health and safety and other resource values identified in the Draft RMP/EIS. Restrictions on

the use of public lands within the Serpentine ACEC to minimize human health risks from exposure to asbestos and reduce airborne emissions of asbestos from

BLM management activities vary among the range of alternatives, but are likely to include limitations on motorized vehicle use and many other surface

disturbing activities.

Please note that public comments and information submitted including names, street addresses, and e­mail addresses of respondents will be available for

public review and disclosure at the above address during regular business hours (8 a.m. to 4 p.m.), Monday through Friday, except holidays. Before including

your address, phone number, e­mail address, or other personal identifying information in your comment, you should be aware that your entire comment­­

including your personal identifying information­­may be made publicly available at any

time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to

do so.

Dianna Brink,
 

Acting Deputy State Director for Natural Resources.
 

[FR Doc. E9­28867 Filed 12­3­09; 8:45 am]
 

Last updated: 12­04­2009

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sroberts on DSKD5P82C1PROD with NOTICES

Federal Register / Vol. 75, No. 67 / Thursday, April 8, 2010 / Notices 17951 

Decision). The matter has been stayed 

during settlement negotiations. The 

Ninth Circuit stayed litigation regarding 

similar challenges to the Lakeview RMP 

in Oregon Natural Desert Association v. 

Gammon, No. 07–35728 (9th Cir.), 

pending resolution of the Southeastern 

Oregon RMP case, and to allow for 

settlement negotiations between the 

parties. The BLM is preparing RMP 

Amendments/EISs consistent with the 

2008 holding of the Ninth Circuit. 

The two RMP Amendments/EISs plan 

to address the following issues: 

• Consideration of information from 

updates of resource information related 

to wilderness characteristics; 

• Development of a range of 

allocation alternatives with respect to 

ORV use, travel, and transportation; and 

• Development of grazing 

management alternative(s). 

The purpose of the public scoping 

processes is to determine other relevant 

issues that will influence the scope of 

the environmental analyses, including 

alternatives, and guide the planning 

processes. 

The BLM has also identified some 

preliminary planning criteria to guide 

development of the RMP Amendments, 

to avoid unnecessary data collection 

and analysis, and to ensure the RMP 

Amendments are tailored to the issues. 

These criteria may be modified and/or 

other criteria may be identified during 

the public scoping process. Preliminary 

planning criteria include compliance 

with all legal mandates of the FLPMA, 

the NEPA, the Federal Advisory 

Committee Act, the Administrative 

Procedures Act, the BLM planning 

regulations in 43 CFR part 1600, and 

other relevant laws. The following 

planning criteria will also guide the 

planning processes: 

• The principles of multiple-use and 

sustained yield will be observed; 

• A systematic interdisciplinary 

approach to integrate, physical, 

biological, economic, and other sciences 

will be used; 

• Priority will be given to the 

designation and protection of Areas of 

Critical Environmental Concern; 

• The best available data regarding 

natural resources will be used, to the 

extent possible; 

• Present and potential uses of public 

lands will be considered; 

• The relative scarcity of values and 

availability of alternative means and 

sites for recognizing those values will be 

considered; 

• Long term benefits to the public 

against short term benefits will be 

weighed; 

• Tribal, Federal, and state pollution 

laws, standards and implementation 

plans will be complied with, to the 

extent possible; and 

• Consistency and coordination with 

other programs, plans and policies will 

be sought. 

You may submit comments on issues 

and planning criteria in writing to the 

BLM at any public scoping meeting, or 

you may submit them to the BLM using 

one of the methods listed in the 

ADDRESSES section above. To be most 

helpful, you should submit comments 

either prior to the close of the 90-day 

scoping period or within 30 days after 

the last public meeting. Before 

including your address, phone number, 

e-mail address, or other personal 

identifying information in your 

comment, you should be aware that 

your entire comment—including your 

personal identifying information—may 

be made publicly available at any time. 

While you can ask us in your comment 

to withhold your personal identifying 

information from public review, we 

cannot guarantee that we will be able to 

do so. The minutes and list of attendees 

for each scoping meeting will be 

available to the public and open for 30 

days after the meeting to any participant 

who wishes to clarify the views he or 

she expressed. The BLM will evaluate 

identified issues to be addressed in the 

RMP Amendments, and will place them 

into one of three categories: 

1. Issues to be resolved in the plan 

amendment; 

2. Issues to be resolved through policy 

or administrative action; or 

3. Issues beyond the scope of the plan 

amendments. 

The BLM will provide an explanation 

in the Draft RMP Amendments/EISs as 

to why an issue was placed in category 

two or three. The public is also 

encouraged to help identify any 

management questions and concerns 

that should be addressed in the RMP 

Amendments. The BLM will work 

collaboratively with interested parties to 

identify the management decisions that 

are best suited to local, regional, and 

national needs and concerns. 

The BLM will use an interdisciplinary 

approach to develop the RMP 

Amendments in order to consider the 

variety of resource issues and concerns 

identified. At a minimum, specialists 

with expertise in the following 

disciplines will be involved in the 

planning processes: Rangeland 

management, wilderness, travel 

management, recreation, and wildlife. 

Authority: 40 CFR 1501.7; 43 CFR 1610.2. 

Larry Frazier, 

Acting Vale District Manager. 

Carol Benkosky, 

Lakeview District Manager. 

[FR Doc. 2010–7986 Filed 4–7–10; 8:45 am] 

BILLING CODE 4310–33–P 

DEPARTMENT OF THE INTERIOR 

Bureau of Land Management 

[LLCAC09000 L16100000.DP0000] 

Notice Re-opening the Comment 

Period for the Draft Resource 

Management Plan and Draft 

Environmental Impact Statement for 

the Clear Creek Management Area, 

California 

AGENCY: Bureau of Land Management, 

Interior. 

ACTION: Notice. 

SUMMARY: The Bureau of Land 

Management (BLM) announces a reopening of the comment period on the 

Draft Resource Management Plan (RMP) 

and Draft Environmental Impact 

Statement (EIS) for the Clear Creek 

Management Area (CCMA). The original 

notice was published in the Federal 

Register on December 4, 2009 [74 FR 

0232] and provided for a comment 

period to end on March 5, 2010. The 

BLM is re-opening the comment period 

to end April 19, 2010. 

FOR FURTHER INFORMATION CONTACT: Sky 

Murphy, BLM Hollister Field Office, 20 

Hamilton Court, Hollister, California 

95023, (831) 630–5039. 

SUPPLEMENTARY INFORMATION: The 

original Notice of Availability provided 

for comments on the Draft RMP/Draft 

EIS to be received through March 5, 

2010. The BLM is re-opening the 

comment period in response to and in 

light of the land use restrictions 

considered in the plan. Comments on 

the Draft RMP and EIS will now be 

accepted through April 19, 2010. 

Karen Montgomery, 

Acting Deputy State Director for Natural 

Resources. 

[FR Doc. 2010–7999 Filed 4–7–10; 8:45 am] 

BILLING CODE 4310–40–P 
 

APPENDIX B 

LIST OF ATTENDEES 










































































































APPENDIX C 

MEETING MATERIALS 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

BUREAU OF LAND MANAGEMENT
 

Draft Clear Creek Management Area
 

Resource Management Plan & Environmental Impact Statement
 

Public Meeting
 

5:30-8:30 p.m. 

AGENDA 

Open House: 5:30-6:30 p.m. 

•	 Please Sign-In 

•	 Speaker Registration located at NEPA Station 

•	 Citizen’s Guide to NEPA located at NEPA Station 

•	 Public Comments Forms available at all Stations 

•	 Q&A with BLM, and EPA specialists, NEPA Facilitators 

Formal Presentations: 6:30-7:00 p.m. 

•	 RMP/EIS Overview & Schedule – Rick Cooper, BLM Hollister Field Office 

•	 Public Involvement & Ground Rules for Speakers – Kelly Bayer - Facilitator, Tetra Tech 

Inc. 

Public Comment Session: 7:00 – 8:30 p.m. 

•	 Allow 3 minutes for each (registered) public speaker to provide comments. 

Closing Remarks / Next Steps 

Thanks for your participation! 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A Citizen’s Guide to the NEPA, Having your Voice Heard. 

The following information was adapted from the document (identified above), prepared by the
 

Council of Environmental Quality, from the Executive Office of the President.
 

For a full version of this document please consult the following Web site:
 

http://ceq.hss.doe.gov/nepa/Citizens_Guide_Dec07.pdf 

PURPOSE OF THE GUIDE 

This guide has been developed to help citizens and organizations who are concerned about the 

environmental effects of federal decision-making to effectively participate in Federal agencies’ 

environmental reviews under the National Environmental Policy Act (NEPA). 

PURPOSE OF THE NEPA 

NEPA requires Federal agencies [i.e. BLM] to prepare Resource Management Plans (RMP) and 

Environmental Impact Statements (EIS) that describe environmental effects of management 

alternatives that include, among others, impacts on social, cultural, and economic resources, as 

well as natural resources and public health and safety. 

The environmental review process under NEPA provides an opportunity for you to be involved 

in the Federal agency decision-making process. It will help you understand what the Federal 

agency is proposing; and to offer your thoughts on alternative ways to accomplish what the 

agency is proposing, or comments on the analysis of the environmental effects of the proposed 

action [i.e. Preferred Alternative] and possible mitigation of potential harmful effects of such 

actions. 

HOW TO COMMENT 

Public comments should be clear, concise, and relevant to the analysis of the proposed action. 

� Take the time to organize thoughts and explain your views as clearly as possible. 

� As a general rule, the tone of the comments should be polite and respectful. 

� Solution oriented comments are more effective than those that simply oppose the 

preferred alternative. 

� Describe any assumptions that you used. 

� Provide technical information and/or data to support your views. 

� Provide specific examples to illustrate your concerns. 

� Offer reasonable alternatives or solutions. 

� Make sure to edit written comments and submit them by the comment period deadline. 

In drafting comments, try to focus on the purpose and need of the proposed action, the range of 

alternatives, the assessment of the environmental impacts of those alternatives, and the 

proposed mitigation. It also helps to be aware of what other types of issues the decision-maker 

is considering in relationship to the proposed action. 

Please note that commenting is not a form of “voting” on an alternative. Numerous comments 

that repeat the same basic message of support or opposition will typically be responded to 

collectively. 

 

 

ATTACHMENT 2 – CCMA Draft RMP/EIS Socioeconomic 

Workshop Report 
 

 

 

SOCIOECONOMIC WORKSHOP REPORT 

CLEAR CREEK MANAGEMENT AREA
 

RESOURCE MANAGEMENT PLAN AND ENVIRONMENT IMPACT
 

STATEMENT
 

JUNE 2010 

PREPARED BY:
 

TETRA TECH, INC.
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TABLE OF CONTENTS 

Section	 Page 

1.	 INTRODUCTION..................................................................................................................1
 

1.1	 Workshop Purpose ..............................................................................................1
 

1.2	 Workshop Location ..............................................................................................1
 

2.	 WORKSHOP SUMMARY......................................................................................................1
 

2.1	 Participants..........................................................................................................1
 

2.2	 Workshop Format ................................................................................................3
 

2.3	 Summary of Group Input......................................................................................4
 

2.4	 Summary of Workshop Group Written Comments..............................................10
 

3.	 REGIONAL ECONOMIC DATA............................................................................................13
 

3.1	 Background........................................................................................................13
 

3.1.1	 Introduction: Socioeconomic Concepts and Data Sources......................14
 

3.1.2	 Demographic Characteristics..................................................................14
 

3.1.3	 Housing Characteristics..........................................................................15
 

3.1.4	 Economic Characteristics: Employment and Income ..............................15
 

3.1.5	 Environmental Justice Characteristics ....................................................16
 

3.1.6	 Social Characteristics .............................................................................17
 

3.1.7	 Contribution from Public Lands...............................................................18
 

3.1.8	 Range of Alternatives .............................................................................19
 

3.1.9	 Range of Impacts ...................................................................................19
 

3.2	 Compensation and Employment by Industry Sector...........................................21
 

3.2.1	 Regional Updates and Changes Since 2001 ..........................................21
 

3.2.2	 Detailed Compensation and Employment by Industry Sector for the
 

Sectors Represented at the Socioeconomic Workshop ..........................25
 

3.3	 Changes in Housing Values Surrounding the CCMA .........................................27
 

4.	 CONTRIBUTION OF THE CCMA TO THE LOCAL ECONOMY AND SOCIAL VALUES..................28
 

5.	 SOCIOECONOMIC IMPACTS AND ALTERNATIVES PREFERRED BY THE WORKSHOP GROUPS.29 

6.	 CONCLUSION ..................................................................................................................30
 

7.	 REFERENCES..................................................................................................................32
 

LIST OF TABLES 

Table	 Page 

Table 1 List of Organizations Affiliations and Individual Invitees to the Socioeconomic Workshop ............ 2
 

Table 2 List of the Attendees to the Socioeconomic Workshop................................................................. 2
 

Table 3 Population Trends near the CCMA Area.................................................................................... 14
 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report i 
 

 

 

 

APPENDICES
 

A Invitation Letter 

B Workshop Materials 

C Compensation, Employment, and Housing Tables 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report ii 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1. INTRODUCTION 

The Bureau of Land Management (BLM) Hollister Field Office, in cooperation with the 

Environmental Protection Agency (EPA), prepared a Draft Resource Management 

Plan/Environmental Impact Statement (RMP/EIS) to provide direction for managing 

public lands in the Clear Creek Management Area (CCMA). 

The BLM is required by section 202 of the Federal Land Policy and Management Act 

(FLPMA) to integrate “physical, biological, economic, and other sciences” into its land use 

planning (43 USC, 1712). Section 102 of the National Environmental Policy Act (NEPA) 

requires federal agencies to “insure the integrated use of the natural and social sciences...in 

planning and decision making” (42 USC, 4332). 

1.1 WORKSHOP PURPOSE 

RMPs must accurately describe social and economic conditions in the planning area as a 

foundation for identifying patterns of change, including the changing role of public lands. 

Therefore, the quality of this information and how well it is understood by the public are 

critical to the BLM’s success in meeting its multiple­use mandate. Involving community 

members and decision makers in the socioeconomic aspects of the planning process is a 

means of increasing public support for BLM efforts and creating plans that reflect local 

conditions and perspectives. 

The socioeconomic components of BLM planning documents can play an important role in 

ensuring that plans not only achieve management goals but that they maximize the benefits 

for affected communities. The socioeconomic workshop was designed to accomplish the 

following: 

• Create a common base of understanding in the planning process; 

• Understand local demographic and economic trends; 

• Understand the role of natural resources in the local economy; 

• Assist in fulfilling the NEPA and FLPMA requirements; and 

• Assist in gathering and analyzing socioeconomic data. 

1.2 WORKSHOP LOCATION 

On February 22, 2010, the BLM Hollister Field Office held a social and economic workshop 

for the CCMA draft RMP/EIS in San Juan Oaks Golf Resort, Hollister. The workshop was 

centrally located in the area with the highest potential for socioeconomic impacts from the 

public land use decisions and alternatives described in the CCMA Draft RMP/EIS. The 

workshop was held in the afternoon from 1:00 PM to 5:00 PM. 

2. WORKSHOP SUMMARY 

2.1 PARTICIPANTS 

On February 3, 2010, the BLM Hollister Field Office sent an invitation letter to 

representatives from the local community, organizations, and local and state agencies. The 

list of invitees included representatives from the Resource Advisory Council, San Benito 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 1 
 

 

 

 

 

 

 

 

 

 

                 

     

 

 

      

 

         

   

 

 

 

 

 

   

 

 

 

 

 

 

 

 

   

 

 

 

 

 

 

 

 

 

 

 

 

   

 

 

 

 

 

 

 

 

 

     

 

 

 

           

 

 

 

 

 

 

 

 

 

 

 

 

 

County, California State Off­Highway Motor Vehicle Recreation Division, the OHV 

Commission, local business owners, private landowners, OHV club representatives, 

mineralogical societies and rock hounding groups, and tribes. Invitees and participants are 

listed in Table 1 and Table 2, respectively. The invitees were asked to be part of a panel that 

discusses and provides input for the socioeconomic issues outlined in the invitation letter 

(See Appendix A). 

The BLM also sent a general notification to the people on the CCMA RMP/EIS mail list. In 

addition, the BLM published a news release in the media, inviting the public to attend the 

socioeconomic workshop and to contribute to the output that would be provided by the 

panel. 

Table 1

List of Organizations Affiliations and Individual Invitees to the Socioeconomic Workshop

Resource Advisory Council

Ed Tobin, Salinas Ramblers Motorcycle Club (sitting 

in for Steve Koretoff) 

San Benito County

Rich Inman, Associate County Administration Officer 

California State Off­Highway Motor Vehicle

Recreation Division

Daphne Green, Deputy Director
­

Phil Jenkins
­

Jeff Gaffney, Hollister Hills State Vehicular
­

Recreation Area
­

OHV Commission

Gary Williard, Commissioner 

OHV Businesses

Fred Gotelli, Hollister Honda
­

John Ortiz, Faultline Powersports
­

Steve Polks, Pinit Motorsports
­

Chris Carter, Motion Pro
­

Eddy Bensen, Fremont Honda­Kawasaki
­

Dan Dunning, Zoom Cycle
­

John Clayton
­

Jeff Geiskophf, Cycle Gear
­

Other Business

Wayne Pfeffer, Tres Pinos County Store 

Don Castro, Racer’s Edge 

Phil Barrett, Flapjacks 

Unlimited Representative of Accessory Parts 

Private Landowners

Mark Henze, Hernandez Valley Landowners 

Association 

Dave Schreiner, State Gem Mine 

Nancy Birdwell, Birdwell Ranch 

Linda Anderson 

Rocky Hill, Landowner/Grazing Operator 

Lee Scazighini, Landowner/Grazing Operator 

Sharon Teague, Landowner/Grazing Operator 

Ray Iddings, Landowner/Mining Claimant 

OHV Club Representatives

Don Amador, Blue Ribbon Coalition 

Amy Granat, CORVA, CAL4WD 

Nick Haris, American Motorcycle Association (AMA) 

Dave Pickett, AMA Dist. 36 

Matt Beck, President, Salinas Ramblers Motorcycle 

Club (also landowners)
­

Martin Markham, President of Timekeepers
­

Jim Strenfel, Timekeepers LAO
­

Bruce Brazil, CERA LAO
­

Mineralogical Societies/Rock hounding Groups

Bill Spence, Bay Area Mineralogical Society, President 

Marshall Havner, Coalinga Rock Club 

Tribes

Rick Larios, Native American 

Table 2
 

List of the Attendees to the Socioeconomic Workshop
 

AMA District 36 Hollister Motorsports 

American Land Access Association Honda­Kawasaki of Modesto 

Bay Area Gem and Mineral Society KTM 

Bay Area Mineralogists Mobworthy Motorsports 

BMW­Yamaha Santa Cruz County Motion Pro 

California Association of Four­Wheel Drive Clubs (Cal4) Off Road Business Association 

California Federation of Mineralogical Society Ohlone 

California State Gem Mine Pinit Motorsports 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 2 
 

           

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2
 

List of the Attendees to the Socioeconomic Workshop
 

CERA 

CORVA 

Cycle Gear 

D/4 Cycles 

Economic Development Corporation of San Benito 

County 

Engines Only 

Faultline 

Flap Jacks 

Fox Racing 

Friends of Clear Creek Area Organization 

Hernandez Ranches 

Hernandez Valley Landowners 

Hollister Honda 

Racers Edge 

Salinas Ramblers Motorcycle Club 

San Benito County 

San Benito County Chamber of Commerce 

San Francisco Gems and Mineral Society 

SCR4 

Supervisor – San Benito County 

Taco Bell 

Three Rocks Research 

Timekeepers Motorcycle Club 

Tres Pinos Store 

Tucker Rocky 

Zoom Cycle Accessories 

2.2	 WORKSHOP FORMAT 

Participants were asked to sign in and were handed the workshop materials (See Appendix 

B). The workshop session started at 1:30, with a presentation outlining the socioeconomic 

analysis process and summarizing the environmental settings provided in the draft 

RMP/EIS. Section 3.1 of this report presents the social and economic conditions and other 

background information that was summarized during the presentation and included in the 

Draft RMP/EIS. Following the presentation, attendants gathered by interest groups to 

discuss their perspectives on the six discussion topics provided during the workshop and 

included in the invitation letter. Attendants were organized into six small groups: OHV 

business, OHV recreation (including clubs and organizations), other business services 

(including retail establishments, such as restaurants, lodging, and gas stations), mineral and 

rock collectors, landowners, and others. 

Each group conferred about the following six discussion topics identified in the invitation 

letter and also provided in the workshop material: 

•	 Have businesses seen a drop in activity/revenue since the CCMA closure? 

•	 Have any businesses closed since the closure of the CCMA? 

•	 Has there been a rebound in economic activity since the initial closure? 

•	 How could CCMA draft RMP alternatives affect you economically? 

•	 How could CCMA draft RMP alternatives affect your lifestyle? 

•	 Does the information in the CCMA draft RMP/EIS reflect current social and 

economic conditions and the potential impacts associated with the range of 

alternatives? 

The groups prepared responses to each discussion topic, and a speaker was designated for 

each group. Attendants reconvened to present their input on each of the six discussion 

topics to other groups and workshop attendees. Each of the group speakers and panel 

members had about three minutes to summarize their input for each of the discussion 

topics. At the end of the workshop, attendants were provided with additional time to ask 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 3 
 

 

 

 

 

 

        

 

 

 

 

        

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                    

 

 

 

questions or comment on the social and economic conditions within the planning area and 

the effects of BLM land use decisions. 

2.3 SUMMARY OF GROUP INPUT 

Attendee Input on the First Discussion Topic: Have businesses seen a drop 

in activity/revenue since the CCMA closure? 

Input from OHV Business Group: The speaker from this group said that businesses related to 

OHV have seen a decrease in their revenues, of up to 33 percent. The group also noted the 

decrease in BLM funds for OHV use. The BLM OHV fund was $1.5 million last year, but it 

has decreased by 40 percent. Written comments from individual OHV business owners said 

that their sales revenues decreased by between 10 and 50 percent. 

Input from OHV Recreation Group: This group included members of OHV businesses that also 

participated in OHV recreation organizations, as well as OHV business owners that did not 

belong to a particular organization. The speaker said that the CCMA closure had an impact 

on all the OHV businesses. The speaker noted that small businesses, like Zoom Cycle 

Accessories, had a 30 to 40 percent reduction in revenue. Engines Only had a reduction of 

30 percent, and Hollister Honda saw a 20 percent reduction in business. The drop in new 

OHV vehicles sales ranged between 30 and 40 percent. Employment at DH Cycles, Inc., 

decreased from 28 employees to six. The speaker also noted that dealers have stopped 

getting new vehicles. 

Those submitting written comments from businesses like Zoom Cycle Accessories noted 

that their businesses have had a “dramatic” drop in sales since May 2008 with the closure of 

the CCMA. The reduction in sales was between 30 and 40 percent, for a total of $35,000 per 

month, the equivalent of a $420,000 reduction between May 2008 and May 2009. The 

representative of Zoom Cycles also said that 85 percent of the stores’ accessories sales was 

for off­road vehicles. 

Since the closure of the CCMA, OHV riders have been travelling to Hollister Hills, which 

fills to capacity on most weekends. This is causing riders to 1) return home, 2) wait for 

others to leave, or 3) give up the OHV riding sport. Commenters from Zoom Cycle 

Accessories and Pinit Motorsports also said that numerous riders who used to stop by the 

store before going to the CCMA are not coming anymore. The reduction in visits to the area 

has had economic impacts on the local gas stations, restaurants, supply stores, and lodging in 

San Benito and Santa Clara Counties. The commenter noted that the reduction in sales is 

also impacting the sales taxes for these counties. Additionally, fewer customers are 

purchasing new or used OHV vehicles, resulting in the loss of federal and state taxes. 

Input from Business Services, Including Retail, Restaurants, Gas Stations, and Lodging: The speaker 

noted that small businesses within the planning area employ approximately 500 persons. The 

group calculated the loss caused by the absence of OHV events at the CCMA at $135,000 

per year. The speaker from this group noted that in addition to the loss in income, there is 

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an impact on the quality of life caused by the loss of the desired OHV experience and the 

peace of mind when riding in the CCMA. 

Input from Mineral and Rock Collectors Group: The speaker from this group estimated the loss in 

contribution to the local economy per car visiting the CCMA at $125. The speaker noted 

that impacts on mineral properties within the CCMA as a result of the closure are related to 

property resale, income, and property transfer between family members. The speaker noted 

that loss in claims resulting from the closure ranges between tens of thousands to hundreds 

of thousands of dollars. The mine reserve within the CCMA is estimated in several million 

dollars. The speaker noted that the CCMA is the last rock hounding area west of the Sierra 

Nevada that was still open. To get to another place within the region, rock collectors would 

have to drive for a long distance. 

Attendees Input on the Second Discussion Topic: Have any businesses 

closed since the closure of the CCMA? 

Input from OHV Business Group: The group noted that the OHV business is facing extinction. 

No businesses have closed yet, as a result of the BLM’s temporary closure within the 

CCMA, although there is a strong possibility of a loss of OHV businesses near the CCMA 

area if the closure were to become permanent. The group speaker said that the closure 

impacts are expanding to the district level. 

Input from OHV Recreation Group: The group speaker said that two OHV dealers have closed, 

and 15 percent of the accessory business stores have gone out of business.1 

Input from Mineral and Rock Collectors Group: The group speaker said that the reduction in fourwheel­drive maintenance stores is affecting the members of this group who own four­wheel 

drive vehicles. 

Input from Landowners Group: The speaker noted that the CCMA closure has destroyed the 

volunteer base of the historic preservation project and the ability of the members to 

continue with the program that he was running. 

Input from Business Services, Including Retail, Restaurants, Gas Stations, and Lodging: The group 

speaker said that the whole small business community is impacted because of the overall 

economic recession and the closure of the CCMA. The speaker said that the group is aware 

of 12 businesses that have closed since the CCMA closed. 

1 The BLM notes the inconsistencies between this group’s perception of the situation and that of the OHV Business 

Group. This inconsistency could be the result of differing knowledge of the level of business closures, the overall area 

being considered by each group, and different participants in each group. 

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Attendees Input on the Third Discussion Topic: Has there been a rebound 

in economic activity since the initial closure? 

Input from OHV Business Group: The group speaker said that if there had been a rebound, it 

would have happened in areas such as Mendocino and Eldorado. 

Jeff Gaffney, Deputy Director of Hollister Hills State Vehicular Recreation Area (SVRA), 

noted that in 2009 managers of the SVRA had to close the park 19 times. Riders who 

typically go to the CCMA are going off­trail in the SVRA. The riding style and experience in 

the SVRA is completely different from that of the CCMA. The speaker added that the 

SVRA cannot be a replacement for the CCMA. 

Input from OHV Recreation Group: The group speaker agreed with the comment provided by 

the SVRA director, and he added that regular SVRA riders cannot ride in the CCMA 

because the terrain is different and more challenging. 

As an answer to the third discussion topic, the group speaker said that there has been no 

rebound in economic activity. 

At this point, Rick Cooper, manager of the BLM Hollister Field Office, asked the panel if 

the presented numbers in the decrease in revenue and sales account for the impacts caused 

by the overall economic downturn. One member of the panel answered that the sales in 

California have not decreased and customers coming to the local stores within the CCMA 

area are telling the owners that it is the last time they will stop by their store because of the 

CCMA closure. The owner of Yamaha Santa Cruz said that he had a $0.5 million loss in 

sales, and 20 percent of this loss is due to the CCMA closure. 

One person from the audience said that she owns 11 motorcycles and some of these 

motorcycles are suitable only for rides in the CCMA. She uses different types of motorcycles 

to ride in the SVRA. The same person said that the BLM did not notify all the types of 

businesses that could be affected by the closure. She added that many people have stopped 

riding as a result of the closure. 

Input from Business Services, Including Retail, Restaurants, Gas Stations, and Lodging: The group 

speaker said that there has been no rebound in the economy. No clients are coming to the 

area. He said that small businesses have had to adjust, depending on the situation. 

Attendees Input on the Fourth Discussion Topic: How could CCMA draft 

RMP alternatives affect you economically? 

Input from OHV Recreation Group: The group speaker said that Alternative A is the only viable 

alternative. Any other alternative would reduce OHV recreation. This would affect current 

riders, future riders, and succeeding generations of riders. The speaker added that reducing 

OHV recreation is definitely resulting in a loss of jobs. He gave examples of reduction in 

employees for several OHV businesses surrounding the CCMA area. 

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Input from Landowners Group: One member of the group said that the Tucker Zone within the 

CCMA area is a valuable national wildlife resource primarily suitable for hiking and hunting. 

He said that Alternative A is acceptable, but he felt that OHV riding is not appropriate in the 

Tucker Zone as it would disturb wildlife. Use, or even “jeep trail” use, would disturb the 

bald eagles, condors, elk, and other wildlife, and their habitat would be destroyed. The 

member noted his concern with the decrease in property value and asked for access to the 

Tucker Zone and its designation as a wildlife area. 

Another member of the landowners suggested that property values within the CCMA have 

dropped by 80 percent as a result of the closure. 

Input from OHV Business Group: The speaker said that only Alternative A has his group’s 

support. 

Input from Business Services, Including Retail, Restaurants, Gas Stations, and Lodging: The speaker 

said that his group supports only Alternative A. The speaker suggested seasonal opening of 

the CCMA to OHV riders. The speaker noted the bikers’ respect for the land and their will 

to enjoy it and keep it protected. 

Input from Mineral and Rock Collectors Group: The group speaker said that his group can work 

with a modified Alternative E. He said that members of his group are mostly more than 45 

years old, so they often need access to the area from the Clear Creek Canyon entrance off 

Coalinga Road because of physical limitations. The speaker also asked to provide access for 

people who own claims within the CCMA. 

Attendees Input on the Fifth Discussion Topic: How could CCMA draft RMP 

alternatives affect your lifestyle? 

Input from OHV Business Group: The speaker noted the large impact the closure has on 

eliminating the OHV clubs’ events at the CCMA. He said that an individual event would 

have an attendance of approximately 700, and about 1,500 people would attend a week’s 

event. The other closest OHV riding area is a drive of six to seven hours. This change is 

impacting people’s lifestyles. The speaker said that the lifestyle change also will result in 

future major economic impacts within the area that cannot be quantified. 

Input from Business Services, Including Retail, Restaurants, Gas Stations, and Lodging: The speaker 

noted that in order to gain momentum, they still need to have the CCMA available. He said 

that the CCMA provides the opportunity for visitors to feel good and feel that what they 

have invested in is coming back to them. 

Input from OHV Recreation Group: The speaker said that dealers are also riders. He noted that 

very few other parks exist, and those that do exist are too small. The loss of the CCMA is 

tremendous, and riders cannot enjoy the same type of lifestyle in other parks. He noted that 

motorcyclists have had a substantial investment in OHV equipment that they cannot use in 

places other than the CCMA. 

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Input from Mineral and Rock Collectors Group: The speaker said that his group is in a state of 

“hibernation” as a result of the closure. He reiterated the uniqueness of the CCMA west of 

the Sierra Nevada. 

Input from Landowners Group: One member from the landowners group said that the CCMA is 

the only place left that he could access for recreation. He said that he is not concerned with 

the health risk. 

Attendees Input on the Sixth Discussion Topic: Does the information in the 

CCMA draft RMP/EIS reflect current social and economic conditions and 

the potential impacts associated with the range of alternatives? 

Input from Landowners Group: The speaker said that the CCMA draft RMP/EIS did not 

quantify impacts on the local area of reduced riding. He noted that the community did not 

realize the impact at the time the document was prepared. 

Input from OHV Recreation Group: The speaker said that the demographic data in the draft 

RMP/EIS is outdated. He also noted that the document does not mention the increase of 

OHV riders on the SVRA. He felt that the document’s preparers did not do any outreach to 

the people who used to obtain passes to ride in the CCMA. 

The speaker asked the SVRA director how many single­track miles are in the SVRA (there 

are 30 miles). 

Input from Business Services, Including Retail, Restaurants, Gas Stations, and Lodging: The speaker 

said that the CCMA has been closed for almost two years. He noted that information in the 

draft RMP/EIS is redundant and asked for a questionnaire to be sent to the area’s 

permittees to get their feedback on the closure impacts. 

Input from Landowners Group: The speaker said that other communities are left out and are not 

represented in the workshop. Those communities also are missing from the draft RMP/EIS. 

Input from Mineral and Rock Collectors Group: The speaker said that none of the alternatives 

presented in the draft RMP/EIS note how and why people collect minerals and rocks. 

General Comments from the Audience 

One audience member said that she visited all the retail stores in Hollister to notify them 

about the workshop. She said that those stores were not invited. 

One member from the panel said that 80 percent of the visitors to the CCMA are from the 

OHV community. He said that he ran a quick poll and concluded that visitors’ spending is 

distributed in the following way: 19 percent for restaurants, 80 percent for gas, and 60 

percent for food in general. The panel member said that visitors spend to a lesser degree on 

hotels and bike accessories. 

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One member from the audience asked how grazing access to the CCMA could be less 

dangerous (with respect to asbestos exposure) than access for other activities. BLM 

personnel explained that areas allowed for grazing are outside the area of critical 

environmental concern (ACEC). 

One member from the panel said that two supervisors from San Benito County asked for an 

extension of the review period based on the socioeconomic issues discussed during the 

workshop. The same member said that the percent of sales tax generated in San Benito 

County by OHV recreation is $10,000 per month. He noted that this amount would be 

reduced if the CCMA remained closed. He also estimated that the amount of gasoline taxes 

that goes into grants is several million dollars. The member felt this would justify the 

preparation of a supplemental EIS. 

One member of the audience asked how long the closure would continue. BLM personnel 

replied that the final RMP/EIS is planned for 2010 and that the Record of Decision is for 

January 2011. 

One member of the panel asked if there is a benefit to the BLM by taking down staging 

areas. He said that the draft RMP/EIS was released for public review concurrently with two 

other documents. He noted the importance of an extension of the public review period and 

asked the BLM to grant this extension. Another member of the panel reiterated the need for 

an extension of the review period. 

A panel member noted the importance of an outreach to local business. 

One member of the panel requested that the BLM ensure the document is available to the 

public on time. 

An audience member emphasized the importance of CCMA to mineral and rock collectors. 

He noted that he cannot carry the necessary equipment to access the mining land. He also 

said that if the access provided by Road 14 were eliminated, the ability of mineral and rock 

collectors to access the area would be severely restricted, due to the steepness of the terrain. 

He asked BLM personnel if they were under pressure to accept the EPA health risk report. 

The answer was “no.” 

One supervisor from San Benito County said that she is personally in favor of opening the 

CCMA. She said that she will convey the issues discussed during the workshop to the other 

members of the Board of Supervisors. The supervisor said that the CCMA is a proven 

economic engine. 

One member of the panel asked if the federal emergency closure program was used to close 

the CCMA. The manager of the BLM Hollister Field Office replied that the CCMA was 

closed under the authority of 43 CFR, 8364.1, to “persons, property, and public lands and 

resources.” 

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2.4	 SUMMARY OF WORKSHOP GROUP WRITTEN COMMENTS 

Some workshop participants had prepared written materials for the socioeconomic 

workshop, and during the group discussions, participants wrote notes of their views on 

discussion topics. These written materials were submitted at the conclusion of the workshop, 

and additional written comments and supporting documentation were submitted later. The 

following is a summary of these written submissions. 

Socioeconomic Assessment in the RMP/EIS and Workshop Participation: One commenter noted that 

the socioeconomic discussion about the CCMA RMP/EIS must include all the affected 

parties. The commenter added that impacts on innkeepers and food establishments have not 

been addressed in the draft RMP/EIS. There are at least eight communities, 49 lodging 

establishments, and 75 eating establishments affected by the closure. 

One commenter said that public representation in the socioeconomic workshop was not 

adequate. The commenter asked for an appropriate notification with the needed 

documentation and a reasonable preparation time. 

RMP/EIS Alternatives: One commenter noted that Alternative E would result in the highest 

impact on OHV riders. However it would also affect mineral and rock collectors, hunters, 

nature enthusiasts, mountain bikers, and other recreationists. 

One commenter proposed setting up a CCMA Advisory Council Committee. The 

commenter noted that this approach is working in other California BLM districts. An 

advisory committee would provide the public, elected officials, professional consultants, and 

scientists with opportunities to work with the BLM on using, sharing, and appreciating the 

CCMA, while complying with NEPA. 

Impacts on Mineral and Rock Collectors: In response to a statement in the draft RMP/EIS under 

Alternatives D, E, and F that the closure would not result in adverse effects on mineral and 

rock collectors, one commenter said that these three alternatives eliminate access for most 

mineral and rock collectors to access their traditional collecting sites. They have to hike five 

to 15 miles to access these sites. Of the more than 49,000 members of the American 

Federation of Mineralogical Societies, more than half of them are age 55 and older and 

would have difficulty hiking this far. The comment adds that senior mineral and rock 

collectors depend on Clear Creek Road and other connecting spur roads to access the 

collecting sites. 

Asbestos at the CCMA: One commenter said that the BLM and EPA analysis does not 

distinguish between the different types of asbestos fibers. The commenter added that the 

BLM and EPA have ignored authoritative articles in medical journals with regard to 

nonoccupational chrysotile asbestos exposure, knowing that chrysotile is the predominant 

variety of asbestos in the ACEC. The articles in the medical journals claim that there is no 

evidence to conclude that chrysotile asbestos is a carcinogen in a nonoccupational setting. 

The commenter asked why was there no effort made to pinpoint the origins of the 

amphibole variety (a known carcinogen) that was collected in the air samples. 

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The commenter presented his concern regarding the EPA’s risk analysis program (Integrated 

Risk Information System [IRIS]) used to assess the risks of asbestos exposure. The 

commenter noted that the IRIS program is “being overhauled in light of medical findings, 

uncertainties, and flaws within their models,” as indicated on the EPA Web site. The 

commenter included letters and medical articles in his written submission. He added that the 

Carcinogen Risk Assessment Verification Endeavor (CRAVE) Work Group had been 

reviewing the model since 1986, according to an EPA official, and that they never released 

their findings. The commenter explained that the CRAVE Work Group disbanded, and he 

felt that the EPA could be withholding that group’s findings. 

The commenter stated that the EPA admits that “the risk” may be overestimated. Given 

this, the commenter asked how the public could have confidence it the EPA’s assessment 

methods or its estimation of risk at the CCMA. 

The commenter requested in his letter that the RMP consider and accommodate all 

concerns, where possible. He said that some form of regulation of OHV activity in the 

ACEC seems prudent and suggested limiting OHV activities to designated areas other than 

on the two main roads (Clear Creek and Spanish Lakes 18) and requiring permits and risk 

waivers. The commenter also suggested limiting access to riders above the age of 18. 

The commenter asked for an investigation into the source of the amphibole asbestos road 

contamination, with a suitable remediation plan, if needed. 

One commenter noted that the approach to reduce health risks by limiting the access to the 

CCMA would increase the safety risks in other surrounding parks. The closure of the CCMA 

is causing overuse of other local OHV parks, such as Hollister Hills and Carnegie SVRAs, 

the Metcalf Motorcycle County Park in Santa Clara County, and other OHV areas on US 

Forest Service and BLM public lands, such as Stonyford and Cow Mountain. 

One commenter noted that there are no known cases of illness related to the asbestos in the 

CCMA. The commenter added that members from the Mountaineers Motorcycle Club cut 

trails in the early 1960s in the CCMA and those riders are now in their 70s or 80s without 

any sickness symptoms related to asbestos, and they are still alive and able to ride. The 

commenter asked how long the emergency closure period would be extended and noted that 

it has been closed for two years. 

Impacts on Wildlife: A group of landowners submitted a proposal aimed at regulating public 

access and preserving wildlife in the Tucker Zone. The group proposed that the BLM adopt 

it as its preferred alternative for the Tucker Zone under the RMP/EIS as a Wildlife 

Conservation and Wilderness Study Area alternative that promotes the conservation and 

study of wildlife (including bald eagles, condors, and elk) and wildlife habitat in the Tucker 

Zone. The proposal noted that preservation of the Tucker Zone as wildlife habitat would 

help mitigate the loss of habitat elsewhere in the CCMA. 

The proposal involves a cooperative effort between the group of landowners, the BLM, the 

California Department of Fish and Game (CDFG), and the Ventana Wildlife Society (VWS) 

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conservation organization. The proposal also involves granting nonexclusive easements by 

the landowners to the BLM land in the Tucker Zone for the following limited purposes: 

•	 Allowing BLM and CDFG employees, contractors, and agents access to the Tucker 

Zone for range/land management and law enforcement; 

•	 Allowing a limited number of La Panza elk tag holders access for elk hunting on 

BLM land; and 

•	 Limiting public access to organized, educational, and photographic hiking trips in 

the Tucker Zone. 

The proposal is conditioned on the following: 

•	 The BLM not selling or exchanging any BLM land in the Tucker Zone; 

•	 The BLM not authorizing or constructing any new on­ or off­road vehicle roads or 

trails into or within the Tucker Zone; 

•	 The BLM granting nonexclusive rights­of­way to the landowners, covering 

approximately 300 yards of a dirt road on BLM land near Cane Canyon, to provide 

emergency access when the flow of water in the San Benito River prevents the 

landowners from safely crossing it; and 

•	 The parties involved entering into a written agreement concerning the items above. 

Commenters noted that Cane Canyon, in the Tucker Zone, is eligible for inclusion in the 

Wild and Scenic River Inventory, and the BLM would have to place this area under 

protective management, as identified in the draft RMP/EIS. 

Impacts on Landowners: Several commenters noted that if the BLM sells or exchanges the 

Tucker Zone property, members of the public would no longer be able to use this land for 

hunting, hiking, and camping. Further, there is no assurance that the buyer would adequately 

protect these invaluable wildlife resources. Also, if the BLM were to allow increased 

recreation (OHV and other motorized and nonmotorized uses) to expand into the Tucker 

Zone, neighboring landowners would be affected by more noise, dust, trespassers and 

conflicts. 

Socioeconomic Impacts: Commenters felt that property values in Hernandez Valley would be 

drastically impacted if the BLM were to dispose of the Tucker Zone property. They noted 

that people buy land in Hernandez Valley to hike, view wildlife, hunt, and explore the 

wilderness. If prospective buyers cannot enjoy these activities in the Tucker Zone, many of 

them would not consider purchasing land. 

One commenter observed that his two motorcycle shops have been impacted by the global 

economy, and the closure of the CCMA has added to this problem. He added that he used 

to have 28 employees but now employs only six workers. He no longer sells new bikes in his 

shops, and his gross sales value went down from $6.0 million to less than $2.0 million. 

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The CCMA closure has resulted in a loss of revenue in one commenter’s store of $6,000 per 

month as a result of the reduction in OHV riders alone, without counting hunters and 

bikers. The commenter noted that his store offers the last full service to motorists traveling 

south on Highway 25. Before the closure of the CCMA, about 30 trucks would stop by his 

store. The average sale would be $50 dollar per truck, equivalent to $1,500 per weekend. 

Demographic Analysis: One commenter asked why the draft RMP/EIS considered only five 

counties in the population analysis and omitted Santa Clara, Alameda, San Mateo, Stanislaus, 

Kern, Madera, San Joaquin, King, Tulare, and San Luis Obispo Counties. The commenter 

also added that if 60 to 65 percent of all riders are from Santa Clara County, the BLM should 

have collected information from Santa Clara County riders and business owners. 

3. REGIONAL ECONOMIC DATA 

This section provides background information for the CCMA and a summary of the social 

and economic conditions described in the Draft RMP/EIS. It also contains an analysis of 

impacts that were included in the workshop presentation to describe the effects of CCMA 

land use decisions for the socioeconomic workshop and supplemental information about the 

industry sectors that provide jobs and income in the RMP analysis area. Data for Santa Clara 

County is included separately since it is part of the larger San Francisco Bay Area; however, 

several Santa Clara County business representatives at the workshop said that they would be 

affected by changes in the BLM’s management of the CCMA. 

3.1 BACKGROUND 

The CCMA is in central California in the southern portion of San Benito County and the 

western portion of Fresno County. It encompasses approximately 75,000 acres, 63,000 of 

which are public land managed by the Hollister Field Office and 12,000 acres of which are 

state and private lands. 

The Serpentine ACEC covers approximately 30,000 acres within the CCMA boundary. It 

was designated an ACEC with the approval of the 1984 Hollister RMP, which addressed the 

BLM’s land use decisions for CCMA public lands. The designation was based on the human 

health risk associated with the naturally occurring asbestos and the occurrence of special 

status plant species endemic to the area. The 450­acre Atlas Mine Superfund site is within 

the ACEC and is listed on the EPA’s National Priorities List (NPL) of hazardous waste sites 

potentially posing the greatest long­term threat to health and the environment. 

The updated Hollister RMP prepared in 2007 did not address land use decisions in the 

CCMA. This was because the EPA was preparing an asbestos exposure and human health 

risk assessment to provide the BLM and the general public with information on the 

exposure levels from various types of activities in the CCMA. The study was prepared in 

connection with the Atlas Asbestos Mine Superfund Site and technical deficiencies of a 1992 

health risk assessment that the BLM used to evaluate CCMA visitors’ exposure to airborne 

asbestos fibers in the area. The EPA released the CCMA Asbestos Exposure and Human 

Health Risk Assessment on May 1, 2008. The authors of the study concluded that visiting 

the CCMA more than once a year could put adults and children above the EPA’s acceptable 

risk range for exposure to carcinogens. They found an increased long­term cancer risk from 

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engaging in many of the typical recreation activities at the CCMA. In order to protect public 

land users from human health risks of exposure to airborne asbestos, the BLM Hollister 

Field Office published a notice in the Federal Register announcing the temporary closure of 

the CCMA to all forms of entry and public use. The notice stated that the order will be in 

effect while the BLM completes the RMP for the CCMA to determine if and how visitor use 

can occur without associated excess health risks. 

The CCMA RMP/EIS presents the baseline existing conditions of the natural and human 

environment, a range of management alternatives for the BLM and interested parties to 

address emerging issues in the region, and an evaluation of the environmental consequences 

of current management and the range of alternative management actions. The following is a 

summary of the information discussed in the RMP/EIS and presented at the socioeconomic 

workshop. 

3.1.1 Introduction: Socioeconomic Concepts and Data Sources 

Socioeconomic resources include population, housing, public services, income, employment, 

and lifestyle, family, and social values. These resources are analyzed to meet the requirements 

of NEPA, to identify the impacts of a federal action on the human environment. 

Socioeconomic analysis also is conducted to meet the planning criteria for the RMP that 

state economic and social baselines and consequences will be developed in coordination with 

local and county governments and help understand which actions would be preferred from 

the standpoint of the local population, so that the preferred multiple uses of the affected 

public can be most efficiently addressed. 

The sources of the socioeconomic data found in the RMP include statistics compiled by the 

federal and state government, studies on the role of recreation in California’s economy, 

county and state planning documents, and discussions with stakeholders. The information 

from these sources was used to develop the baseline conditions in the CCMA planning area. 

Changes to this baseline as a result of each of the project alternatives were evaluated at a 

regional and local level to help select the best management for the area. 

3.1.2 Demographic Characteristics 

As presented in Table 3, population trends in the 1990s near the CCMA area show a greater 

percentage of growth at the local level in Fresno and San Benito Counties than in California. 

This probably reflects a move to a more affordable residential and commercial property on 

the part of the families and businesses, as compared to that in the San Francisco Bay Area. 

Table 3

Population Trends near the CCMA Area

Location 1990 2000 2004 Total Percent Change 

1990­2000 2000­2004 

Fresno County 672,250 804,333 876,842 20.0 9.0 

Clovis 49,650 68,468, 81,256 37.9 18.7 

Coalinga 8,050 16,213 16,735 101.4 3.2 

Fresno 350,700 427,652 458,203 21.9 7.1 

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Table 3
 

Population Trends near the CCMA Area
 

Reedley 15,650, 20,756 21,849 32.6 5.3 

Sanger 14,650 18,931 20,612 13.7 8.9 

Selma 14,650 19,444 21,881 32.7 12.5 

San Benito 

County 

36,911 53,789 57,353 45.7 6.6 

Hollister 19,000 34,413 36,993 81.1 7.5 

California ― ― ― 14.3 7.3 

Source: BLM 2009 

While growth in San Benito County as a whole fell below the state average between 2000 

and 2004, growth in Hollister and Fresno County was, once again, above the state average. 

By 2030, the population of Fresno County is forecast to increase by about 62 percent and 

San Benito County by almost 58 percent, while the state’s population is forecast to grow by 

approximately 41 percent. 

3.1.3 Housing Characteristics 

In San Benito County, the housing affordability index was 76 in 2000, which suggests that 

the median family could not afford the median house. In Fresno County, the housing 

affordability index was 130 for 2000, which suggests that the median family could afford the 

median house. Given the changes in the economy in recent years, including a drop in interest 

rates and housing values, housing affordability status in both San Benito and Fresno County 

may have changed. 

3.1.4 Economic Characteristics: Employment and Income 

As shown in Figure 1, from 1990 to 2002, both employment and income in San Benito and 

Fresno Counties fell below the state averages. However employment growth in the 1980s, 

1990s, and 2000s was above the state average for San Benito County but dipped below the 

state average in Fresno County in the 1990s. 

Figure 1

Employment 

84.0 

86.0 

88.0 

90.0 

92.0 

94.0 

96.0 

1990 2000 2002 

Year 

Percent

Fresno County 

San Benito County 

California 

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In 2002, the government was the largest employer in California and in San Benito and 

Fresno Counties. In the same year, manufacturing and retail trade were among the top four 

private employers in California, Fresno County, and San Benito County. Accommodation 

and food services and construction were among the top four private employers in San 

Benito County. 

Average per capita incomes in San Benito and Fresno Counties fell below state average, and 

showed little growth in Fresno County. However, income growth in San Benito County 

mirrored the state average (Figure 2). By 2002, per capita income in San Benito County was 

$4,329 below the state average, while in Fresno County, per capita income was $9,497 below 

the state average. 

Figure 2

Income 

0 

5,000 

10,000 

15,000 

20,000 

25,000 

30,000 

35,000 

40,000 

1980 1990 2000 2002 

Year 

Per Capita Personal Income

Fresno County 

San Benito County 

California 

In 2002, about 30 percent of personal income was from non­labor sources (including 

interest, dividends, and transfer payments, such as Medicare). This indicates that most 

people derived their income from their work, rather than from retirement pay, interest, 

dividends, or other sources. 

As shown in Figure 2, income in San Benito and Fresno Counties fell below the state 

averages. Employment growth in the 1980s, 1990s, and 2000s was above the state average 

for San Benito County. In Fresno County, employment growth was below the state average 

in the 1990s. 

3.1.5 Environmental Justice Characteristics 

Each federal agency is responsible for identifying disproportionately high and adverse 

human health or environmental effects of its actions on minority and low­income 

populations. 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 16 
 

   

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 3
 

California Racial Composition 

59.5 

6.7 

1 

10.9 

0.3 

16.8 

4.7 

White 

Black or African 

American 

American Indian and 

Alaska Native 

Asian 

Native Hawaiian and 

Other Pacific Islander 

Some other race 

Two or more races 

San Benito County Racial Composition 

65.2 

1.1 

1.2 

2.4 

0.2 

24.9 

5.1 

Fresno County Racial Composition 

54.3 

5.3 

1.6 

8.1 

0.1 

25.9 

4.7 

As shown in Figure 3 above, San Benito and Fresno Counties share the same general ethnic 

pattern with California, with a very large Hispanic population and a majority of the white 

population. Fresno County has a higher percentage of Native Hawaiian and Other Pacific 

Islander (5.3 percent) and Asian (8.1 percent) than San Benito County, with 1.1 percent from 

the Native Hawaiian and Other Pacific Islander population and 0.2 percent from the Asian 

population. However, the percentage of the Native Hawaiian and Other Pacific Islander (6.7 

percent) and Asian (10.9 percent) populations is higher in California than in San Benito 

County (BLM 2009). 

The proportion of Fresno County’s population below the poverty line was higher than the 

state level, whereas the percentage of San Benito County’s population in poverty was lower 

than the state average (BLM 2009). 

3.1.6 Social Characteristics 

The CCMA is a part of the planning area’s social values as well as demographic and 

economic values. It provides a link between modern and traditional and rural lifestyles, adds 

to the value of preserved open space and natural habitat, provides exposure to nature and 

remoteness that are often missing in modern urban lives, facilitates bonding with family and 

friends, and provides a connection between Native Americans and their ancestral lands. For 

example, ranching and mineral collection have long cultural and family traditions. Residents 

in the area value living near open space for the ease of access to outdoor opportunities. 

Many areas within three hours drive of the CCMA are densely populated, and open space in 

these areas is heavily used. The CCMA provides separation from these areas and 

opportunities for families to spend time together and to understand each other better and 

for young adults to participate in constructive social activities. Several generations of families 

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and relatives from other parts of the state and other states also often participate in OHV 

recreation in the CCMA. 

3.1.7 Contribution from Public Lands 

Public lands in the CCMA contribute to all of the socioeconomic resources described above 

by providing lands for recreation, grazing, and mining and by contributing to public revenue. 

The socioeconomic effects of recreation provided by BLM lands in the CCMA include 

stimulating the local economy by drawing in tourism expenditures from hunters, hikers, 

OHV enthusiasts, and other recreational visitors into the local economy. Their expenditures 

on gasoline, food, lodging, supplies, and other goods and services generate income in these 

service sectors, which, in turn engenders increased expenditures by these industries 

throughout the economy. This multiplier effect within the local economy increases overall 

economic activity, employment, and income. In addition, subsistence income is derived from 

rock hounding in the CCMA. Areas within three hours drive of the CCMA with the largest 

number of employees in retail sales of motorcycles in 2001 included mainly the largest 

population centers, such as San Francisco, San Jose, and other Bay Area cities, as well as 

areas with large numbers of enthusiasts, such as Monterey Bay and western Fresno County. 

Engaging recreational activities on BLM lands also can foster a sense of community and of 

participating in a communal activity, bonding with friends and family, and solitude and 

closeness to nature. Recreational activities can have a negative effect on the value of 

preserving biodiversity and heritage, which needs to be considered, in addition to the other 

more beneficial effects. 

Grazing on public lands in the CCMA provides valuable forage and preserves the way of life 

in the West, family traditions, and open space. The three largest leaseholders authorized for 

grazing on public lands in the CCMA account for almost two­thirds of the acres leased by 

the HFO in the CCMA and for over 80 percent of the AUMs. Land values in the area 

surrounding the CCMA have risen in recent years beyond their potential to produce income 

from grazing. Private landowners with large ranches who live next to large tracts of public 

land charge hunters for access to their own private land and to adjacent BLM land. This 

often takes the form of membership fees in hunting clubs that provide lodging or camping 

sites and support facilities and services. In addition, healthy rangeland contributes to wildlife 

habitat and scenic resources. 

There is limited potential for the CCMA to contribute to the local economy from oil and 

gas, but casual mineral collection is a source of subsistence income and a valued form of 

recreation in the CCMA. 

Public lands in the CCMA provide revenue to state and local governments from grazing 

fees, oil and gas royalties, and recreation permit fees. Payment in lieu of taxes help 

compensate for federal ownership of land; economic activities resulting in sales and use tax 

contributions provide revenue to local governments. 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3.1.8 Range of Alternatives 

A range of alternatives was developed and described in detail in the RMP/EIS to respond to 

the potential health risk issues, while maintaining multiple uses on public lands within the 

CCMA. These alternatives are as follows: 

•	 Alternative A is the No Action alternative and does not take into account the 

temporary closure of the Serpentine ACEC. Management of recreation 

opportunities, special status species habitat, and other resources would be 

maintained at levels before the May 1, 2008, closure order. 

•	 Alternative B maintains multiple use opportunities in CCMA and would limit annual 

visitor use days, would impose seasonal use restrictions, and would apply other 

mitigation measures to protect public health and safety. 

•	 Alternative C would limit OHV recreation opportunities in the Serpentine ACEC, 

based on vehicle types and minimum age requirements, and includes other 

mitigation measures to protect public health. 

•	 Alternative D would emphasize vehicle access for nonmotorized recreation 

opportunities inside the ACEC and new OHV recreation opportunities outside the 

ACEC. 

•	 Alternative E (the Preferred Alternative) allows vehicle touring on an 11­mile scenic 

route in the ACEC and emphasizes nonmotorized recreation opportunities 

elsewhere. 

•	 Alternative F would limit public use in the ACEC to nonmotorized access by permit 

only. 

•	 Alternative G proposes to minimize public health risk by prohibiting all public 

access and entry into the Serpentine ACEC. 

Most natural resource management actions and cultural and heritage resource management 

actions contained in these alternatives would maintain the long­term social and economic 

health of local and regional economies and social systems and the heritage values of cultural 

artifacts. All except Alternative A would allow, but would restrict to some degree, activities 

that provide socioeconomic benefits to the region, local area, and individuals. Public health 

risks would be reduced and natural habits and unique species would benefit from reduced 

disturbance. 

3.1.9 Range of Impacts 

The alternatives would result in a range of impacts, mainly on economic characteristics that 

would be industry­ or location­specific and social characteristics in the planning area. It is 

unlikely that the alternatives would result in long­term regional effects on population and 

housing since the plan would not be growth inducing, nor would it cause people to leave the 

area. 

The regional economic perspective involves a large densely populated area with a diverse 

economy, in which activities on public lands in the CCMA would represent a very small 

facet. Recreation and the revenue generated by it in this region would be more affected by 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

population growth pressures, the availability of hunting permits, and social views on health 

and use of free time. Individual local and regional business owners could see losses as a 

result of restrictions on recreational activities. Individual motorcycle shops in the region and, 

potentially, service businesses could see losses in sales, depending on the level of restriction 

of recreation activities and the alternative selected. Alternatives E, F, and G would have 

major long­term adverse impacts on the social and economic conditions of businesses and 

employees in the communities that specialize in OHV sales. This means that there would be 

a highly noticeable, long­term or permanent, measurable negative change. 

Local grazing permittees and ranchers on adjacent private lands could see a loss in revenue 

from hunting services that provide access to the CCMA, particularly given restrictions in 

vehicle access that could prevent hunters from accessing or retrieving game (most likely to 

be an issue under Alternatives E, F, and G). The level of developable minerals would depend 

more on demand than what is available in the CCMA; however, Alternatives E, F, and G, 

which prohibit minerals entry or development in the Serpentine ACEC, could affect 

subsistence income from minerals collection. Most alternatives would continue to allow 

grazing of all or almost all AUMs, allowing the continued contribution of forage at a rate 

lower than that of leasing additional private land (if it were available). Eliminating grazing in 

the CCMA under Alternative G (not preferred) could have severe financial and social effects 

on seven allotments and seven permittees, particularly if this were to require that they find 

forage alternatives or sell livestock. If operation costs were to increase to the point where 

permittees would have to sell their ranches, this would result in a loss of lifestyle and 

potentially open space values. 

None of the anticipated socioeconomic impacts to be experienced by individuals and groups 

of a particular race or ethnicity appear to be negative, and no minority or low­income 

populations appear to be disproportionately at risk of being affected by public land 

management. 

Some areas for experiencing solitude would be lost under all alternatives except A. In 

addition, there would be some loss of locales for friends and family to bond and potentially a 

loss of OHV recreation, if other areas for OHV recreation were too far away. 

Urban, rural, and suburban communities with a high level of OHV recreational users and 

with the largest overall number of registered OHVs would be most likely to be affected by 

this. The top communities for registered OHVs are Bakersfield, Hollister, Livermore, Tulare, 

Clovis, Paso Robles, Wasco, Gilroy, and Porterville. However, OHV enthusiasts travel from 

greater distances to participate in this activity, and the social effects on this group could be 

more widespread. There would be effects on the social values of some grazing permittees, 

including the loss of a tradition of grazing on BLM lands under Alternative G, which would 

eliminate grazing in the CCMA. If the loss of hunting revenues or the loss of BLM­provided 

AUMs were to result in the loss of ranching, the lifestyle of ranchers and of residents and 

visitors who value livestock grazing on open land as an asset of Western culture would be 

adversely affected. All alternatives would improve the value of preserving unique species and 

biodiversity and pristine environments for future generations and of reducing the risk to 

public health and safety from exposure to airborne asbestos fibers. 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3.2	 COMPENSATION AND EMPLOYMENT BY INDUSTRY SECTOR 

This section provides updates of some of the employment information provided in the 

RMP/EIS and also provides a context for the types of employment impacts described in the 

RMP/EIS. It identifies the regional employment and compensation levels in the industries 

that would be most affected by the RMP/EIS alternatives (farming, mining, accommodation 

and food services, and retail trade), as compared to the other industries in the region. This 

information is supplied to show how much the regional economy depends on the sectors 

that would receive the greatest impacts and how much the regional economy depends on the 

counties that would be most affected by changes in management of the CCMA. In general, 

the updates and new data support the impact assessment that is in the RMP/EIS and that is 

described in Section 3.1.9. 

3.2.1	 Regional Updates and Changes Since 2001 

The RMP/EIS provided total employment and personal income figures for the Central 

Coast analysis area for 1980, 1990, 2000, and 2002. This area includes Monterey and Santa 

Cruz Counties and the Diablo Range analysis area, which includes Fresno, Merced, and San 

Benito Counties. This section presents more detailed data concerning compensation and 

employment for these areas, as well as for Santa Clara County, updated from the dates 

available at the time the draft RMP was prepared. The most current complete data for both 

employment and compensation by industry was from 2007, although some compensation 

data was available for 2008. This data is presented as tables in Appendix C and is described 

below. Tables C­1, C­2, C­3 present the total compensation by industry for 2001, 2007, and 

2008. Tables C­4 and C­5 show the percentage changes in compensation by industry 

between 2001 and 2007 and between 2007 and 2008. Tables C­6 and C­7 show employment 

by industry for 2001 and 2007, and Table C­8 shows the percentage change in employment 

between 2001 and 2007. Table C­9 presents average wages by industry. Table C­10 shows 

the 2007 percentage of total compensation in each industry sector represented in the 

socioeconomic workshop. 

In 2001, of the major industry sectors, Government and Government Enterprises provided 

the greatest value of compensation in the Central Coast analysis area, with a total of $2.8 

billion and an average of $1.4 billion. This was followed by Manufacturing, Retail Trade, 

Health Care and Social Assistance, and Accommodation and Food Services (Table C­1). 

However, in Monterey County, Forestry, Fishing, and Related Activities provided one of the 

highest levels of compensation, at $474 million; in Santa Cruz County, Professional, 

Scientific, and Technical Services provided one of the highest levels of compensation, at 

$426 million. The top five major industry sectors in the Diablo Range analysis area, with 

respect to compensation of employees, were Government and Government Enterprises 

(which provided a total of $3.7 billion and an average of $1.2 billion to its workforce), 

Manufacturing, Health Care and Social Assistance, Retail Trade, and Construction; in San 

Benito County, Wholesale Trade was among the five top paying industries. In contrast, in 

Santa Clara County, Manufacturing ($27.8 billion) and Professional, Scientific, and Technical 

Services($14.8 billion) provided the greatest compensation, followed by Government and 

Government Enterprises, Information, and Wholesale Trade (BEA 2009a). 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

At the same time, the largest employers in the Central Coast analysis area and in Monterey 

County alone were Government and Government Enterprises, Retail Trade, Forestry, 

Fishing, and Related Activities, Health Care and Social Assistance, and Accommodation and 

Food Services (please refer to Table C­6). In Santa Cruz County, Professional, Scientific, and 

Technical Services and Manufacturing replaced Forestry, Fishing, and Related Activities and 

Accommodation and Food Services among the top five employers. In 2001 the largest 

employers in the Diablo Range analysis area were Government and Government 

Enterprises, Retail Trade, Health Care and Social Assistance, Manufacturing, and 

Accommodation and Food Services. In the Diablo Range analysis area, Forestry, Fishing, 

and Related Activities ranked second in employment in Fresno County and was the fourth 

largest employment sector in Merced County. Construction replaced Forestry, Fishing, and 

Related Activities among the top five employers in San Benito County. In Santa Clara 

County in 2001, Manufacturing was by far the largest employer, followed by Professional, 

Scientific, and Technical Services, Retail Trade, Government and Government Enterprises, 

and Administrative and Waste Services (BEA 2009b). 

Between 2001 and 2007 within the Central Coast analysis area, compensation in Health Care 

and Social Assistance, Wholesale Trade, and Government and Government Enterprises 

increased by the greatest percentages (Table C­4); however, in Monterey County, the highest 

percentage increases occurred in Forestry, Fishing, and Related Activities and Transportation 

and Warehousing. The compensation provided by Information and Manufacturing declined 

by the greatest percentages in the Central Coast analysis area. Over this period, 

compensation in Administrative and Waste Services, Educational Services, and Professional, 

Scientific, and Technical Services increased by the greatest percentages in the Diablo Range 

analysis area. Utilities saw the largest percentage increase in Fresno County, whereas 

Information and Forestry, Fishing, and Related Activities had the greatest percentage 

increases in compensation in Merced County. The compensation provided by Management 

of Companies and Enterprises declined by the greatest percentage in the Diablo Range 

analysis area, but in Fresno and Merced Counties, compensation from Mining decreased by 

the greatest percentage. In Santa Clara County, compensation in Forestry, Fishing, and 

Related Activities, Educational Services, and Arts, Entertainment, and Recreation increased 

by the largest proportion between 2001 and 2007 (BEA 2009a). 

The same five major industry sectors provided the greatest compensation in the Central 

Coast analysis area in 2007 as in 2001, but the total level of compensation increased (see 

Tables C­2 and C­1). Within the Government and Government Enterprises industry sector 

in the Central Coast analysis area, local government accounted for the highest compensation 

(a total of $2.2 billion) in 2007 (Table C­2). In 2007 Computer and Electronic Product 

Manufacturing contributed the most to Durable Goods Manufacturing, and Food 

Manufacturing contributed the most to Nondurable Goods Manufacturing ($217 million and 

$206 million, respectively). The greatest compensation in Retail Trade in the Central Coast 

analysis area in 2007 came from Food and Beverage Stores and Motor Vehicle and Parts 

Dealers (with $268 million and $213, respectively). In Monterey County, Forestry, Fishing, 

and Related Activities ranked second in terms of compensation in 2007, following 

Government and Government Enterprises, contributing $890 million in compensation. 

About 99 percent of this total came from Agriculture and Forestry Support Activities. In 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Santa Cruz County, Health Care and Social Assistance followed Government and 

Government Enterprises as one of the largest contributors to compensation in 2007. The 

greatest contributions came from Ambulatory Health Care Services and Hospitals ($284 

million and $207 million, respectively; BEA 2009a). 

Similarly, in the Diablo Range analysis area, the same five major industry sectors provided 

the greatest compensation in 2007 as in 2001 (Tables C­2 and C­1). In 2007 the most 

compensation in Government and Government Enterprises came from Local Government, 

for a total of $3.7 billion, and the largest percentage of Health Care and Social Assistance 

compensation came from Ambulatory Health Care Services and Hospitals ($991 million and 

$885 million, respectively; Table C­2). Nondurable Goods Manufacturing provided slightly 

more compensation than Durable Goods Manufacturing, with the largest proportion 

deriving from Food Manufacturing ($835 million). In Fresno County, Health Care and Social 

Assistance provided the most compensation, following Government and Government 

Enterprises, most of which came from Ambulatory Health Care Services and Hospitals 

($845 million and $792 million, respectively). In Merced and San Benito Counties, 

Manufacturing provided the next greatest compensation, following Government and 

Government Enterprises, and in San Benito County, its contribution was very close to that 

of Government and Government Enterprises, at $167 million. Compensation in 

Manufacturing in San Benito County was relatively evenly distributed between Durable 

Goods (the largest proportion of which came from Fabricated Metal Product 

Manufacturing) and Nondurable Goods, with $85 million and $82 million, respectively. In 

Merced County Nondurable Goods Manufacturing was the dominant source of 

Manufacturing compensation, primarily Food Manufacturing (BEA 2009a). 

In Santa Clara County the same industry sectors that were the dominant sources of 

compensation in 2001 were the primary providers of compensation in 2007 (Tables C­1 and 

C­2). Computer and Electronic Product Manufacturing ($21.5 billion), Machinery 

Manufacturing ($1.5 billion), Miscellaneous Manufacturing ($691 million), and Fabricated 

Metal Product Manufacturing ($652 million) were the dominant suppliers of Manufacturing 

compensation (Table C­2) (BEA 2009a). 

As presented in Table C­8, employment in the Central Coast analysis area increased the most 

in Real Estate and Rental Leasing (45.6 percent), Accommodation and Food Services (29.7 

percent), Educational Services (24.5 percent), and Wholesale Trade (17.8 percent) between 

2001 and 2007. However, the Real Estate and Rental Leasing and Accommodation and 

Food Services sectors were not among the highest growth sectors for wage compensation. 

Differences among individual counties in the Central Coast analysis area include 

employment in Forestry, Fishing, and Related Activities, which saw the second largest 

percentage increase in Monterey County (23.8 percent). This industry also experienced a 

concurrent increase in total compensation, after Real Estate and Rental Leasing. 

Employment in Accommodation and Food Services increased by nearly 136 percent in Santa 

Cruz County (BEA 2009b). 

In the Diablo Range analysis area, employment in Real Estate and Rental Leasing (63.0 

percent), Educational Services (45.1 percent), Administrative and Waste Services (34.0 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

percent), Construction (32.7 percent), and Professional, Scientific, and Technical Services 

(30.1 percent) increased by the greatest percentages between 2001 and 2007 (Table C­8). In 

Fresno County, employment in Utilities increased (35.5 percent) by more than in 

Administrative and Waste Services and Construction. In Merced County, employment in 

Information more than doubled (a 164.7 percent increase), while in San Benito County, 

employment in this sector declined by 4.2 percent. In each of the three counties in the 

Diablo Range analysis area, employment in Management of Companies and Enterprises, 

Retail Trade, and Farming declined. Similar to the Central Coast and Diablo Range analysis 

areas, in Santa Clara County, Real Estate and Rental Leasing (64.7 percent) and Educational 

Services (20.3 percent) were among the industries with the greatest percentage increases in 

employment between 2001 and 2007. As shown in Table C­8, unlike the Central Coast and 

Diablo Range analysis areas, employment in Santa Clara County declined in 10 out of 21 

industries (Management of Companies and Enterprises, Manufacturing, Farming, Utilities, 

Transportation and Warehousing, Information, Professional, Scientific, and Technical 

Services, Administrative and Waste Services, Retail Trade, and Government and 

Government Enterprises) (BEA 2009b). 

Table C­7 shows the most currently available employment data for the RMP planning area. 

In 2007 the greatest employment in the Central Coast analysis area was in Government and 

Government Enterprises, Retail Trade, Accommodation and Food Services, Health Care 

and Social Assistance, and Professional, Scientific, and Technical Services. There were slight 

differences in major employers in Monterey and Santa Cruz Counties. In Monterey County, 

Forestry, Fishing, and Related Activities was the second­largest employer in 2007 (and also 

provided the second largest level of compensation); employment in Santa Cruz County 

reflected that of the Central Coast analysis area. The largest employers in 2007 in the Diablo 

Range analysis area were similar to those in the Central Coast analysis area: Government and 

Government Enterprises, Retail Trade, and Health Care and Social Assistance. However, 

Manufacturing (42,617 jobs) and Construction (35,125 jobs) provided substantial 

employment in the Diablo Range analysis area. Forestry, Fishing, and Related Activities was 

one of the top five employers in Fresno County in 2007, with 34,686 employees (7.6 percent 

of total employment), and Farming employed 9.5 percent of the workforce in Merced 

County (8,969 workers) and was the fourth largest employment sector. The largest 

employers in Santa Clara County also were similar to those in the Central Coast and Diablo 

Range analysis areas; however, most jobs were in Manufacturing (170,176) and Professional, 

Scientific, and Technical Services (163,802) (BEA 2009b). 

Table C­9 shows that the average compensation per worker in 2007 was $38,033 in the 

Central Coast analysis area, $33,777 in the Diablo Range analysis area, and $75,189 in Santa 

Clara County, an increase of 21.8 percent, 27.5 percent, and 13.5 percent, respectively, since 

2001. Within the Central Coast analysis area, the highest levels of compensation per 

employee occurred in Management of Companies and Enterprises ($129,374), and the 

lowest occurred in Real Estate and Rental and Leasing. The highest compensation per 

employee in Monterey County was in the Utilities sector at $97,440, and in Santa Cruz 

County, compensation per employee in Management of Companies and Enterprises 

averaged $170,639. In 2007 in the Diablo Range analysis area, the highest compensation per 

employee occurred in Government and Government Enterprises at $62,215, followed by 

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Management of Companies and Enterprises at $56,499. Similar to the Central Coast analysis 

area, the lowest was in Real Estate and Rental and Leasing. In Fresno County in 2007, 

compensation per employee in Utilities was the highest at $104,272, and average 

compensation per employee was higher than the average in the Diablo Range analysis area 

for 11 industries (Utilities, Management of Companies and Enterprises, Government and 

Government Enterprises, Information, Wholesale Trade, Manufacturing, Health Care and 

Social Assistance, Finance and Insurance, Construction, Mining, and Transportation and 

Warehousing). The source of the highest compensation per employee in Merced County was 

Management of Companies and Enterprises (the same as the Diablo Range analysis area); 

however, the lowest was in Educational Services. Government and Government Enterprises 

provided the largest compensation per employee in San Benito County. Compensation per 

worker in Santa Clara County differed by industry and compensation levels. Information, 

Wholesale Trade, Manufacturing, Professional, Scientific, and Technical Services, and 

Utilities provided the highest compensation per worker, ranging from $177,388 down to 

$84,230 (BEA 2009a, 2009b). 

Data concerning compensation for 2008 was available only for the major industry sectors. 

As shown in Table C­3, the same five major industry sectors provided the greatest 

compensation in the Central Coast analysis area in 2008 as in 2001 and 2007; however, the 

total level of compensation increased since 2007 in Government and Government 

Enterprises, Health Care and Social Assistance, and Accommodation and Food Services, and 

it decreased in Retail Trade and Manufacturing (Table C­5). In Santa Cruz County, 

compensation in Health Care and Social Assistance declined between 2007 and 2008. Similar 

to the Central Coast analysis area, the same five major industry sectors provided the greatest 

compensation in the Diablo Range analysis area in 2008 as in 2001 and 2007; however, of 

the top five industries, compensation increased only for Government and Government 

Enterprises and Health Care and Social Assistance and declined for Manufacturing, Retail 

Trade and Construction since 2007. In Merced County, compensation in Manufacturing 

increased between 2007 and 2008. Similar major industry sectors provided the greatest 

compensation in Santa Clara County in 2008 as in 2001 and 2007, except that Wholesale 

Trade was no longer among the top five industries for compensation; it was replaced by 

Health Care and Social Assistance with the fifth largest compensation. Compensation 

increased in Professional, Scientific, and Technical Services, Information, Government and 

Government Enterprises, and Health Care and Social Assistance between 2007 and 2008 in 

Santa Clara County; but compensation in Manufacturing declined during that period (BEA 

2009a). 

3.2.2	 Detailed Compensation and Employment by Industry Sector for the 

Sectors Represented at the Socioeconomic Workshop 

The industry sectors shown in Tables C­1 through C­9 and discussed at the socioeconomic 

workshop that would be affected by restrictions in OHV use at the CCMA are the following: 

•	 Mining; 

•	 Retail Trade, including Motor Vehicle and Parts Dealers, Food and Beverage Stores, 

and Gasoline Stations; and 

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•	 Accommodation and Food Services, including Accommodation and Food Services 

and Drinking Places. 

As shown in Table C­10, in 2007, the percentage of total compensation to workers in Mining 

in the Central Coast analysis area was not available because it is proprietary information. 

This often means that the industry is so small that revealing any information would disclose 

data from a particular business. Retail Trade was the source of about 7.8 percent of 

compensation, about 18.5 percent of which was from Motor Vehicle and Parts Dealers, 23.3 

percent was from Food and Beverage Stores, and 2.3 percent was from Gasoline Stations. 

Retail Trade was a higher percentage of total compensation (9.4 percent) in Santa Cruz 

County than in Monterey County (7.0 percent). Food and Beverage Stores had a greater 

contribution to Retail Trade in Santa Cruz County (29.7 percent), while Gasoline Stations 

contributed a higher percentage to Retail Trade compensation in Monterey County (3.0 

percent). Accommodation and Food Services contributed about 5.3 percent of total 

compensation in the Central Coast analysis area in 2007, about 43.8 percent of which came 

from Accommodation and 56.2 percent came from Food Services and Drinking Places. In 

Santa Cruz County a lower percentage of compensation to workers came from 

Accommodation and Food Services (4.0 percent), as compared to Monterey County (6.1 

percent), and most of this sector in Santa Cruz County was composed of Food Services and 

Drinking Places (81.9 percent). The industry sectors most directly affected by the CCMA 

closure provided about 13.1 percent of total compensation in the Central Coast analysis area, 

which decreased to 12.9 percent in 2008. The more detailed industries represented at the 

Socioeconomic Workshop, excluding Mining, provided about 8.8 percent of total 

compensation to workers in this area (BEA 2009a). 

As with the Central Coast analysis area, the percentage of total compensation to workers in 

Mining in the Diablo Range analysis area was not available because it is proprietary 

information. Retail Trade was the source of about 7.6 percent of compensation in the Diablo 

Range analysis area, about 21.3 percent of which was from Motor Vehicle and Parts Dealers 

and 19.1 percent was from Food and Beverage Stores; the amount from Gasoline Stations 

was undisclosed to protect businesses in San Benito County. Retail Trade was the highest 

percentage of total compensation (9.9 percent) in San Benito County, which had the greatest 

percentage of Retail Trade derived from Food and Beverage Stores (53.7 percent). Gasoline 

Stations contributed a higher percentage to Retail Trade compensation in Merced County 

(7.4 percent) than Fresno County (3.1 percent). Accommodation and Food Services 

contributed about 2.8 percent of total compensation in the Diablo Range analysis area in 

2007, about 9.8 percent of which came from Accommodation and 86.1 percent came from 

Food Services and Drinking Places. The percentage of compensation to workers that came 

from Accommodation and Food Services was the highest in San Benito County (3.0 percent) 

and the lowest in Merced County (2.4 percent). The industry sectors most directly affected 

by the CCMA closure provided about 10.4 percent of total compensation in the Central 

Coast analysis area, which decreased to 10.1 percent in 2008. The more detailed industries 

represented at the Socioeconomic Workshop, excluding Mining and Gasoline Stations, 

provided about 5.9 percent of total compensation to workers in this area (BEA 2009a). 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In Santa Clara County, compensation from Mining provided about 0.02 percent of total 

compensation to workers. Both Retail Trade and Accommodation and Food Services were 

lower percentages of total compensation in Santa Clara County, at 4.7 percent and 1.8 

percent, than for the Central Coast analysis area and the Diablo Range analysis area. 

Compensation from Motor Vehicle and Parts Dealers and Food and Beverage Stores each 

comprised 12.5 of Retail Trade, and Gasoline Stations provided 1.2 percent of compensation 

from Retail Trade. Most compensation from Accommodation and Food Services (80.4 

percent) was derived from Food Services and Drinking Places. The industry sectors most 

directly affected by the CCMA closure provided about 6.6 percent of total compensation in 

Santa Clara County, which decreased to 6.4 percent in 2008. The more detailed industries 

represented at the Socioeconomic Workshop provided about 3.1 percent of total 

compensation to workers in this area (BEA 2009a). 

In 2007 approximately 10.3 percent of employment in the Central Coast analysis area was in 

Retail Trade; 8.3 percent was in Accommodation and Food Services; employment in Mining 

was not available in order to avoid disclosure of proprietary information for Santa Cruz 

County. In Monterey County, a greater portion of the workforce was employed in 

Accommodation and Food Services (8.9 percent) than in Santa Cruz County (7.4 percent), 

and Gasoline Stations employed 0.2 percent of the workforce in Monterey County. In the 

Diablo Range analysis area, a similar portion of the workforce to that in the Central Coast 

analysis area was employed in Retail Trade (10.4 percent), but a lower percentage was 

employed in Accommodation and Food Services (5.9 percent). Similarly, employment in 

Mining was not available in order to avoid disclosure of proprietary information in San 

Benito County. In Santa Clara County, about 8.9 percent of the workforce was employed in 

Retail Trade, which is a lower level than either the Central Coast or the Diablo Range 

analysis areas. Roughly 6.0 percent of Santa Clara County’s workforce was employed in 

Accommodation and Food Services, while 0.1 percent worked in Mining. The percentages 

employed in the industries that would likely be affected by changes in management of the 

CCMA are relatively low from an economy­wide perspective, particularly compared to the 

largest employment sectors, such as Government and Government Enterprises. However, 

from a more local perspective, these sectors still employed a large number of workers: 

71,211, excluding Mining in Santa Cruz County, in the Central Coast analysis area; 94,057, 

excluding Mining in San Benito County, in the Diablo Range analysis area; and 176,291 in 

Santa Clara County (Table C­7). 

3.3	 CHANGES IN HOUSING VALUES SURROUNDING THE CCMA 

Landowners next to the CCMA and participating in the socioeconomic workshop felt that 

their property values had declined due to the temporary closure of the CCMA and that the 

loss in value could become permanent if long­term restrictions were too stringent. Initial 

research into property values in the area is presented below. 

US Census median housing value estimates were used to show the recent trends in housing 

values in the RMP study area. These values were analyzed to show changes in housing values 

since the closure of the CCMA; however, this does not imply that the cause of changes in 

median housing values is related to the CCMA closure. The three­year averages for 2005 to 

2007 and 2006 to 2008 were used instead of the single­year averages since single­year 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 27 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

averages were not available for all areas, particularly San Benito County (Table C­11). From 

2005 to 2007, the average housing median value in the Central Coast analysis area was 

$690,500, 34.5 percent higher than the median housing value in California ($513,200) and 

279.8 percent higher than the nationwide median housing value ($181,800). The average 

median housing value in the Central Coast area decreased by 2.4 percent from 2006 to 2008, 

from $690,500 to $673,700. Within the same period, the average median housing value 

decreased by 0.6 percent in California and increased by 5.8 percent nationwide. In Monterey 

County alone the average median housing value decreased by 3.5 percent, from $662,300 to 

$638,600. The average median housing value in Santa Cruz County decreased by 1.4 percent 

during the same period, from $718,700 to $708,700 (US Census Bureau 2010a, 2010b). 

In the Diablo Range analysis area the average median housing value was $429,033 from 2005 

to 2007, 16.4 percent lower than the average median housing value in California and 135 

percent higher then the nationwide average median housing value. It decreased by three 

percent from 2006 to 2008, from $429,033 to $416,066. Of the three counties within the 

Diablo Range analysis area, the average median value in Fresno County increased by 0.7 

percent, while it decreased by 6.8 percent and 2.7 percent in Merced and San Benito 

Counties. Fresno and Merced Counties had lower average median housing values than 

California for both periods (2005 to 2007 and 2006 to 2008). For Fresno County, the median 

housing value was 44.5 percent lower than that of California from 2005 to 2007 and 43.7 

lower than that of California from 2006 to 2008. The median housing value in Merced 

County was 35.0 percent lower than the average value in California from 2005 to 2007 and 

39.1 percent lower than the average value in California from 2006 to 2008. San Benito 

County’s median housing value was higher than that of California by 30.3 percent from 2005 

to 2007 and 27.5 percent higher from 2006 to 2008 (US Census Bureau 2010a, 2010b). 

Santa Clara County had the highest average median housing value among the counties near 

the CCMA area, with $725,800 from 2005 to 2007. From 2006 to 2008, it increased by 2.4 

percent to $743,200 (US Census Bureau 2010a, 2010b). 

Although housing values within most of the counties near the CCMA decreased at a higher 

rate than that of the state, except for Fresno County where it increased, the source of 

decrease in value is not easily identifiable. The closure of the CCMA occurred during the 

economic recession that has affected businesses and housing values. Some areas have been 

more acutely affected than others. Some of the decrease in housing values in the counties 

near the CCMA could be indirectly connected to the closure, as a result of a decrease in the 

economic activity; however, they are more likely to reflect the overall decrease in economic 

activity for the time the estimates were made. It is more likely that a change in housing 

values resulting from the closure of the CCMA would be much more localized than there are 

reliable data to support. 

4. CONTRIBUTION OF THE CCMA TO THE LOCAL ECONOMY AND SOCIAL VALUES 

As reinforced by the input from the Socioeconomic Workshop, CCMA visitors feel a strong 

social and economic connection to the area. Hobby groups, such as recreational rock and 

mineral collectors, value the area as a place to gather with others, who have similar interests 

and values, to pursue their mutual interests. Members of these groups tend to be from a 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 28 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

similar demographic (over the age of 55); the CCMA provides them with a uniquely 

accessible resource not available elsewhere west of the Sierra Nevada. Mineral collection and 

ranching in the CCMA can provide a link between modern and traditional/rural lifestyles. 

For example, mineral collection and ranching have long cultural and family traditions. 

Similarly, nearby private landholders also value the CCMA for proximity to recreation, 

particularly for ease of access to hiking, OHV use, and appreciation of the natural 

environment. Members of this group said that these social benefits add value to their 

property. 

Recreation opportunities within the CCMA, including hiking, camping, hunting, and OHV 

use, provide an experience that workshop participants said was unique and irreplaceable. For 

nonmotorized recreationists, this experience can involve exposure to nature and solitude, 

quiet, and opportunities for self discovery that are missing in modern life. Many areas within 

three hours drive of the CCMA are densely populated and the open space is heavily used. 

The CCMA provides a sense of separation from these areas. For all visitors, the CCMA can 

represent an opportunity for families to participate in activities together, to spend time 

together, and to understand each other better. The CCMA also presents possibilities for 

young adults to participate in social activities that are not destructive and that broaden their 

experiences, and it offers occasions for several generations of relatives to participate in OHV 

recreation. OHV recreationists emphasized that, even though other OHV recreation 

opportunities exist, the type of recreation opportunity provided by the CCMA was 

unavailable within a day’s drive. In addition, the emergency closure of the CCMA has caused 

overcrowding in other nearby OHV recreation areas, diminishing the recreation experience 

in those areas. 

Workshop participants said that visitation to the CCMA also has contributed to the 

economic and social well being of business owners. OHV business groups (motorcycle 

dealers and accessory and parts shops) and the other members of the business community 

said there has been a marked reduction in economic activity since the closure, including 

declining sales of motorcycles and associated parts and services and decreased sales at 

restaurants, lodgings, and gasoline stations. These participants felt that visitation at the 

CCMA contributed the satisfaction of owning and operating their businesses, through the 

economic activity visitors generate. 

Some business owners said that the CCMA also provides business opportunities that are 

unique to the area, mainly mining minerals that do not occur in abundance elsewhere. 

Other workshop participants highlighted the cultural importance of the CCMA. For 

example, Rick Larios noted there are traditional use areas and values within the CCMA that 

are important to local Native Americans, and visiting the CCMA has extended the 

connection of Native Americans with their ancestral lands and traditions. 

5. SOCIOECONOMIC IMPACTS AND ALTERNATIVES PREFERRED BY THE WORKSHOP GROUPS 

The RMP/EIS identified in Section 4.15.2.4, Recreation (and Transportation) Management 

Actions, that, given the anticipated growth in population and in OHV recreation activity, it is 

likely that some individual businesses, like motorcycle shops in Salinas and Hollister, would 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 29 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

continue to rely greatly on OHV recreation in the CCMA. This assessment also is borne out 

by workshop participants, who indicated that their businesses and recreational opportunities 

would be affected. However, the RMP/EIS also stated that expenditures on recreation in the 

CCMA would be relatively small compared to the economic activity in the Central Coast and 

Diablo Range study areas, a conclusion that is supported by the supplemental data on 

employment and compensation information presented in Section 3.2, Compensation and 

Employment by Industry Sector. The RMP/EIS also identified that public lands provided 

one of the few venues for residents to escape a growing population and to find a sense of 

isolation, an experience that would be even more valued as the population continues to grow 

as expected. The increasing value of the CCMA to its various user groups is demonstrated by 

the level of participation at the socioeconomic workshop (73 people signed in) and the input 

presented in Section 2.3, Summary of Group Input, and 2.4, Summary of Workshop Group 

Written Comments. 

The RMP/EIS indicates that, as a result of Alternatives E, F, and G, communities with 

comparatively high employment in retail motorcycle sales are most likely to experience longterm adverse effects under these alternatives as motorized recreation on public lands in 

CCMA decreases significantly. It concludes that Alternatives E, F, and G would have major 

long­term adverse impacts on the social and economic conditions of businesses and 

employees within the communities that specialize in OHV sales due to the loss of OHV 

recreation opportunities on CCMA public lands. As summarized below, the selection of the 

most desired alternatives by workshop participants reflects this assessment of alternatives in 

the RMP/EIS. 

Most groups that participated in the socioeconomic workshop said that RMP Alternative A 

(the No Action Alternative) is the option that would be least likely to adversely affect the 

level of social and economic benefit they derive from the CCMA. Some participants said that 

modifying this alternative to ensure public safety, such as putting in place seasonal or age 

restrictions or waivers, could be acceptable in order to maintain full access. Participants said 

that the emergency closure has reduced business, participation in recreation activities and 

organizations, and the level of satisfaction with their overall recreation experience; for this 

reason, Alternative G would not be acceptable to many of the groups participating in the 

Workshop. Representatives of some recreation organizations felt that their organizations 

would become obsolete if the CCMA remained closed. The rock and minerals collectors 

group said that Alternative E could still provide enough access to allow them to pursue their 

interests, as long as there was some vehicle access to the mineral collection areas. 

Representatives of tribal interests said that they prefer alternatives that would restrict access 

in order to reduce damage to the natural environment and tribal resources. This group felt 

that public access over the years has degraded these resources and resulted in a great deal of 

trash in areas of heavy public use. 

6. CONCLUSION 

The socioeconomic workshop provided a forum for a cross­section of users who would be 

affected by the RMP alternatives to describe the social and economic value of the CCMA 

and to identify the types of effects they anticipate from the RMP alternatives. User groups 

identified their interest in the use of the public lands in the CCMA and their overarching 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 30 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

social and economic concerns. A summary of existing conditions in the RMP planning area 

and the RMP alternatives provided a basis on which the different groups could identify their 

particular issues. The workshop also provided information on additional data sources that 

user groups could access to gain additional insight on the regional economy and the role of 

their businesses in that economy. User input was collected at the workshop from 

participants and from written documentation provided by participants. This information has 

been summarized in this report and will help the BLM understand how the groups 

potentially affected by the RMP value the CCMA. Participant input and this report will 

become part of the public record for the CCMA RMP, to document public participation in 

the RMP process. 

In general, the additional baseline data provided in this report, updating employment figures 

in the RMP/EIS, and providing greater detail on employment and compensation by industry 

support the conclusions in the RMP/EIS that regional economic impacts from the RMP 

Alternatives would be minimal. However, as also identified in the RMP/EIS, participant 

input indicated that restrictions on use or closure of the CCMA to OHV and rock hounding 

would have user group­specific economic impacts and social impacts. Examples of the 

magnitude and types of these effects were described in detail through the group input and 

written submittals for the socioeconomic workshop. The overwhelming response by 

participants in OHV recreation, OHV­related businesses, and service and retail businesses in 

the immediate vicinity of the CCMA to select Alternative A imply that some option that 

would allow continued OHV use in the area be considered, even though regional economic 

impacts resulting from reduced OHV use of the CCMA would be minimal. It also indicated 

that continued motorized access for mineral collectors would be a socially important 

consideration. 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 31 
 

 

 

 

 

 

 

 

 

 

 

 

7. REFERENCES 

BEA (Bureau of Economic Analysis). 2009a. CA06N Compensation of employees by NAICS industry. 

Internet Web site: http://www.bea.gov/regional/reis/action.cfm. 

_____ . 2009b. CA25N Total full­time and part­time employment by NAICS industry. Internet Web site: 

http://www.bea.gov/regional/reis/action.cfm. 

BLM. 2009. Clear Creek Management Area Draft Resource Management Plan and Draft Environmental 

Impact Statement. November 2009. 

US Census Bureau. 2010a. Selected Housing Characteristics: 2006­2008, 2006­2008 American Community 

Survey 3­Year Estimates. Internet Web site: http://factfinder.census.gov/servlet/ADPTable?_ 

bm=y&­state=adp&­context=adp&­qr_name=ACS_2008_3YR_G00_DP3YR4&­ds_name= 

ACS_2008_3YR_G00_&­tree_id=3308&­_caller=geoselect&­geo_id=05000US06069&­format=&­

_lang=en. 

_____ . 2010b. Selected Housing Characteristics: 2005­2007, 2005­2007 American Community Survey 3­

Year Estimates. Internet Web site: http://factfinder.census.gov/servlet/ADPTable?_bm=y&­

state=adp&­context=adp&­qr_name=ACS_2007_3YR_G00_DP3YR4&­

ds_name=ACS_2007_3YR_G00_&­tree_id=3307&­redoLog=true&­_caller=geoselect&­

geo_id=05000US06069&­format=&­_lang=en. 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 32 
APPENDIX A 

INVITATION LETTER 

United States Department of the Interior 

BUREAU OF LAND MANAGEMENT 

Hollister Field Office 

20 Hamilton Court 

Hollister, CA 95023 

www.ca.blm.gov/hollister 

January 25, 2010 

In Reply Refer to: 

(1610) P 

CA-0900.38 

Name 

Agency/Org/Title 

Address 

Etc. 

The Bureau of Land Management (BLM) invites you to attend a Social and Economic Strategies 

Workshop to discuss social and economic issues related to public land use decisions and alternatives 

described in the Clear Creek Management Area (CCMA) Draft Resource Management Plan (RMP) 

and Environmental Impact Statement (EIS), prepared by the Hollister Field Office and released for 

public review and comments on December 4, 2009. 

The Hollister Field Office will host the Social and Economic Strategies Workshop to discuss 

potential impacts to social and economic conditions as a result of alternative land use decisions 

outlined in the BLM’s CCMA Draft RMP and EIS. The goal of the workshop is to provide local 

businesses, private landowners, and other existing rights-holders, as well as local government and 

elected officials with information about the Draft CCMA RMP/EIS and use their knowledge to assist 

BLM in characterizing social and economic trends in local communities and the region that may 

affect and be affected by public land use planning decisions for CCMA. 

The workshop will also devote some time introducing participants to economic concepts, the sources 

of economic data, the data itself and the processes of economic analysis. Following this portion of 

the meeting, participants will have the opportunity to critique the data presented in the Draft 

RMP/EIS and respond to questions that will assist in identifying the ways public land resources are 

integrated into the local economy and way of life. For example, 

− What are the area’s most significant social and economic assets? 

− Are there any common misconceptions about the local economy? 

− What are the strengths and weaknesses of the local (and regional) economies? 

− How would CCMA Draft RMP alternatives affect you economically? 

− How would CCMA Draft RMP alternatives affect your lifestyle? 

− Does the information in the CCMA Draft RMP/EIS reflect current social and economic 

conditions and the potential impacts associated with the range of alternatives? 

The Social and Economic Strategies Workshop for the CCMA Draft RMP/EIS will be held from 

1:00 pm - 5:00 p.m. in Hollister, CA on Monday, February 22, 2010 at San Juan Oaks.... 
Participants will have the opportunity to discuss the social and economic values of the region, to 

provide input on the future and direction of land use planning, and to discuss the role that BLM 

public lands in CCMA have in supporting community goals and values. 

To stay on schedule and ascertain the appropriate information needed for the CCMA RMP/EIS, it 

will be important to keep the workshops focused on social and economic issues, not general planning 

issues and comments. The BLM-managed lands in CCMA are within a region with a large and 

rapidly growing population and economy. However, this makes it important to identify the smaller 

communities and groups within the region that may be more directly affected by BLM planning 

decisions for CCMA, and public involvement from these particular groups may help identify 

opportunities to advance local economic and social goals through planning and policy decisions 

within the authority of BLM, its cooperating agencies, or other partners. 

For more information on the planning sessions, contact BLM Hollister Field Office Environmental 

Coordinator, Sky Murphy (831) 630-5039. 

Sincerely, 

Rick Cooper, 

Field Office Manager 
APPENDIX B 

WORKSHOP MATERIALS 

BUREAU OF LAND MANAGEMENT 

Socioeconomic Workshop 

Clear Creek Management Area 

Draft Resource Management Plan 

and Environmental Impact Statement 

Hollister, CA –February 22, 2010 

1:00-5:00 pm 

AGENDA 

Sign-in: 1:00 – 1:20 pm 

Presentation: 1:20 – 1:50 pm 

- Introduction and Purpose of the Workshop- Rick Cooper, BLM Hollister Field Office 

- Socioeconomic Analysis- Genevieve Kaiser, Facilitator, Tetra Tech Inc. 

Break: 1:50 – 2:00 pm 

Group Discussions: 2:00 – 2:30 pm 

Organize into small groups for discussion based on social and economic interests 

For example: 

OHV Business – OHV Recreation (Clubs/Org.) – Other Business/Services – 

Minerals/Mining -- Landowners/Grazing/Hunting – Other/Misc. 

Groups should discuss the info provided during the workshop and select a speaker to report 

the perspectives of participants in relation to socioeconomic issues and concerns. 

Each group should identify a note-taker to record the discussion of the questions provided in 

the workshop materials 

Group Input: 2:30 – 4:30 pm 

Group speakers and key participants will reconvene to present the findings from each group. 

Group speakers will have about three minutes to present a summary of the group’s input to 

each of the questions provided in the workshop materials 

Meeting Summary and Closing Remarks: 4:30 – 5:00 pm 

General audience and other attendees will have an opportunity to ask questions and provide 

input on social and economic issues related to the Draft CCMA RMP/EIS, as time permits 
Bureau of Land Management 

Draft Clear Creek Management Area 

 Resource Management Plan & Environmental Impa

Socioeconomic Workshop 

San Juan Oaks Golf Resort, Hollister, CA 

February 22, 2010 

( PLEASE PRINT) 

NAME ORGANIZATION / AFFILIATION (*) ADDRESS 

(*) optional: Names of meeting attendees are part of the public record. You may request confidentiality to withhold your contact informat

Such requests will be honored to the extent allowed by law. All submissions from organizations or businesses will be made a
 

 

 

 

 

 

 

 

BUREAU OF LAND MANAGEMENT 

Draft Clear Creek Management Area Resource Management Plan 

& Environmental Impact Statement 

Socioeconomic Discussion Topics 

Thank you for participating in today’s socioeconomic workshop for the Draft Clear Creek 

Management Area (CCMA) Resource Management Plan (RMP) and Environmental Impact 

Statement (EIS). Your input on the socioeconomic analysis in the Draft Environmental Impact 

Statement is appreciated. 

 Written input may be submitted by any of the following methods: 

Hand: Place in drop-box during public meetings. 

Mail: BLM Hollister Field Office

 Attn: CCMA RMP/EIS 

20 Hamilton Court 

 Hollister, CA 95023 

Email: cahormp@ca.blm.gov 

Fax: (831) 630-5055 Attn: CCMA RMP/EIS 

Name (Please print): ____________________________________________________ 

Affiliation (if applicable): __________________________________________________ 

Phone: ______________________________ Email: ___________________________ 

Address: ______________________________________________________________ 

City, State, Zip: _________________________________________________________ 

•		 Have businesses have seen a drop in activity/revenue since the CCMA closure? 

•		 Have any businesses closed since the closure of the CCMA? 

•		 Has there been a rebound in economic activity since the initial closure? 

•		 How would CCMA Draft RMP alternatives affect you economically? 

•		 How would CCMA Draft RMP alternatives affect your lifestyle? 

•		 Does the information in the CCMA Draft RMP/EIS reflect current social and economic 

conditions and the potential impacts associated with the range of alternatives? 
 

APPENDIX C 

COMPENSATION, EMPLOYMENT, AND HOUSING 

TABLES 

Table C­1

Compensation of Employees by Industry, 2001 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Total average compensation per job 

(dollars)1 $39,538 $41,862 $81,400 $40,700 $34,597 $31,633 $36,317 $10Compensation of employees, received2 $7,129,614 $4,601,181 $11,730,795 $5,865,398 $11,630,035 $2,117,391 $589,566 $14,33

Farm compensation $469,255 $191,089 $660,344 $330,172 $404,815 $179,516 $33,261 $61Nonfarm compensation $6,660,359 $4,410,092 $11,070,451 $5,535,226 $11,225,220 $1,937,875 $556,305 $13,71

Private compensation $4,749,634 $3,549,939 $8,299,573 $4,149,787 $8,257,820 $1,362,908 $418,106 $10,03

Forestry, fishing, and related activities $474,345 $19,476 $493,821 $246,911 $536,107 $51,160 (D) (D) 

Forestry and logging (D) (D) (D) (D) (D) (D) $0 (D) Fishing, hunting, and trapping (D) (D) (D) (D) (D) (D) $0 (D) 

Agriculture and forestry support 

activities $471,171 $18,520 $489,691 $244,846 $535,006 $50,886 (D) (D) 

Mining $18,457 $3,495 $21,952 $10,976 $15,510 $1,192 (D) (D) 

Oil and gas extraction (D) (D) (D) (D) (D) $0 $0 (D) Mining (except oil and gas) $12,779 (D) (D) (D) (D) (D) (D) (D) Support activities for mining (D) $0 (D) (D) $7,506(D) $0 (D) 

Utilities $49,481 (D) (D) (D) $108,984(D) (D) (D) Construction $336,121 $257,907 $594,028 $297,014 $691,215 $75,710 $53,579 $82

Construction of buildings $106,088 $71,110 $177,198 $88,599 $171,560 $18,644 $8,663 $19Heavy and civil engineering construction $51,354 $53,506 $104,860 $52,430 $79,200 $6,600 $4,647 $9Specialty trade contractors $178,679 $133,291 $311,970 $155,985 $440,455 $50,466 $40,269 $53

Manufacturing $476,974 $554,655 $1,031,629 $515,815 $1,096,302 $357,050 $113,925 $1,56

Durable goods manufacturing $147,094 $410,229 $557,323 $278,662 $498,240 $72,109 $79,877 $65

Wood product manufacturing $5,379 $11,714 $17,093 $8,547 $37,704 $7,591 $8,706 $5

Nonmetallic mineral product manufacturing $14,473 $33,354 $47,827 $23,914 $39,076 (D) (D) (D) Primary metal manufacturing $1,189 (D) (D) (D) $16,695 $0 $321 $1Fabricated metal product manufacturing $16,419 $12,243 $28,662 $14,331 $112,432 $17,682 $30,092 $16Machinery manufacturing $19,724 $17,981 $37,705 $18,853 $122,942 $9,355 $4,042 $13Computer and electronic product manufacturing $70,648 $289,261 $359,909 $179,955 $55,910 (D) $12,035 $6Electrical equipment and appliance manufacturing (D) $2,189 (D) (D) (D) (D) (D) (D) Motor vehicles, bodies and trailers, and parts manufacturing (D) (D) (D) (D) (D) (D) (D) (D) Other transportation equipment manufacturing (D) (D) (D) (D) (D) (D) (D) (D) Furniture and related product $4,263 $6,687 $10,950 $5,475 $24,535 $2,287 $484 $2

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­1

Compensation of Employees by Industry, 2001 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

manufacturing Miscellaneous manufacturing $5,814 $14,064 $19,878 $9,939 $61,930 $2,323 (D) (D) 

Nondurable goods manufacturing $329,880 $144,426 $474,306 $237,153 $598,062 $284,941 $34,048 $91

Food manufacturing $235,279 $75,655 $310,934 $155,467 $407,587 $187,725 $11,106 $60Beverage and tobacco product manufacturing $38,218 $7,538 $45,756 $22,878 $61,039 (D) $3,915 $6

Textile mills (D) $413 (D) (D) (D) (D) $0 (D) Textile product mills $493 $2,513 $3,006 $1,503 $3,191(D) $0 $Apparel manufacturing $10,604 $2,666 $13,270 $6,635 (D) (D) (D) (D) 

Leather and allied product manufacturing (D) (D) (D) (D) $11,374 $0 $0 $1Paper manufacturing $22,474 (D) (D) (D) $32,589 (D) (D) (D) Printing and related support activities $9,379 $11,855 $21,234 $10,617 $30,557 (D) (D) (D) Petroleum and coal products manufacturing $0 $0 $0 $0 $10,786 $0 (D) (D) Chemical manufacturing $12,462 $27,713 $40,175 $20,088 $13,604 (D) (D) (D) Plastics and rubber products manufacturing $854 $9,384 $10,238 $5,119 $25,353 $4,267 $435 $3

Wholesale trade $270,881 $218,966 $489,847 $244,924 $606,548(D) $25,140 (D) 

Retail trade $544,495 $439,566 $984,061 $492,031 $931,399 $188,203 $75,541 $1,19

Motor vehicle and parts dealers $107,536 $98,237 $205,773 $102,887 $220,666 $45,857 $13,554 $28Furniture and home furnishings stores $22,359 $16,796 $39,155 $19,578 $39,529 $5,434 $473 $4Electronics and appliance stores $14,136 $12,466 $26,602 $13,301 $39,015 $3,163 $1,650 $4Building material and garden supply stores $53,247 $40,912 $94,159 $47,080 $79,492 $17,978 $4,838 $10Food and beverage stores $115,370 $111,105 $226,475 $113,238 $182,807 $41,684 $37,061 $26Health and personal care stores $39,606 $33,203 $72,809 $36,405 $77,182 $10,419 (D) (D) Gasoline stations $15,775 $10,631 $26,406 $13,203 $35,827 $11,105 $1,206 $4Clothing and clothing accessories stores $40,785 $21,914 $62,699 $31,350 $42,664 $4,622 $883 $4Sporting goods, hobby, book and music stores $15,608 $27,209 $42,817 $21,409 $20,344 $4,667 $572 $2General merchandise stores $63,920 $31,261 $95,181 $47,591 $129,186 $32,930 (D) (D) Miscellaneous store retailers $44,010 $28,849 $72,859 $36,430 $48,229 $6,595 $911 $5Nonstore retailers $12,143 $6,983 $19,126 $9,563 $16,458 $3,749 (D) (D) 

Transportation and warehousing $119,814 (D) (D) (D) $330,801 $70,500 (D) (D) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­1

Compensation of Employees by Industry, 2001 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Air transportation $5,025 $177 $5,202 $2,601 (D) (D) $0 (D) 

Rail transportation $1,853 $3,275 $5,128 $2,564 $31,298 $3,073 $0 $3

Water transportation (D) $0 (D) (D) $0 $0 $0 Truck transportation $57,452 $25,688 $83,140 $41,570 $154,451 $30,681 $5,429 $19Transit and ground passenger 

transportation $6,003 $3,287 $9,290 $4,645 $11,375 (D) (D) (D) Pipeline transportation $0 $0 $0 $0 (D) (D) $0 Scenic and sightseeing transportation $1,133 $283 $1,416 $708 (D) $0 $0 (D) Support activities for transportation $12,802 $4,397 $17,199 $8,600 $26,345 $2,258 $2,344 $3Couriers and messengers (D) (D) (D) (D) $42,791 (D) $0 (D) 

Warehousing and storage $20,567 $7,287 $27,854 $13,927 $35,719 $24,382 (D) (D) 

Information $172,414 $207,108 $379,522 $189,761 $248,937 $15,972 $4,581 $26

Publishing industries, except Internet $89,772 $136,119 $225,891 $112,946 $43,087 $5,243 (D) (D) Motion picture and sound recording industries $8,428 $4,551 $12,979 $6,490 $5,646(D) (D) (D) Broadcasting, except Internet3 $15,180 $3,467 $18,647 $9,324 $72,900 $1,893 (D) (D) Internet publishing and broadcasting (D) (D) (D) (D) (D) (D) $0 (D) 

Telecommunications $54,453 $40,117 $94,570 $47,285 $119,355 $7,174 $1,537 $12

ISPs, search portals, and data processing $3,123 $20,817 $23,940 $11,970 $6,518 $1,275 (D) (D) Other information services3 (D) (D) (D) (D) (D) (D) $0 (D) 

Finance and insurance $295,300 $125,910 $421,210 $210,605 $524,024 $46,173 $11,484 $58

Monetary authorities ­ central bank $0 $0 $0 $0 (D) $0 $0 (D) Credit intermediation and related activities $192,229 $63,708 $255,937 $127,969 $193,337 $20,969 $7,227 $22Securities, commodity contracts, investments $43,217 $19,245 $62,462 $31,231 $78,363 (D) $137 $7Insurance carriers and related activities $56,482 $41,203 $97,685 $48,843 $249,545 $21,574 $4,120 $27Funds, trusts, and other financial 

vehicles $3,372 $1,754 $5,126 $2,563 (D) (D) $0 (D) 

Real estate and rental and leasing $80,590 $75,103 $155,693 $77,847 $131,979 $14,089 $3,146 $14

Real estate $57,632 $39,670 $97,302 $48,651 $91,696 $10,789 $2,253 $10

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­1

Compensation of Employees by Industry, 2001 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Rental and leasing services (D) (D) (D) (D) (D) $3,300 $893 (D) Lessors of nonfinancial intangible assets (D) (D) (D) (D) (D) $0 $0 (D) 

Professional, scientific, and technical services $274,117 $426,342 $700,459 $350,230 $376,785 $38,018 $15,174 $42Management of companies and enterprises $204,343 $218,041 $422,384 $211,192 $201,879 $61,508 $2,785 $26

Administrative and waste services $186,140 $133,149 $319,289 $159,645 $305,094 $30,883 $5,787 $34

Administrative and support 

services $175,126 $126,034 $301,160 $150,580 $276,046 $29,957 (D) (D) 

Waste management and 

remediation services $11,014 $7,115 $18,129 $9,065 $29,048 $926 (D) (D) 

Educational services $68,927 $36,222 $105,149 $52,575 $63,597 $1,108 $1,835 $6Health care and social assistance $471,329 $382,689 $854,018 $427,009 $1,270,889 $186,761 $18,351 $1,47

Ambulatory health care services $253,681 $165,253 $418,934 $209,467 $606,451 $82,657 $12,341 $70

Hospitals (D) $114,903 (D) (D) $429,374 $63,185 $0 $49Nursing and residential care facilities $50,877 $51,977 $102,854 $51,427 $159,893 $26,454 $2,890 $18Social assistance (D) $50,556 (D) (D) $75,171 $14,465 $3,120 $9

Arts, entertainment, and recreation $69,498 $39,646 $109,144 $54,572 $62,328 $7,351 $7,564 $7

Performing arts and spectator sports $10,519 $3,522 $14,041 $7,021 $12,780 $212 (D) (D) Museums, historical sites, zoos, and parks $18,485 $931 $19,416 $9,708 $2,041 $272 $0 $

Amusement, gambling, and 

recreation $40,494 $35,193 $75,687 $37,844 $47,507 $6,867 (D) (D) 

Accommodation and food services $438,369 $188,047 $626,416 $313,208 $334,899 $57,456 $19,606 $41

Accommodation $237,871 $41,048 $278,919 $139,460 $40,073 $5,919 (D) (D) 

Food services and drinking places $200,498 $146,999 $347,497 $173,749 $294,826 $51,537 (D) (D) 

Other services, except public administration $198,039 $149,483 $347,522 $173,761 $420,543 $77,336 $18,383 $51

Repair and maintenance $47,008 $35,871 $82,879 $41,440 $104,544 $23,373 $4,160 $13Personal and laundry services $31,778 $27,216 $58,994 $29,497 $70,321 $5,550 $2,474 $7Membership associations and organizations $90,549 $65,355 $155,904 $77,952 $213,366 $41,099 $9,055 $26Private households $28,704 $21,041 $49,745 $24,873 $32,312 $7,314 $2,694 $4

Government and government enterprises $1,910,725 $860,153 $2,770,878 $1,385,439 $2,967,400 $574,967 $138,199 $3,68

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­1

Compensation of Employees by Industry, 2001 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Federal, civilian $361,065 $38,738 $399,803 $199,902 $578,800 $40,450 $8,383 $62Military $306,576 $7,453 $314,029 $157,015 $26,683 $6,447 $1,595 $3State and local $1,243,084 $813,962 $2,057,046 $1,028,523 $2,361,917 $528,070 $128,221 $3,01

State government $189,211 $242,541 $431,752 $215,876 $389,356 $11,883 $7,214 $40Local government $1,053,873 $571,421 $1,625,294 $812,647 $1,972,561 $516,187 $121,007 $2,60

1Total average compensation per job is compensation of employees received divided by total full­time and part­time wage and salary employment. 2The estimates of compensation for 2001­2006 are based on the 2002 North American Industry Classification System (NAICS). The estimates for 20

NAICS. 

3Under the 2007 NAICS, internet publishing and broadcasting was reclassified to other information services. 

(D) Not shown to avoid disclosure of confidential information, but the estimates for this item are included in the total. Source: BEA 2009a 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­2

Compensation of Employees by Industry, 2007 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Total average compensation per job 

(dollars)1 $51,513 $51,507 $103,020 $51,510 $45,414 $41,992 $45,789 $13Compensation of employees, received2 $9,335,105 $5,346,260 $14,681,365 $7,340,683 $16,570,402 $3,101,520 $789,133 $20,46

Farm compensation $455,539 $170,750 $626,289 $313,145 $412,598 $185,604 $25,156 $62Nonfarm compensation $8,879,566 $5,175,510 $14,055,076 $7,027,538 $16,157,804 $2,915,916 $763,977 $19,83

Private compensation $6,048,482 $3,985,766 $10,034,248 $5,017,124 $11,914,709 $1,992,398 $577,131 $14,48

Forestry, fishing, and related activities $890,365 (D) (D) (D) $732,395 $108,987 (D) (D) 

Forestry and logging (D) $671 (D) (D) (D) (D) $0 (D) Fishing, hunting, and trapping (D) (D) (D) (D) (D) $0 $0 (D) 

Agriculture and forestry support 

activities $885,871 $7,941 $893,812 $446,906 $725,821(D) (D) (D) 

Mining $23,565 (D) (D) (D) $13,161 $0 (D) (D) 

Oil and gas extraction (D) $0 (D) (D) (D) $0 $0 (D) Mining (except oil and gas) (D) (D) (D) (D) $0 $0 (D) (D) Support activities for mining (D) $0 (D) (D) (D) $0 $0 (D) 

Utilities $56,418 (D) (D) (D) $205,625(D) (D) (D) Construction $416,362 $315,517 $731,879 $365,940 $1,148,510 $141,567 $86,539 $1,37

Construction of buildings $136,474 $76,978 $213,452 $106,726 $280,135 $42,096 $17,424 $33Heavy and civil engineering construction $51,784 $61,434 $113,218 $56,609 $194,172 $13,390 $5,336 $21Specialty trade contractors $228,104 $177,105 $405,209 $202,605 $674,203 $86,081 $63,779 $82

Manufacturing $350,700 $464,385 $815,085 $407,543 $1,420,375 $488,545 $166,703 $2,07

Durable goods manufacturing $102,392 $344,980 $447,372 $223,686 $609,425 $107,186 $84,839 $80

Wood product manufacturing $12,267 $9,644 $21,911 $10,956 $41,126 $3,379 $10,227 $5

Nonmetallic mineral product manufacturing $22,131 $21,016 $43,147 $21,574 $43,355 $13,101 $13,356 $6Primary metal manufacturing $1,725 (D) (D) (D) $8,978 $0 (D) (D) Fabricated metal product manufacturing $9,021 $34,648 $43,669 $21,835 $123,580 $33,931 $22,636 $18Machinery manufacturing $16,411 $46,406 $62,817 $31,409 $124,192 $5,943 $7,264 $13Computer and electronic product manufacturing $30,271 $186,476 $216,747 $108,374 (D) (D) $8,227 (D) Electrical equipment and appliance manufacturing (D) $2,600 (D) (D) $10,548 (D) (D) (D) Motor vehicles, bodies and trailers, and parts manufacturing (D) (D) (D) (D) (D) (D) (D) (D) Other transportation equipment (D) (D) (D) (D) (D) (D) $0 (D) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­2

Compensation of Employees by Industry, 2007 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

manufacturing Furniture and related product manufacturing $3,433 $8,657 $12,090 $6,045 $20,694 $3,771 (D) (D) Miscellaneous manufacturing $4,317 $14,618 $18,935 $9,468 $59,363 $3,275 $2,689 $6

Nondurable goods manufacturing $248,308 $119,405 $367,713 $183,857 $810,950 $381,359 $81,864 $1,27

Food manufacturing $151,502 $54,875 $206,377 $103,189 $550,680 $284,145 (D) $83Beverage and tobacco product manufacturing $41,704 $9,070 $50,774 $25,387 $78,988 (D) $6,947 $8

Textile mills $0 (D) (D) (D) (D) (D) $0 (D) Textile product mills $618 $2,983 $3,601 $1,801 $5,948(D) $0 $Apparel manufacturing (D) $2,067 (D) (D) $6,005(D) $0 $

Leather and allied product manufacturing (D) $682 (D) (D) (D) $0 $0 (D) Paper manufacturing $25,918 (D) (D) (D) $45,009 (D) (D) (D) Printing and related support activities $7,732 $8,669 $16,401 $8,201 $30,681 (D) $1,444 (D) Petroleum and coal products manufacturing (D) $0 (D) (D) $23,388 (D) $0 (D) Chemical manufacturing $7,115 $33,410 $40,525 $20,263 $44,026 (D) (D) (D) Plastics and rubber products manufacturing $602 $6,411 $7,013 $3,507 $16,454 $735 (D) (D) 

Wholesale trade $395,668 $330,570 $726,238 $363,119 $845,245 $91,375 $28,981 $96

Retail trade $648,996 $500,435 $1,149,431 $574,716 $1,230,490 $244,623 $77,942 $1,55

Motor vehicle and parts dealers $116,676 $96,398 $213,074 $106,537 $274,665 $45,651 $10,935 $33Furniture and home furnishings stores $21,127 $14,582 $35,709 $17,855 $57,108 $7,516 (D) (D) Electronics and appliance stores $16,840 $20,513 $37,353 $18,677 $53,077 $5,284 $994 $5Building material and garden supply stores $59,418 $55,596 $115,014 $57,507 $116,866 $32,385 $4,044 $15Food and beverage stores $119,051 $148,519 $267,570 $133,785 $201,735 $52,408 $41,845 $29Health and personal care stores $53,855 $39,982 $93,837 $46,919 $115,351 $16,172 $5,874 $13Gasoline stations $19,378 $7,319 $26,697 $13,349 $38,292 $18,155 (D) (D) Clothing and clothing accessories stores $52,875 $24,074 $76,949 $38,475 $64,137 $7,588 $578 $7Sporting goods, hobby, book and music stores $15,721 $17,826 $33,547 $16,774 $29,161 $4,161 $699 $3General merchandise stores $84,687 $42,346 $127,033 $63,517 $191,505 $45,063 $6,405 $24Miscellaneous store retailers $49,638 $28,532 $78,170 $39,085 $65,561 $6,709 $1,278 $7

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­2

Compensation of Employees by Industry, 2007 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Nonstore retailers $39,730 $4,748 $44,478 $22,239 $23,032 $3,531 (D) (D) 

Transportation and warehousing $179,089 (D) (D) (D) $474,423(D) (D) (D) 

Air transportation $20,053 (D) (D) (D) $38,739 (D) $0 (D) 

Rail transportation $1,213 $2,446 $3,659 $1,830 (D) $3,284 $0 $

Water transportation (D) $0 (D) (D) (D) $0 $0 (D) Truck transportation $83,069 $15,949 $99,018 $49,509 $193,852 $50,363 $8,182 $25Transit and ground passenger 

transportation $7,706 $2,287 $9,993 $4,997 $16,474 $8,426 (D) (D) Pipeline transportation $0 $0 $0 $0 $1,745 $0 $0 $Scenic and sightseeing transportation $924 $632 $1,556 $778 (D) (D) (D) (D) Support activities for transportation $16,060 $5,238 $21,298 $10,649 $55,213 $3,210 $920 $5Couriers and messengers (D) (D) (D) (D) (D) (D) (D) (D) 

Warehousing and storage $32,432 $16,793 $49,225 $24,613 $65,955 (D) $0 $6

Information $173,269 $78,687 $251,956 $125,978 $310,859 $58,746 $4,678 $37

Publishing industries, except Internet $108,582 $34,835 $143,417 $71,709 $53,192 (D) (D) (D) Motion picture and sound recording industries $9,414 $6,457 $15,871 $7,936 $5,719 $1,287 (D) (D) Broadcasting, except Internet3 $25,077 $9,952 $35,029 $17,515 $114,067 $5,355 (D) (D) Internet publishing and broadcasting (N) (N) (N) (N) (N) (N) (N) (N) 

Telecommunications $28,399 $25,134 $53,533 $26,767 $129,990(D) $2,884 (D) 

ISPs, search portals, and data processing $0 $1,811 $1,811 $906 $5,852(D) $0 (D) Other information services3 $1,797 $498 $2,295 $1,148 $2,039(D) $0 (D) 

Finance and insurance $368,123 $166,850 $534,973 $267,487 $735,745 $70,596 $20,277 $82

Monetary authorities ­ central bank $0 (D) (D) (D) $0 $0 $0 Credit intermediation and related activities $240,187 $77,662 $317,849 $158,925 $295,718 $37,621 $11,537 $34Securities, commodity contracts, investments $71,258 $27,613 $98,871 $49,436 $75,949 (D) $418 $7Insurance carriers and related activities $43,963 $53,990 $97,953 $48,977 $361,178 $27,658 $8,322 $39Funds, trusts, and other financial 

vehicles $12,715 (D) (D) (D) $2,900(D) $0 $

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­2

Compensation of Employees by Industry, 2007 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Real estate and rental and leasing $101,232 $55,838 $157,070 $78,535 $174,205 $27,525 $4,555 $20

Real estate $61,770 $48,178 $109,948 $54,974 $126,922 $20,070 $3,909 $15Rental and leasing services $39,462 $7,660 $47,122 $23,561 (D) $7,455 $646 (D) Lessors of nonfinancial intangible assets $0 $0 $0 $0 (D) $0 $0 (D) 

Professional, scientific, and technical services $402,763 $342,321 $745,084 $372,542 $657,029 $66,571 $9,172 $73Management of companies and enterprises $143,266 $320,290 $463,556 $231,778 $212,729 $43,801 $2,657 $25

Administrative and waste services $189,478 $199,487 $388,965 $194,483 $555,493 $50,021 $17,711 $62

Administrative and support 

services $162,579 $193,422 $356,001 $178,001 $506,875 $48,605 $14,397 $56

Waste management and 

remediation services $26,899 $6,065 $32,964 $16,482 $48,618 $1,416 $3,314 $5

Educational services $91,826 $55,355 $147,181 $73,591 $116,299 $1,787 $2,572 $12Health care and social assistance $684,351 $618,989 $1,303,340 $651,670 $1,986,086 $272,654 $28,291 $2,28

Ambulatory health care services $369,436 $284,543 $653,979 $326,990 $845,214 $122,271 $24,039 $99

Hospitals (D) $206,793 (D) (D) $791,537 $93,141 $0 $88Nursing and residential care facilities $61,201 $64,852 $126,053 $63,027 $206,800 $39,756 (D) (D) Social assistance (D) $62,801 (D) (D) $142,535 $17,486 (D) (D) 

Arts, entertainment, and recreation $96,661 $52,537 $149,198 $74,599 $76,068 $10,784 $6,813 $9

Performing arts and spectator sports $21,153 $9,283 $30,436 $15,218 $15,523 $873 (D) (D) Museums, historical sites, zoos, and parks $23,853 $1,634 $25,487 $12,744 $5,544 $370 $0 $

Amusement, gambling, and 

recreation $51,655 $41,620 $93,275 $46,638 $55,001 $9,541 (D) (D) 

Accommodation and food services $568,123 $212,511 $780,634 $390,317 $478,273 $74,553 $23,714 $57

Accommodation $303,833 $38,447 $342,280 $171,140 $51,726 $4,706 (D) $5

Food services and drinking places $264,290 $174,064 $438,354 $219,177 $426,547 $69,847 (D) $49

Other services, except public administration $268,227 $182,610 $450,837 $225,419 $541,699 $100,480 $24,010 $66

Repair and maintenance $52,225 $43,352 $95,577 $47,789 $135,029 $33,378 $6,086 $17Personal and laundry services $43,118 $28,250 $71,368 $35,684 (D) (D) (D) (D) Membership associations and organizations $132,900 $81,810 $214,710 $107,355 $268,630 $51,527 $11,145 $33Private households $39,984 $29,198 $69,182 $34,591 (D) (D) (D) (D) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­2

Compensation of Employees by Industry, 2007 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Government and government enterprises $2,831,084 $1,189,744 $4,020,828 $2,010,414 $4,243,095 $923,518 $186,846 $5,35

Federal, civilian $577,447 $50,092 $627,539 $313,770 $718,056 $65,278 $12,551 $79Military $542,291 $15,065 $557,356 $278,678 $68,513 $14,681 $3,252 $8State and local $1,711,346 $1,124,587 $2,835,933 $1,417,967 $3,456,526 $843,559 $171,043 $4,47

State government $273,301 $359,918 $633,219 $316,610 $653,596 $83,187 $996 $73Local government $1,438,045 $764,669 $2,202,714 $1,101,357 $2,802,930 $760,372 $170,047 $3,73

1Total average compensation per job is compensation of employees received divided by total full­time and part­time wage and salary employment. 2The estimates of compensation for 2001­2006 are based on the 2002 North American Industry Classification System (NAICS). The estimates for 20

NAICS. 

3Under the 2007 NAICS, internet publishing and broadcasting was reclassified to other information services. 

(D) Not shown to avoid disclosure of confidential information, but the estimates for this item are included in the total. Source: BEA 2009a 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­3

Compensation of Employees by Industry, 2008 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Total average compensation per job 

(dollars)1 $53,306 $52,101 $105,407 $52,704 $47,023 $44,580 $48,310 $13Compensation of employees, received2 $9,666,386 $5,283,270 $14,949,656 $7,474,828 $17,035,040 $3,214,059 $775,420 $21,02

Farm compensation $509,820 $197,631 $707,451 $353,726 $462,398 $209,612 $26,853 $69Nonfarm compensation $9,156,566 $5,085,639 $14,242,205 $7,121,103 $16,572,642 $3,004,447 $748,567 $20,32

Private compensation $6,176,013 $3,837,627 $10,013,640 $5,006,820 $12,119,870 $2,006,531 $553,587 $14,67

Forestry, fishing, and related activities $912,824 (D) (D) (D) $754,688 $110,228 (D) (D) 

Forestry and logging (N) (N) (N) (N) (N) (N) (N) (N) Fishing, hunting, and trapping (N) (N) (N) (N) (N) (N) (N) (N) 

Agriculture and forestry support 

activities (N) (N) (N) (N) (N) (N) (N) (N) 

Mining $27,709 (D) (N) (N) $15,987 $0 (D) (D) 

Oil and gas extraction (N) (N) (N) (N) (N) (N) (N) (N) Mining (except oil and gas) (N) (N) (N) (N) (N) (N) (N) (N) Support activities for mining (N) (N) (N) (N) (N) (N) (N) (N) 

Utilities $62,827 $22,259 $85,086 $42,543 $239,522(D) (D) (D) Construction $383,326 $274,058 $657,384 $328,692 $1,059,969 $111,501 $70,465 $1,24

Construction of buildings (N) (N) (N) (N) (N) (N) (N) (N) Heavy and civil engineering construction (N) (N) (N) (N) (N) (N) (N) (N) Specialty trade contractors (N) (N) (N) (N) (N) (N) (N) (N) 

Manufacturing $338,301 $449,323 $787,624 $393,812 $1,400,314 $504,372 $163,992 $2,06

Durable goods manufacturing $95,992 $332,552 $428,544 $214,272 (D) $99,942 $79,473 (D) 

Wood product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) 

Nonmetallic mineral product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Primary metal manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Fabricated metal product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Machinery manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Computer and electronic product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Electrical equipment and appliance manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Motor vehicles, bodies and trailers, and parts manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Other transportation equipment (N) (N) (N) (N) (N) (N) (N) (N) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­3

Compensation of Employees by Industry, 2008 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

manufacturing Furniture and related product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Miscellaneous manufacturing (N) (N) (N) (N) (N) (N) (N) (N) 

Nondurable goods manufacturing $242,309 $116,771 $359,080 $179,540 (D) $404,430 $84,519 $48

Food manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Beverage and tobacco product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) 

Textile mills (N) (N) (N) (N) (N) (N) (N) (N) Textile product mills (N) (N) (N) (N) (N) (N) (N) (N) Apparel manufacturing (N) (N) (N) (N) (N) (N) (N) (N) 

Leather and allied product manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Paper manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Printing and related support activities (N) (N) (N) (N) (N) (N) (N) (N) Petroleum and coal products manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Chemical manufacturing (N) (N) (N) (N) (N) (N) (N) (N) Plastics and rubber products manufacturing (N) (N) (N) (N) (N) (N) (N) (N) 

Wholesale trade $433,047 $272,604 $705,651 $352,826 $831,445(D) $28,358 (D) 

Retail trade $641,185 $490,034 $1,131,219 $565,610 $1,218,688 $238,949 $83,708 $1,54

Motor vehicle and parts dealers (N) (N) (N) (N) (N) (N) (N) (N) Furniture and home furnishings stores (N) (N) (N) (N) (N) (N) (N) (N) Electronics and appliance stores (N) (N) (N) (N) (N) (N) (N) (N) Building material and garden supply stores (N) (N) (N) (N) (N) (N) (N) (N) Food and beverage stores (N) (N) (N) (N) (N) (N) (N) (N) Health and personal care stores (N) (N) (N) (N) (N) (N) (N) (N) Gasoline stations (N) (N) (N) (N) (N) (N) (N) (N) Clothing and clothing accessories stores (N) (N) (N) (N) (N) (N) (N) (N) Sporting goods, hobby, book and music stores (N) (N) (N) (N) (N) (N) (N) (N) General merchandise stores (N) (N) (N) (N) (N) (N) (N) (N) Miscellaneous store retailers (N) (N) (N) (N) (N) (N) (N) (N) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­3

Compensation of Employees by Industry, 2008 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Nonstore retailers (N) (N) (N) (N) (N) (N) (N) (N) 

Transportation and warehousing $194,844 $60,497 $255,341 $127,671 $498,784(D) (D) (D) 

Air transportation (N) (N) (N) (N) (N) (N) (N) (N) 

Rail transportation (N) (N) (N) (N) (N) (N) (N) (N) 

Water transportation (N) (N) (N) (N) (N) (N) (N) (N) Truck transportation (N) (N) (N) (N) (N) (N) (N) (N) Transit and ground passenger 

transportation (N) (N) (N) (N) (N) (N) (N) (N) Pipeline transportation (N) (N) (N) (N) (N) (N) (N) (N) Scenic and sightseeing transportation (N) (N) (N) (N) (N) (N) (N) (N) Support activities for transportation (N) (N) (N) (N) (N) (N) (N) (N) Couriers and messengers (N) (N) (N) (N) (N) (N) (N) (N) 

Warehousing and storage (N) (N) (N) (N) (N) (N) (N) (N) 

Information $164,109 $74,598 $238,707 $119,354 $357,566 $58,828 $3,672 $42

Publishing industries, except Internet (N) (N) (N) (N) (N) (N) (N) (N) Motion picture and sound recording industries (N) (N) (N) (N) (N) (N) (N) (N) Broadcasting, except Internet3 (N) (N) (N) (N) (N) (N) (N) (N) Internet publishing and broadcasting (N) (N) (N) (N) (N) (N) (N) (N) 

Telecommunications (N) (N) (N) (N) (N) (N) (N) (N) 

ISPs, search portals, and data processing (N) (N) (N) (N) (N) (N) (N) (N) Other information services3 (N) (N) (N) (N) (N) (N) (N) (N) 

Finance and insurance $372,217 $153,229 $525,446 $262,723 $721,201 $64,823 $19,549 $80

Monetary authorities ­ central bank (N) (N) (N) (N) (N) (N) (N) (N) Credit intermediation and related activities (N) (N) (N) (N) (N) (N) (N) (N) Securities, commodity contracts, investments (N) (N) (N) (N) (N) (N) (N) (N) Insurance carriers and related activities (N) (N) (N) (N) (N) (N) (N) (N) Funds, trusts, and other financial 

vehicles (N) (N) (N) (N) (N) (N) (N) (N) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­3

Compensation of Employees by Industry, 2008 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Real estate and rental and leasing $87,045 $55,240 $142,285 $71,143 $178,803 $25,037 $4,787 $20

Real estate (N) (N) (N) (N) (N) (N) (N) (N) Rental and leasing services (N) (N) (N) (N) (N) (N) (N) (N) Lessors of nonfinancial intangible assets (N) (N) (N) (N) (N) (N) (N) (N) 

Professional, scientific, and technical services $424,595 $350,963 $775,558 $387,779 $688,256 $64,266 (D) (D) Management of companies and enterprises $151,988 $280,520 $432,508 $216,254 $205,268 $52,573 (D) (D) 

Administrative and waste services $197,629 $215,637 $413,266 $206,633 $569,517 $46,768 $13,385 $62

Administrative and support 

services (N) (N) (N) (N) (N) (N) (N) (N) 

Waste management and 

remediation services (N) (N) (N) (N) (N) (N) (N) (N) 

Educational services $97,507 $61,704 $159,211 $79,606 $131,444 $1,225 $2,683 $13Health care and social assistance $720,994 $604,297 $1,325,291 $662,646 $2,138,408 $289,271 $29,440 $2,45

Ambulatory health care services (N) (N) (N) (N) (N) (N) (N) (N) 

Hospitals (N) (N) (N) (N) (N) (N) (N) (N) Nursing and residential care facilities (N) (N) (N) (N) (N) (N) (N) (N) Social assistance (N) (N) (N) (N) (N) (N) (N) (N) 

Arts, entertainment, and recreation $100,485 $51,824 $152,309 $76,155 $78,628 $10,343 $6,875 $9

Performing arts and spectator sports (N) (N) (N) (N) (N) (N) (N) (N) Museums, historical sites, zoos, and parks (N) (N) (N) (N) (N) (N) (N) (N) 

Amusement, gambling, and 

recreation (N) (N) (N) (N) (N) (N) (N) (N) 

Accommodation and food services $581,117 $214,961 $796,078 $398,039 $480,957 $78,515 $23,862 $58

Accommodation (N) (N) (N) (N) (N) (N) (N) (N) 

Food services and drinking places (N) (N) (N) (N) (N) (N) (N) (N) 

Other services, except public administration $284,264 $193,414 $477,678 $238,839 $550,425 $103,933 $24,127 $67

Repair and maintenance (N) (N) (N) (N) (N) (N) (N) (N) Personal and laundry services (N) (N) (N) (N) (N) (N) (N) (N) Membership associations and organizations (N) (N) (N) (N) (N) (N) (N) (N) Private households (N) (N) (N) (N) (N) (N) (N) (N) 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­3

Compensation of Employees by Industry, 2008 (Thousands of Dollars)

Industry

Monterey

County

Santa Cruz

County

Central Coast

Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo R

Tota

Government and government enterprises $2,980,553 $1,248,012 $4,228,565 $2,114,283 $4,452,772 $997,916 $194,980 $5,64

Federal, civilian $599,252 $52,170 $651,422 $325,711 $761,119 $71,587 $12,566 $84Military $546,069 $17,349 $563,418 $281,709 $96,854 $16,856 $3,730 $11State and local $1,835,232 $1,178,493 $3,013,725 $1,506,863 $3,594,799 $909,473 $178,684 $4,68

State government $298,202 $385,065 $683,267 $341,634 $695,795 $101,688 (D) (D) Local government $1,537,030 $793,428 $2,330,458 $1,165,229 $2,899,004 $807,785 (D) (D) 

1Total average compensation per job is compensation of employees received, divided by total full­time and part­time wage and salary employment. 2The estimates of compensation for 2001­2006 are based on the 2002 North American Industry Classification System (NAICS). The estimates for 20

NAICS. 

3Under the 2007 NAICS, Internet Publishing and Broadcasting was reclassified as Other Information Services. 

(D) Not shown to avoid disclosure of confidential information, but the estimates for this item are included in the total. (N) Data not available for this year. Source: BEA 2009a 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­4

Compensation of Employees by Industry, Percent Change 2001 to 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Total average compensation per job (dollars)1 30.3 23.0 26.6 31.3 32.7 26.

Compensation of employees, received2 30.9 16.2 25.2 42.5 46.5 33.8 

Farm compensation ­2.9 ­10.6 ­5.2 1.9 3.4 ­24.4 Nonfarm compensation 33.3 17.4 27.0 43.9 50.5 37.3 

Private compensation 27.3 12.3 20.9 44.3 46.2 38.0 

Forestry, fishing, and related activities 87.7 NA NA 36.6 113.0 NA 

Forestry and logging NA NA NA NA NA NA Fishing, hunting, and trapping NA NA NA NA NA NA 

Agriculture and forestry support activities 88.0 ­57.1 82.5 35.7 NA NA 

Mining 27.7 NA NA ­15.1 ­100.0 NA 

Oil and gas extraction NA NA NA NA NA NA Mining (except oil and gas) NA NA NA NA NA NA Support activities for mining NA NA NA NA NA NA 

Utilities 14.0 NA NA 88.7 NA NA Construction 23.9 22.3 23.2 66.2 87.0 61.5 

Construction of buildings 28.6 8.3 20.5 63.3 125.8 101.Heavy and civil engineering construction 0.8 14.8 8.0 145.2 102.9 14.8 Specialty trade contractors 27.7 32.9 29.9 53.1 70.6 58.4 

Manufacturing ­26.5 ­16.3 ­21.0 29.6 36.8 46.3 

Durable goods manufacturing ­30.4 ­15.9 ­19.7 22.3 48.6 6.2 

Wood product manufacturing 128.1 ­17.7 28.2 9.1 ­55.5 17.5 

Nonmetallic mineral product manufacturing 52.9 ­37.0 ­9.8 11.0 NA NA Primary metal manufacturing 45.1 NA NA ­46.2 NA NA Fabricated metal product manufacturing ­45.1 183.0 52.4 9.9 91.9 ­24.8 Machinery manufacturing ­16.8 158.1 66.6 1.0 ­36.5 79.7 Computer and electronic product manufacturing ­57.2 ­35.5 ­39.8 NA NA ­31.6Electrical equipment and appliance manufacturing NA 18.8 NA NA NA NA Motor vehicles, bodies and trailers, and parts manufacturing NA NA NA NA NA NA Other transportation equipment manufacturing NA NA NA NA NA NA Furniture and related product manufacturing ­19.5 29.5 10.4 ­15.7 64.9 NA Miscellaneous manufacturing ­25.7 3.9 ­4.7 ­4.1 41.0 NA 

Nondurable goods manufacturing ­24.7 ­17.3 ­22.5 35.6 33.8 140.4 

Food manufacturing ­35.6 ­27.5 ­33.6 35.1 51.4 NA Beverage and tobacco product 9.1 20.3 11.0 29.4 NA 77.4 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­4

Compensation of Employees by Industry, Percent Change 2001 to 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

manufacturing 

Textile mills NA NA NA NA NA NA Textile product mills 25.4 18.7 19.8 86.4 NA NA Apparel manufacturing NA ­22.5 NA NA NA NA 

Leather and allied product manufacturing NA NA NA NA NA NA Paper manufacturing 15.3 NA NA 38.1 NA NA Printing and related support activities ­17.6 ­26.9 ­22.8 0.4 NA NA Petroleum and coal products manufacturing NA NA NA 116.8 NA NA Chemical manufacturing ­42.9 20.6 0.9 223.6 NA NA Plastics and rubber products manufacturing ­29.5 ­31.7 ­31.5 ­35.1 ­82.8 NA 

Wholesale trade 46.1 51.0 48.3 39.4 NA 15.3

Retail trade 19.2 13.8 16.8 32.1 30.0 3.2 

Motor vehicle and parts dealers 8.5 ­1.9 3.5 24.5 ­0.4 ­19.3 Furniture and home furnishings stores ­5.5 ­13.2 ­8.8 44.5 38.3 NA Electronics and appliance stores 19.1 64.6 40.4 36.0 67.1 ­39.8 Building material and garden supply stores 11.6 35.9 22.1 47.0 80.1 ­16.4 Food and beverage stores 3.2 33.7 18.1 10.4 25.7 12.9 Health and personal care stores 36.0 20.4 28.9 49.5 55.2 NA Gasoline stations 22.8 ­31.2 1.1 6.9 63.5 NA Clothing and clothing accessories stores 29.6 9.9 22.7 50.3 64.2 ­34.5 Sporting goods, hobby, book and music stores 0.7 ­34.5 ­21.7 43.3 ­10.8 22.2 General merchandise stores 32.5 35.5 33.5 48.2 36.8 NA Miscellaneous store retailers 12.8 ­1.1 7.3 35.9 1.7 40.3 Nonstore retailers 227.2 ­32.0 132.6 39.9 ­5.8 NA 

Transportation and warehousing 49.5 NA NA 43.4 NA NA 

Air transportation 299.1 NA NA NA NA NA 

Rail transportation ­34.5 ­25.3 ­28.6 NA 6.9 NA 

Water transportation NA NA NA NA NA NA Truck transportation 44.6 ­37.9 19.1 25.5 64.2 50.7 Transit and ground passenger transportation 28.4 ­30.4 7.6 44.8 NA NA 

Pipeline transportation NA NA NA NA NA NA Scenic and sightseeing transportation ­18.4 123.3 9.9 NA NA NA Support activities for transportation 25.4 19.1 23.8 109.6 42.2 ­60.8 Couriers and messengers NA NA NA #VALUE! NA NA 

Warehousing and storage 57.7 130.5 76.7 84.6 NA NA 

Information 0.5 ­62.0 ­33.6 24.9 267.8 2.

Publishing industries, except Internet 21.0 ­74.4 ­36.5 23.5 NA NA Motion picture and sound recording industries 11.7 41.9 22.3 1.3 NA NA 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­4

Compensation of Employees by Industry, Percent Change 2001 to 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Broadcasting, except Internet3 65.2 187.0 87.9 56.5 182.9 NA Internet publishing and broadcasting NA NA NA NA NA NA 

Telecommunications ­47.8 ­37.3 ­43.4 8.9 NA 87.6

ISPs, search portals, and data processing ­100.0 ­91.3 ­92.4 ­10.2 NA NA Other information services3 NA NA NA NA NA NA 

Finance and insurance 24.7 32.5 27.0 40.4 52.9 76.6 

Monetary authorities ­ central bank NA NA NA NA NA NA Credit intermediation and related activities 24.9 21.9 24.2 53.0 79.4 59.6 Securities, commodity contracts, investments 64.9 43.5 58.3 ­3.1 NA 205.Insurance carriers and related activities ­22.2 31.0 0.3 44.7 28.2 102.0 Funds, trusts, and other financial vehicles 277.1 NA NA NA NA NA 

Real estate and rental and leasing 25.6 ­25.7 0.9 32.0 95.4 44.8 

Real estate 7.2 21.4 13.0 38.4 86.0 73.5 Rental and leasing services NA NA NA NA 125.9 ­27.7Lessors of nonfinancial intangible assets NA NA NA NA NA NA 

Professional, scientific, and technical services 46.9 ­19.7 6.4 74.4 75.1 ­39.6 Management of companies and enterprises ­29.9 46.9 9.7 5.4 ­28.8 ­4.6 

Administrative and waste services 1.8 49.8 21.8 82.1 62.0 206.0 

Administrative and support services ­7.2 53.5 18.2 83.6 62.2 NA Waste management and remediation services 144.2 ­14.8 81.8 67.4 52.9 NA 

Educational services 33.2 52.8 40.0 82.9 61.3 40.2 Health care and social assistance 45.2 61.7 52.6 56.3 46.0 54.2 

Ambulatory health care services 45.6 72.2 56.1 39.4 47.9 94.8 

Hospitals NA 80.0 NA 84.3 47.4 NA Nursing and residential care facilities 20.3 24.8 22.6 29.3 50.3 NA Social assistance NA 24.2 NA 89.6 20.9 NA 

Arts, entertainment, and recreation 39.1 32.5 36.7 22.0 46.7 ­9.9 

Performing arts and spectator sports 101.1 163.6 116.8 21.5 311.8 NA Museums, historical sites, zoos, and parks 29.0 75.5 31.3 171.6 36.0 NA 

Amusement, gambling, and recreation 27.6 18.3 23.2 15.8 38.9 NA 

Accommodation and food services 29.6 13.0 24.6 42.8 29.8 21.0 

Accommodation 27.7 ­6.3 22.7 29.1 ­20.5 NA 

Food services and drinking places 31.8 18.4 26.1 44.7 35.5 NA 

Other services, except public administration 35.4 22.2 29.7 28.8 29.9 30.6 

Repair and maintenance 11.1 20.9 15.3 29.2 42.8 46.3 Personal and laundry services 35.7 3.8 21.0 NA NA NA Membership associations and organizations 46.8 25.2 37.7 25.9 25.4 23.Private households 39.3 38.8 39.1 NA NA NA 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­4

Compensation of Employees by Industry, Percent Change 2001 to 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Government and government enterprises 48.2 38.3 45.1 43.0 60.6 35.2 

Federal, civilian 59.9 29.3 57.0 24.1 61.4 49.7 Military 76.9 102.1 77.5 156.8 127.7 103.9 State and local 37.7 38.2 37.9 46.3 59.7 33.4 

State government 44.4 48.4 46.7 67.9 600.1 ­86.2 Local government 36.5 33.8 35.5 42.1 47.3 40.5 

1Total average compensation per job is compensation of employees received, divided by total full­time and part­time wage and salary employment. 2The estimates of compensation for 2001­2006 are based on the 2002 North American Industry Classification System (NAICS). The estimates for 20

NAICS. 

3Under the 2007 NAICS, Internet Publishing and Broadcasting was reclassified as Other Information Services. 

NA: Not available, either in order to avoid disclosure of confidential information or because data was not available for one of the years presented. Source: BEA 2009a 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­5

Compensation of Employees by Industry, Percent Change 2007 to 2008

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Total average compensation per job (dollars)1 3.5 1.2 2.3 3.5 6.2 5.5 

Compensation of employees, received2 3.5 ­1.2 1.8 2.8 3.6 ­1.7 

Farm compensation 11.9 15.7 13.0 12.1 12.9 6.7 Nonfarm compensation 3.1 ­1.7 1.3 2.6 3.0 ­2.0 

Private compensation 2.1 ­3.7 ­0.2 1.7 0.7 ­4.1 

Forestry, fishing, and related activities 2.5 NA NA 3.0 1.1 NA 

Forestry and logging NA NA NA NA NA NA Fishing, hunting, and trapping NA NA NA NA NA NA 

Agriculture and forestry support activities NA NA NA NA NA NA 

Mining 17.6 NA NA 21.5NA NA 

Oil and gas extraction NA NA NA NA NA NA Mining (except oil and gas) NA NA NA NA NA NA Support activities for mining NA NA NA NA NA NA 

Utilities 11.4 NA NA 16.5NA NA Construction ­7.9 ­13.1 ­10.2 ­7.7 ­21.2 ­18.6 

Construction of buildings NA NA NA NA NA NA Heavy and civil engineering construction NA NA NA NA NA NA Specialty trade contractors NA NA NA NA NA NA 

Manufacturing ­3.5 ­3.2 ­3.4 ­1.4 3.2 ­1.6 

Durable goods manufacturing ­6.3 ­3.6 ­4.2 NA ­6.8 ­6.3 

Wood product manufacturing NA NA NA NA NA NA 

Nonmetallic mineral product manufacturing NA NA NA NA NA NA Primary metal manufacturing NA NA NA NA NA NA Fabricated metal product manufacturing NA NA NA NA NA NA Machinery manufacturing NA NA NA NA NA NA Computer and electronic product manufacturing NA NA NA NA NA NA Electrical equipment and appliance manufacturing NA NA NA NA NA NA Motor vehicles, bodies and trailers, and parts manufacturing NA NA NA NA NA NA Other transportation equipment manufacturing NA NA NA NA NA NA Furniture and related product manufacturing NA NA NA NA NA NA Miscellaneous manufacturing NA NA NA NA NA NA 

Nondurable goods manufacturing ­2.4 ­2.2 ­2.3 NA 6.0 3.2 

Food manufacturing NA NA NA NA NA NA Beverage and tobacco product manufacturing NA NA NA NA NA NA 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­5

Compensation of Employees by Industry, Percent Change 2007 to 2008

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Textile mills NA NA NA NA NA NA Textile product mills NA NA NA NA NA NA Apparel manufacturing NA NA NA NA NA NA 

Leather and allied product manufacturing NA NA NA NA NA NA Paper manufacturing NA NA NA NA NA NA Printing and related support activities NA NA NA NA NA NA Petroleum and coal products manufacturing NA NA NA NA NA NA Chemical manufacturing NA NA NA NA NA NA Plastics and rubber products manufacturing NA NA NA NA NA NA 

Wholesale trade 9.4 ­17.5 ­2.8 ­1.6NA ­2.1 

Retail trade ­1.2 ­2.1 ­1.6 ­1.0 ­2.3 7.4 

Motor vehicle and parts dealers NA NA NA NA NA NA Furniture and home furnishings stores NA NA NA NA NA NA Electronics and appliance stores NA NA NA NA NA NA Building material and garden supply stores NA NA NA NA NA NA Food and beverage stores NA NA NA NA NA NA Health and personal care stores NA NA NA NA NA NA Gasoline stations NA NA NA NA NA NA Clothing and clothing accessories stores NA NA NA NA NA NA Sporting goods, hobby, book and music stores NA NA NA NA NA NA General merchandise stores NA NA NA NA NA NA Miscellaneous store retailers NA NA NA NA NA NA Nonstore retailers NA NA NA NA NA NA 

Transportation and warehousing 8.8 NA NA 5.1NA NA 

Air transportation NA NA NA NA NA NA 

Rail transportation NA NA NA NA NA NA 

Water transportation NA NA NA NA NA NA Truck transportation NA NA NA NA NA NA Transit and ground passenger transportation NA NA NA NA NA NA 

Pipeline transportation NA NA NA NA NA NA Scenic and sightseeing transportation NA NA NA NA NA NA Support activities for transportation NA NA NA NA NA NA Couriers and messengers NA NA NA NA NA NA 

Warehousing and storage NA NA NA NA NA NA 

Information ­5.3 ­5.2 ­5.3 15.0 0.1 ­21.5 

Publishing industries, except Internet NA NA NA NA NA NA Motion picture and sound recording industries NA NA NA NA NA NA Broadcasting, except Internet3 NA NA NA NA NA NA 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­5

Compensation of Employees by Industry, Percent Change 2007 to 2008

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Internet publishing and broadcasting NA NA NA NA NA NA 

Telecommunications NA NA NA NA NA NA 

ISPs, search portals, and data processing NA NA NA NA NA NA Other information services3 NA NA NA NA NA NA 

Finance and insurance 1.1 ­8.2 ­1.8 ­2.0 ­8.2 ­3.6 

Monetary authorities ­ central bank NA NA NA NA NA NA Credit intermediation and related activities NA NA NA NA NA NA Securities, commodity contracts, investments NA NA NA NA NA NA Insurance carriers and related activities NA NA NA NA NA NA Funds, trusts, and other financial vehicles NA NA NA NA NA NA 

Real estate and rental and leasing ­14.0 ­1.1 ­9.4 2.6 ­9.0 5.1 

Real estate NA NA NA NA NA NA Rental and leasing services NA NA NA NA NA NA Lessors of nonfinancial intangible assets NA NA NA NA NA NA 

Professional, scientific, and technical services 5.4 2.5 4.1 4.8 ­3.5 NA Management of companies and enterprises 6.1 ­12.4 ­6.7 ­3.5 20.0 NA 

Administrative and waste services 4.3 8.1 6.2 2.5 ­6.5 ­24.4 

Administrative and support services NA NA NA NA NA NA Waste management and remediation services NA NA NA NA NA NA 

Educational services 6.2 11.5 8.2 13.0 ­31.4 4.3 Health care and social assistance 5.4 ­2.4 1.7 7.7 6.1 4.1 

Ambulatory health care services NA NA NA NA NA NA 

Hospitals NA NA NA NA NA NA Nursing and residential care facilities NA NA NA NA NA NA Social assistance NA NA NA NA NA NA 

Arts, entertainment, and recreation 4.0 ­1.4 2.1 3.4 ­4.1 0.9 

Performing arts and spectator sports NA NA NA NA NA NA Museums, historical sites, zoos, and parks NA NA NA NA NA NA 

Amusement, gambling, and recreation NA NA NA NA NA NA 

Accommodation and food services 2.3 1.2 2.0 0.6 5.3 0.6 

Accommodation NA NA NA NA NA NA 

Food services and drinking places NA NA NA NA NA NA 

Other services, except public administration 6.0 5.9 6.0 1.6 3.4 0.5 

Repair and maintenance NA NA NA NA NA NA Personal and laundry services NA NA NA NA NA NA Membership associations and organizations NA NA NA NA NA NA Private households NA NA NA NA NA NA 

Government and government enterprises 5.3 4.9 5.2 4.9 8.1 4.4 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­5

Compensation of Employees by Industry, Percent Change 2007 to 2008

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Federal, civilian 3.8 4.1 3.8 6.0 9.7 0.1 Military 0.7 15.2 1.1 41.4 14.8 14.7 State and local 7.2 4.8 6.3 4.0 7.8 4.5 

State government 9.1 7.0 7.9 6.5 22.2 NA Local government 6.9 3.8 5.8 3.4 6.2 NA 

1 Total average compensation per job is compensation of employees received divided by total full­time and part­time wage and salary employment. 2 The estimates of compensation for 2001­2006 are based on the 2002 North American Industry Classification System (NAICS). The estimates for 20

NAICS. 

3 Under the 2007 NAICS, internet publishing and broadcasting was reclassified to other information services. 

NA Not available either in order to avoid disclosure of confidential information or because data was not available for one of the years presented. Source: BEA 2009a 

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­6

Employment by Industry, 2001 (Number of Jobs)

Industry

MontereyCounty

Santa CruzCounty

CentralCoast Total

Central Coast

Average

FresnoCounty

MercedCounty

San BenitoCounty

DiabloRange To

Total employment 227,249 148,125 375,374 187,687 413,647 85,114 22,262 521

Farm employment 17,300 7,959 25,259 12,630 26,560 10,717 1,941 39Nonfarm employment 209,949 140,166 350,115 175,058 387,087 74,397 20,321 481

Private employment 174,675 121,224 295,899 147,950 322,553 60,277 17,486 400

Forestry, fishing, and related activities 26,050 1,565 27,615 13,808 38,713 4,914 (D) (D) Mining 407 137 544 272 518 56 (D) (D) Utilities 695 (D) (D) (D) 1,455(D) (D) (D) Construction 10,255 8,674 18,929 9,465 21,076 3,551 1,843 26Manufacturing 10,501 10,361 20,862 10,431 29,395 10,471 2,694 42

Wholesale trade 5,484 4,381 9,865 4,933 14,144(D) 660 (D) 

Retail trade 22,233 17,689 39,922 19,961 42,681 9,330 2,947 54

Transportation and warehousing 3,893 (D) (D) (D) 10,866 2,694 (D) (D) 

Information 3,499 3,271 6,770 3,385 6,033 566 165 6Finance and insurance 6,952 3,875 10,827 5,414 15,669 1,660 546 17Real estate and rental and leasing 7,754 7,076 14,830 7,415 12,293 2,219 870 15Professional, scientific, and technical services 11,126 12,454 23,580 11,790 15,303 2,014 871 18Management of companies and enterprises 4,037 2,219 6,256 3,128 3,903 988 109 5

Administrative and waste 

services 9,090 6,840 15,930 7,965 16,961 2,554 658 20Educational services 2,948 2,446 5,394 2,697 3,739 230 174 4Health care and social assistance 13,783 13,157 26,940 13,470 36,746 6,670 1,036 44

Arts, entertainment, and 

recreation 4,565 4,630 9,195 4,598 5,125 887 537 6

Accommodation and food 

services 19,916 4,630 24,546 12,273 24,859 4,736 1,278 30Other services, except public administration 11,487 8,749 20,236 10,118 23,074 4,684 1,205 28

Government and government enterprises 35,274 18,942 54,216 27,108 64,534 14,120 2,835 81

Federal, civilian 4,687 562 5,249 2,625 9,633 625 141 10Military 5,493 472 5,965 2,983 1,554 404 101 2State and local 25,094 17,908 43,002 21,501 53,347 13,091 2,593 69

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­6

Employment by Industry, 2001 (Number of Jobs)

Industry

MontereyCounty

Santa CruzCounty

CentralCoast Total

Central Coast

Average

FresnoCounty

MercedCounty

San BenitoCounty

DiabloRange To

State government 4,418 5,824 10,242 5,121 7,476 328 222 8Local government 20,676 12,084 32,760 16,380 45,871 12,763 2,371 61

(D) Not shown to avoid disclosure of confidential information, but the estimates for this item are included in the total. Source: BEA 2009b June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­7

Employment by Industry, 2007 (Number of Jobs)

Industry

Monterey

County

Santa Cruz

County

Central

Coast Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo

Range To

Total employment 233,846 147,903 381,749 190,875 457,157 94,691 24,408 576

Farm employment 14,678 6,804 21,482 10,741 22,496 8,969 1,358 32Nonfarm employment 219,168 141,099 360,267 180,134 434,661 85,722 23,050 543

Private employment 182,685 121,854 304,539 152,270 366,039 69,975 20,264 456

Forestry, fishing, and related activities 32,250 (D) (D) (D) 34,686 5,345 (D) (D) Mining 426 (D) (D) (D) 338 25 (D) (D) Utilities 579 (D) (D) (D) 1,972(D) (D) (D) Construction 10,868 9,851 20,719 10,360 27,664 5,072 2,389 35Manufacturing 6,854 7,509 14,363 7,182 29,665 9,841 3,111 42

Wholesale trade 6,014 5,605 11,619 5,810 16,002 2,421 565 18

Retail trade 22,424 16,943 39,367 19,684 47,183 10,370 2,479 60

Transportation and warehousing 4,175 (D) (D) (D) 13,102(D) (D) (D) 

Information 2,676 1,955 4,631 2,316 5,112 1,498 158 6Finance and insurance 6,430 4,166 10,596 5,298 17,608 2,293 674 20Real estate and rental and leasing 11,805 9,791 21,596 10,798 20,055 3,405 1,618 25Professional, scientific, and technical services 11,534 11,401 22,935 11,468 19,906 2,966 784 23Management of companies and enterprises 1,626 1,877 3,503 1,752 3,211 589 92 3

Administrative and waste 

services 8,717 7,370 16,087 8,044 22,496 3,566 968 27Educational services 3,397 3,321 6,718 3,359 5,417 377 219 6Health care and social assistance 15,041 14,555 29,596 14,798 43,745 7,529 1,052 52

Arts, entertainment, and 

recreation 4,741 4,909 9,650 4,825 5,568 1,117 495 7

Accommodation and food 

services 20,921 10,923 31,844 15,922 27,666 4,963 1,396 34Other services, except public administration 12,207 8,756 20,963 10,482 24,643 5,120 1,296 31

Government and government enterprises 36,483 19,245 55,728 27,864 68,622 15,747 2,786 87

Federal, civilian 4,973 540 5,513 2,757 9,602 761 155 10Military 5,979 396 6,375 3,188 1,572 386 86 2State and local 25,531 18,309 43,840 21,920 57,448 14,600 2,545 74

June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­7

Employment by Industry, 2007 (Number of Jobs)

Industry

Monterey

County

Santa Cruz

County

Central

Coast Total

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Diablo

Range To

State government 4,383 6,213 10,596 5,298 9,585 516 16 10Local government 21,148 12,096 33,244 16,622 47,863 14,084 2,529 64

(D) Not shown to avoid disclosure of confidential information, but the estimates for this item are included in the total. Source: BEA 2009b June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­8

Employment by Industry, Percentage Change 2001 to 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Total employment 2.9 ­0.1 1.7 10.5 11.3 9.6 

Farm employment ­15.2 ­14.5 ­15.0 ­15.3 ­16.3 ­30.0 Nonfarm employment 4.4 0.7 2.9 12.3 15.2 13.4 

Private employment 4.6 0.5 2.9 13.5 16.1 15.9 

Forestry, fishing, and related activities 23.8 NA NA ­10.4 8.8 NA NMining 4.7 NA NA ­34.7 ­55.4 NA NUtilities ­16.7 NA NA 35.5 NA NA NConstruction 6.0 13.6 9.5 31.3 42.8 29.6 Manufacturing ­34.7 ­27.5 ­31.2 0.9 ­6.0 15.5 

Wholesale trade 9.7 27.9 17.8 13.1 NA ­14.4 N

Retail trade 0.9 ­4.2 ­1.4 10.5 11.1 ­15.9 

Transportation and warehousing 7.2 NA NA 20.6 NA NA N

Information ­23.5 ­40.2 ­31.6 ­15.3 164.7 ­4.2 Finance and insurance ­7.5 7.5 ­2.1 12.4 38.1 23.4 Real estate and rental and leasing 52.2 38.4 45.6 63.1 53.4 86.0 Professional, scientific, and technical services 3.7 ­8.5 ­2.7 30.1 47.3 ­10.0 Management of companies and enterprises ­59.7 ­15.4 ­44.0 ­17.7 ­40.4 ­15.6 

Administrative and waste services ­4.1 7.7 1.0 32.6 39.6 47.1 

Educational services 15.2 35.8 24.5 44.9 63.9 25.9 Health care and social assistance 9.1 10.6 9.9 19.0 12.9 1.5 

Arts, entertainment, and recreation 3.9 6.0 4.9 8.6 25.9 ­7.8 Accommodation and food services 5.0 135.9 29.7 11.3 4.8 9.2 

Other services, except public administration 6.3 0.1 3.6 6.8 9.3 7.6 

Government and government enterprises 3.4 1.6 2.8 6.3 11.5 ­1.7 

Federal, civilian 6.1 ­3.9 5.0 ­0.3 21.8 9.9 Military 8.8 ­16.1 6.9 1.2 ­4.5 ­14.9 State and local 1.7 2.2 1.9 7.7 11.5 ­1.9 

State government ­0.8 6.7 3.5 28.2 57.3 ­92.8 Local government 2.3 0.1 1.5 4.3 10.4 6.7 

NA: Not available, either to avoid disclosure of confidential information or because data was not available for one of the years presented. Source: BEA 2009b June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­9

Compensation per Employee by Industry, 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

Compensation of employees $39,920 $36,147 $38,033 $36,247 $32,754 $32,331 

Farm compensation $31,035 $25,096 $28,066 $18,341 $20,694 $18,524 Nonfarm compensation $40,515 $36,680 $38,597 $37,173 $34,016 $33,144 

Private compensation $33,109 $32,709 $32,909 $32,550 $28,473 $28,481 

Forestry, fishing, and related activities $27,608 NA NA $21,115 $20,390 NA NA Mining $55,317 NA NA $38,938 $0 NA NA Utilities $97,440 NA NA $104,272 NA NA NA Construction $38,311 $32,029 $35,170 $41,516 $27,911 $36,224 Manufacturing $51,167 $61,844 $56,505 $47,880 $49,644 $53,585 

Wholesale trade $65,791 $58,978 $62,384 $52,821 $37,743 $51,294 

Retail trade $28,942 $29,536 $29,239 $26,079 $23,589 $31,441 

Transportation and warehousing $42,896 NA NA $36,210 NA NA NA 

Information $64,749 $40,249 $52,499 $60,810 $39,216 $29,608 Finance and insurance $57,251 $40,050 $48,651 $41,785 $30,788 $30,085 Real estate and rental and leasing $8,575 $5,703 $7,139 $8,686 $8,084 $2,815 Professional, scientific, and technical services $34,920 $30,026 $32,473 $33,007 $22,445 $11,699 Management of companies and enterprises $88,109 $170,639 $129,374 $66,250 $74,365 $28,880 

Administrative and waste services $21,737 $27,067 $24,402 $24,693 $14,027 $18,296 

Educational services $27,031 $16,668 $21,850 $21,469 $4,740 $11,744 Health care and social assistance $45,499 $42,528 $44,013 $45,401 $36,214 $26,893 

Arts, entertainment, and recreation $20,388 $10,702 $15,545 $13,662 $9,654 $13,764 Accommodation and food services $27,156 $19,455 $23,306 $17,287 $15,022 $16,987 

Other services, except public administration $21,973 $20,855 $21,414 $21,982 $19,625 $18,526 

Government and government enterprises $77,600 $61,821 $69,711 $61,833 $58,647 $67,066 

Federal, civilian $116,116 $92,763 $104,440 $74,782 $85,779 $80,974 Military $90,699 $38,043 $64,371 $43,583 $38,034 $37,814 State and local $67,030 $61,423 $64,226 $60,168 $57,778 $67,207 

State government $62,355 $57,930 $60,142 $68,189 $161,215 $62,250 Local government $67,999 $63,217 $65,608 $58,562 $53,988 $67,239 

NA: Not available, either to avoid disclosure of confidential information or because data was not available for one of the years presented. Source: BEA 2009a, 2009b June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­10

Percentage of Total Compensation by Socioeconomic Workshop Industry, 2007

Industry

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

D

Mining 0.3(D) (D) 0.1 0.0 (D) (D) Retail trade 7.0 9.4 7.8 7.4 7.9 9.9 

Motor vehicle and parts dealers (percent of Retail Trade) 18.0 19.3 18.5 22.3 18.7 14.0 Food and beverage stores (percent of Retail Trade) 18.3 29.7 23.3 16.4 21.4 53.7 Gasoline stations (percent of Retail Trade) 3.0 1.5 2.3 3.1 7.4 (D) (D) 

Accommodation and food

services 6.1 4.0 5.3 2.9 2.4 3.0 

Accommodation (percent of Accommodation and Food Services) 53.5 18.1 43.8 10.8 6.3 (D) 

Food services and drinking places (percent of Accommodation and Food Services) 46.5 81.9 56.2 89.2 93.7 (D) 

(D) Not shown to avoid disclosure of confidential information. Source: BEA 2009a June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
Table C­11

Housing Median Value

Year

Estimate

United

States California

Monterey

County

Santa Cruz

County

Central Coast

Average

Fresno

County

Merced

County

San Benito

County

D

2005­2007 $181,800 $513,200 $662,300 $718,700 $690,500 $284,800 $333,300 $669,000 $422006­2008 $192,400 $510,200 $638,600 $708,700 $673,650 $286,800 $310,500 $650,900 $41Source: US Census Bureau 2010a, 2010b June 2010 CCMA RMP/EIS – Socioeconomic Workshop Report 
 

 

ATTACHMENT 3 -- CA Department of Parks and Recreation –

Science Review Correspondence and Contributions to BLM's 

EIS Process and Alternative Development 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Attachment #3 - CA Department of Parks and Recreation - Science Review Correspondence and 

Contributions to BLM's EIS Process and Alternative Development 

During this planning process, BLM has sought participation by the public as well as local and 

state agencies. As a result, the Off-Highway Motor Vehicle Recreation (OHMVR) Division of 

California State Parks and others have participated actively in the process throughout this multiyear effort. Many public comments on the Draft RMP/EIS called for independent studies to be 

completed prior to making a final decision regarding off-highway vehicle use on CCMA public 

lands. The OHMVR Division requested that BLM wait until an independent asbestos exposure 

study in the CCMA could be prepared before issuing the CCMA Proposed RMP and Final 

EIS. The BLM agreed to the Division’s request, and on March 22, 2011 they released the report, 

titled “Preliminary Analysis of the Asbestos Exposures Associated with Motorcycle Riding and 

Hiking in the Clear Creek Management Area (CCMA) San Benito County, California.” The 

report was completed by scientists from the International Environmental Research Foundation 

(IERF), and is linked on the OHMVR Division’s website: 

http://ohv.parks.ca.gov/pages/1140/files/ierf_ccma_final_3_8_11-web.pdf. 

After the study was published, BLM, CA DPR, and other agencies worked together to evaluate 

the information provided in the study prepared by IERF and the EPA risk assessment to identify 

areas of agreement and determine a strategy to develop adaptive management criteria for BLM to 

incorporate new information into travel management plans for the CCMA to allow additional 

vehicle use in the Serpentine ACEC. 

Upon release of the IERF study, BLM was asked to address their findings in a series of 

interagency discussions and public meetings, including several San Benito County Board of 

Supervisors meetings, and a California Off-Highway Vehicle Commission meeting located in 

Hollister, CA and scheduled on April 5, 2011 in a well-attended public forum to focus on the 

asbestos exposure studies and discuss health risk information with agency officials and IERF 

scientists. Subsequently, BLM received a letter from the Director of California Department of 

Parks and Recreation that addresses the integrity of the EPA risk assessment. A copy of the letter 

is included in Attachment 3 on the following pages. 

Another interagency meeting with scientists from BLM, EPA, DTSC, and IERF and EPA was 

held on May 29, 2012 to identify any remaining agency concerns and opportunities for additional 

research to be incorporated into travel management plans for the CCMA to allow additional 

vehicle use in the Serpentine ACEC. In Attachment 3 (Volume II, Appendix X) a letter from the 

OHMVR Division dated November 19, 2012 outlines the areas of agreement and opportunities 

for further study. 

As described in Attachment 3, BLM and other agency officials agreed that the EPA risk 

assessment and the IERF report both highlighted the need for further research to determine 

effective strategies to reduce risk to CCMA visitors. Therefore, the preferred alternative located 

in section 2.5.3 of the PRMP/FEIS identifies the following “adaptive management criteria” that 

would allow the BLM management flexibility to modify OHV use restrictions and/or limits on 

roads and trails available for motorized use in the ACEC, should significant new information 

become available. 
 

 

 

 

 

 

 

o Activity based studies that establish effective strategies for 

reduction in personal exposure to asbestos from off-highway 

vehicle recreation. 

o Research results in a significant reduction in the toxicity values 

for asbestos resulting in a reduced excess lifetime cancer risk. 

o Chrysotile asbestos is removed from the list of Toxic and 

Hazardous regulated substances. 

Should any of these criteria be met, BLM would reassess health risks associated with exposure to 

asbestos in the ACEC and determine the need for adaptive management that may modify 

recreation use limitations included under the preferred alternative in this proposed RMP. At a 

minimum, the BLM will re-examine the body of peer-reviewed data available on this subject 

within three years following issuance of a record of decision for the CCMA RMP. 
of'Callfomia • Natural Resources Edmund G. Governor 

DEPARTMENT OF PARKS AND RECREATION • P.O. Box 942896 • Sacramento, CA 94296-001 

(916) 653-8380 

Ruth Coleman, Director 

August 30, 2011 '·· 

The Honorable Doc Hastings The Honorable Ed Markey 

Chair Ranking Member 

United States House of Representatives United States House of Representatives 

Committee on Natural Resources Committee on Natural Resources 

1203 Longworth House Office Building 2108 Rayburn House Office Building 

Washington, DC 20515 Washington, DC 20515 

The Honorable Rob Bishop The Honorable Raul Grijalva 

Chair Ranking Member 

United States House of Representatives United States House of Representatives 

Subcommittee on National Parks, Subcommittee on National Parks, 

Forests, and Public Lands Forests, and Public Lands 

123 Cannon House Office Building 1523 Longworth House Office Building 

Washington, DC 20515 Washington, DC 20515 

Dear Chair Hastings, Ranking Member Markey, Chair Bishop, and Ranking Member Grijalva, 

I am writing to comment on a letter sent by the Off Highway Vehicle Commission on 

July 21, 2011. The commission articulated their concerns about restrictions to off highway vehicle 

recreation opportunities at the Clear Creek Management area imposed by the Bureau of Land 

Management. In particular they expressed many concerns with the findings of a recent 

Environmental Protection Agency (EPA) study on the potential harm that might come from 

exposure to naturally occurring asbestos in the serpentine soils of the area. This Commission is 

charged to promote safe and responsible off highway vehicle opportunities. They take this 

mission seriously and that includes seeking to minimize restrictions on historic recreation. 

While I do not wish to take issue with any of the specifics of their claims, I want to take this 

opportunity to clarify that the Commission is an independent body comprised of gubernatorial 

appointees (5), as well as appointees from the Senate (2), and Assembly (2). As such, the views 

of the Commission are theirs alone and do not necessarily reflect the views of the Administration. 

In particular, the Administration does nQt share the view articulated in the letter that "the approach 

taken by the EPA is not consistent with President Obama's Memorandum on Scientific Integrity". 

The Administration believes that the EPA report does reflect appropriate scientific methods and 

scientific integrity. 
The Honorable Doc Hastings, et al 

August 30,.2011 

Page Two 

We do not expect parties to agree on conclusions or methodologies, and it is entirely appropriate 

for the public to engage in reasonable debate. We do not, however, believe that any party 

operated without scientific integrity. 

Thank you for your consideration in this matter. 

~~~~ Ruth Coleman 

cc: 	 Subcommittee on National Parks, Forests and public Lands 

Sam Farr, US House of Representatives California 

Devin Nunes, US House of Representatives, California 

Dianne Feinstein, US Senator, California 

Barbara Boxer, US Senator; California 

Ken Salazar, Secretary of the Interior 

Bob Abbey, Director, Bureau of Land Management 

Peter Ditton, Acting California State Director, BLM 

Rick Cooper, Field Manager, Hollister Field Office, BLM 

Lisa P. Jackson, Administrator, US EPA 

JereJean Johnson, Remedial Project Manager, US EPA Region 9 

Luis Alejo, California State Assembly, 281

h District 

David Valado, California State Assembly, 30th District 

Anthony Canella, California State Senate, 12th District 

Michael Rubio, California State Senate, 16th District 

Jared Blumenfeld, Regional Administrator, US EPA, Region 9 

John Laird, Secretary, California Natural Resources Agency 

Daphne Greene, Deputy Director, OHMVR Division 

Off-Highway Motor Vehicle Recreation Commissioners 
State of-California • The Natural Resources Agency Edmund G. Brown Jr., Governor 

DEPARTMENT OF PARKS AND RECREATION • P.O. Box 942896 • Sacramento, CA 94296-GOOl * Off-Highway Motor Vehicle Recreation Division Major General Anthony L. Jackson, 

USMC (Ret) , Director 

1725 23'd Street, Suite 200 

Sacramento, California, 95816 

(916) 324-4442 

November 19, 2012 

Rick Cooper, Hollister Field Manager 

Burea of Land Management 

20 Hamilton Court 

Hollister, CA 95023 

Subject: May 29, 2012 Meeting- BLM and OHMVR Clear Creek Management Area 

Thank you for your participation in the meeting of May 29, 2012, held at the Off-Highway 

Motor Vehicle Recreation Division office in Sacramento. The summary minutes from the 

meeting are attached. The discussion regarding the basic scientific issues underlying the 

Clear Creek Management Area (CCMA) studies were helpful and informative to all in 

attendance. The discussion notes identify areas of agreement and define some areas of 

concern among the group. 

As BLM proceeds with the completion of the CCMA Resource Management Plan (RMP) 

decision process, the Division asks that the BLM make provisions in the RMP to continually 

evaluate new scientifically sound information and adapt management options accordingly. 

Regards, 

... 


Philip B. Jenkins 

Acting Deputy Director 

Enclosure 

cc: James G. Kenna, BLM State Director 

Angie Lara, BLM Associate State Director 

Este Stifel, BLM Central California District Manager 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

Page 1 of 1

Summary – CCMA 

5/29/12 

A.	 Areas of Agreement 

1.	 Activity Based Methodology is an effective approach 

2.	 Location under discussion is the area within the ACEC Boundary 

3.	 Staging/Camping No Longer Occur - Agreed it is appropriate to disregard risk factors 

related to staging/camping within the ACEC in future risk calculations 

4.	 Capping does reduce risk, but would still need to be monitored and measured to 

determine exposure as time goes on 

5.	 Key Elements to evaluate risk: Duration, Frequency, and Concentration 

6.	 Lead Rider is exposed to much less risk 

B.	 Areas of Concern 

1.	 Trailing Rider Effect 

- Normal riding styles – are there possibilities to lower risk? 

o Require distance between riders? 

 Is trailing rider effect less pronounced on trails than it is on 

roads? 

 At what distance does trailing rider receive significantly less 

exposure? 

o	 Would using monitors in helmet provide significantly lower exposure 

levels than monitors placed on chest? 

2.	 “Wet Season Riding”

- No consistent rain patterns at CCMA 

- How much rain, and at what frequency, would there need to be to 

significantly reduce risk factors? No solid information in this regard has been 

collected. 

3.	 Clear Creek Road – Road vs. Trail riding 

- Riders avoid dust trail when riding on trails, but encounter higher levels of 

dust when riding on roads. Data in the existing studies does not provide the 

ability to support if riders on trails experience lower levels of exposure or not. 

o Capping road may be a solution 

 Exposure levels after capping would need to be evaluated. 

New risk calculation could possibly be made based on trail 

riding exposure levels and reduced exposure on roads. 

 The relative distances traveled on roads vs. traveled on 

trails and the resulting reduction in risk that might be 

expected from capping the roads needs to be evaluated. 

C.	 Opportunities for additional research 

	 Rider behavior to avoid dust & areas where most dust would be encountered – roads vs trails & 

the efficacy of capping roads. 

 Efficacy of 1-way roads & trails to limit dust. 

 Climate studies of the areas rainfall patterns. Soil studies on moisture content and generation of 

dust. 

 Further research to evaluate risk during moist conditions in the days and weeks following a rain 

event. 
!9

!9

!9

!9

!9

!9

Oak Flat CG

Jade Mill CG

Condon Peak CG

R1

R11B

R15

T153

R11A

R13

R10

T151

R14

T158

R15

Superfund

Atlas Operable Unit

Superfund

Coalinga Operable Unit

Coalinga Road

Los Gatos Road

New Idria Road

Clear Creek Road

Proposed Action

Legend

Area of Environmental Concern (Asbestos)

Hazardous Asbestos Area (HAA)

San Benito Mtn Research Natural Area

San Benito River Zone

Condon Zone

Cantua Zone

Tucker Mountain Zone

Other BLM Lands

County Roads

Highway Licensed and ATV's Only

Scenic Touring Route

!9 Campgrounds

Potential Public Route

Route Construction Proposal

Possible Disposal

CCMA boundary

Route Designation

Highway Licensed - Access By Permit Only

Non Motorized Access

Highway Licensed & ATV's Only

Highway Licensed & ATV's Only

Non Motorized Access

Other BLM Lands

Bureau of Land Management

State

US Department of the Interior

BUREAU OF LAND MANAGEMENT

Hollister Field Office

Hollister, CA 95023

(831)630-5000

www.ca.blm.gov/hollister

Date Prepared: 12/08/2011

M:\gis\master\basic\planning\CCMA\RMP\FEIS

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Miles

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