Dave Cooper
DRAFT Comments - Winnemucca Draft RMP
September 15, 2010

Recreation Management:

All four of the proposed SRMAs under Alternative D should be designated as such to help provide for a diversity of recreation opportunities and resulting experiences on the public lands. These areas will help diversify local economies through tourism as well as benefit local residents by providing recreation opportunities in close proximity to home.
The Nightingale SRMA as proposed will expand a diversity of recreation opportunities and resulting experiences and benefits that will complement those offered in the adjacent Black Rock NCA. Providing OHV opportunities in the SRMA will provide a much needed place for these activities outside the protected NCA. RMZ 1 including the Selenite and Mount Limbo Mountain WSAs should be managed to provide for the protection of wilderness characteristics and motorized travel should be limited to designated routes rather than existing routes. Management and enforcement of motorized use in these areas will be much easier with designated routes that are well marked. At the same time other routes that have been created by motorized vehicle use since the areas were designated as WSA's need to be closed and rehabilitated. The SRMA will also make it easier to manage competitive motorized events that are taking place in this area.

The Pine Forest SRMA should be expanded and managed as outlined in Alternative D. This is a very unique area within the Winnemucca District and northern Nevada and deserves special management and protection of resources. This important area should be withdrawn from mineral entry.
The Granite Range SRMA will provide for a diversity of recreation opportunities and compliment recreation opportunities provided in proximity to the Black Rock NCA and community of Gerlach. In order to properly manage recreation uses and provide opportunities, the Granite Range SRMA should be expanded to encompass more of the mountain range to provide well defined boundaries that are both manageable and identifiable on the ground and can be described. The SRMA boundaries should be expanded to the north to the Winnemucca District boundary, on the west to the existing north - south powerline right of way and/or private lands (or Highway 447) and on the south and east to County Road 34 and/or private land boundaries. Expanding the area will allow for better management of ingress and egress routes as well as management of areas used for different types of recreation pursuits. This will also enhance enforcement as well as allow the recreating public to more easily identify where the boundaries located. This will also expand the RMZs already identified that will provide for a diversity of recreation opportunities. The Granit Mountain SRMA should be withdrawn from mineral entry.

Proposed Areas With Wilderness Characteristics:

All 6 roadless areas identified in Appendix A, Figure 2-80, need to be managed to preserve their wilderness characteristics, provide for primitive unconfined recreation opportunities, and provide for solitude. These important areas are the last remaining roadless areas with wilderness characteristics left in the Winnemucca District. Managing these areas to protect wilderness character will help provide for a diversity of primitive recreation opportunities as well as protect important wildlife habitats and protect other natural and cultural resources in the Winnemucca District and northern Nevada region. Once these areas are lost to roads and development they are gone forever. If these areas are not protected the resulting loss of naturalness, recreation resources and fragmentation of wildlife habitats will result in a greatly reduced, or loss of, recreation opportunities and natural resources (wildlife, vegetation, soil, etc.) into the future.

Visual Resource Management Areas:

In addition to the VRM classes outlined in Alternative D the following changes should be made:
The viewshed in and around Gerlach, Empire, and the Highway 447 travel corridor are high value, very sensitive, and should be designated VRM Class II so that any development will blend in with the landscape instead of contrast to it. The viewshed including the foreground and middle ground in all the surrounding mountains: Selenite Range, Fox Range, Granite Range, Old Razor Back Mountain, Mount Limbo and the Nightingale Mountains, are extremely important and of high value to local residents as well as recreation users and visitors to this remote region.

The proposed utility corridor along the south boundary of the Black Rock NCA should be eliminated and should be designated VRM Class II to protect very important and high value viewsheds. This will insure the integrity of the Black Rock Desert NCA and WSAs in this area remains intact and avoids adverse impacts to this special area. The lack of development in this area is a key reason people come to visit and live in the Black Rock region. The sensations of remoteness and solitude on these vast undeveloped public lands contribute to the experiences people seek when they visit or live in this remote area of northwestern Nevada.

OHV Management:

Alternative D outlines the most logical OHV designations for the Winnemucca District with a few proposed changes as follows: Closed areas should include the Bluewing Mountains as proposed in Alternative C (Appendix A, Figure 2-9) for a total of 61,427 acres closed to OHV use. This will protect one of the last important roadless areas while the surrounding area will be managed for motorized recreation uses.
All of the WSA's in the District should be either closed to OHV use or limited to motorized use that is confined to designated routes as they existed when the areas were designated as WSA's. Routes must be designated to allow for ease of management and enforcement. It will be difficult to manage and enforce OHV use without specifically identifying and marking routes on the ground that can be used for motorized travel. This is also the time to close and rehabilitate vehicle routes that are causing resource damage, are redundant and go to the same locations, or are not necessary for access or transportation purposes. This will help eliminate damage to wildlife habitats or fragmentation of habitats, soil, water, and other natural and cultural resources.

Salable Minerals:

Salable minerals should be allowed as outlined in Alternative D with the following modifications: Areas in and immediately adjacent to Gerlach and Empire should be protected from impacts associated the extraction of salable minerals. The adjacent lands within at least 1 mile should be closed to new sales or require special stipulations to avoid impacts to the high value viewshed, health and safety of residents, as well as air and water quality.

Fluid Mineral Leasing:

Alternative C provides the most protection for sensitive and valuable natural and cultural resources in the Winnemucca District. The areas in and immediately adjacent to the communities of Gerlach and Empire should be closed to fluid mineral leasing in order to provide for the health and safety of residents, protect air and water quality and provide for an unspoiled high value viewshed.

Solid Mineral Leasing Areas:

Alternative D provides a reasonable availability of lands for solid mineral leasing. However, the areas in and immediately adjacent (within 1 mile) to the communities of Gerlach and Empire should be closed to new leasing to protect the health and safety of residents, provide for air and water quality, and protect the high value viewshed. In addition, areas within sight and sound of the Black Rock NCA and designated wilderness boundaries should be included in the area that is open with standard and special stipulations in order to help mitigate and protect the integrity of the NCA, national historic trails and wilderness resources. Sights and sounds from construction, road building, and mining activities in close proximity to theses sensitive special areas would disrupt the recreation experiences and solitude that is an integral part of the of the NCA and wilderness areas.

General Mining Law of 1872:
Alternative C provides a reasonable management approach to areas available for mining under the general mining law of 1872. Sensitive lands with sensitive resources should be closed to entry including the Pine Forest SRMA and Granite Mountain SRMA. In addition to the areas outlined in Alternative C, the lands in and immediately adjacent to the communities of Gerlach and Empire should be closed to entry. This will help provide for resident health and safety, protect quality of life in these communities, protect air and water quality as well as protect the surrounding high value viewshed. In addition, areas within sight and sound of the Black Rock NCA and designated wilderness boundaries should be open with special mitigation on operations in order to help protect the integrity of the NCA, wilderness resources, and national historic trails from the sights and sounds of development and mining activities as well as provide for protection of sensitive natural and cultural resources and very important, high value viewsheds. Any large developments in close proximity will have adverse impacts from sights and sounds of development and especially from long term or mining activates increased traffic, new road and utility developments, etc.

Proposed Utility Corridors:

Alternative C contains reasonable utility corridor routes through the District. Alternative D shows a route adjacent to the south boundary of the Black Rock NCA that should be eliminated. Any large scale utility development in this area, such as a major powerline, will cause long term adverse impacts to the integrity of the NCA, the historic Applegate Lassen Trail, and the Seleinte WSA. The adjacent mountains and viewshed are high value and extremely important to the integrity of the Black Rock NCA, wilderness, and national historic trails. Irretrievable impacts will occur to the California National Historic Trail if any large scale development disturbs the trail corridor. The integrity of the relatively undeveloped primitive nature of the trail corridor will be lost with construction of a major power line or pipeline in this location.

Lands and Reality:

Alternative D, figure 2-74 provides a reasonable plan for land tenure. Sensitive lands and resources should be retained in federal ownership. Environmentally sensitive private lands and resources should be purchased from willing sellers as the opportunity arises. Important private inholdings within WSAs, wilderness areas, ACECs, SRMAs and other special areas should be considered for acquisition to be managed the same as the adjacent public lands. This will protect important resources, enhance management of lands in these areas, provide for public access and enhance recreation opportunities.
An area of public lands adjacent to the south side of Gerlach should be identified for disposal. This small area of public lands should be given to the Gerlach General Improvement District, under the Recreation and Public Purposes Act, for the public purpose of continued use and expansion of the sewer holding ponds.

Right of Way Avoidance and Exclusion Areas:

Alternative D provides for protection of sensitive areas and, in addition, the public land areas immediately within and adjacent to Gerlach and Empire should have special stipulations that will provide for resident health and safety and protect the surrounding high value viewshed as well as protect soil, water, air and other natural and cultural resources.