More grazing in SPRNCA? Still time to comment on draft RMP!

How to submit comments on draft SPRNCA Resource Management Plan 
Help us protect the river and celebrate the 30th Anniversary of the San Pedro Riparian National Conservation Area (SPRNCA).  Submit your substantive comments on the draft RMP to the Bureau of Land Management during the public comment period that ends September 27, 2018.  [In the row for SPRNCA DRMP Vol1, click on the Comment on Document button.]  Use the guide linked here to help you craft your comments.

In a nutshell, the draft RMP has four management alternatives:
Alternative A – a continuation of the existing management regime
  • Existing public access remains, restoration on a case-by-case basis, and livestock grazing continues on four current allotments
Alternative B – increased land use throughout
  • More public access, broadest range of methods for restoration, entire SPRNCA open to livestock grazing
Alternative C – the BLM’s preferred alternative
  • A mix of recreational opportunities, most of SPRNCA open to hunting, with only the uplands open to livestock grazing
Alternative D – light on the land
  • No areas open to livestock grazing, emphasis on resource protection and light restoration methods
Below you will find a number of issues of concern about the draft RMP.  Choose one or more that particularly resonate with you and write why YOU are concerned about them.  In your comments, you might:
  • Reflect on the success of the management strategies of the past three decades and describe how the new draft Resource Management Plan (RMP) that the Bureau of Land Management (BLM) recently published for comment misses the mark.
  • Insist that BLM not compromise the many species of birds and other wildlife like beaver who call the river home.
  • Share your concerns about BLM’s Preferred Alternative C in the new draft RMP for the SPRNCA.  It does not sufficiently emphasize the original intent and central purpose of the enabling legislation to conserve, protect and enhance the riparian forest along the river and its wildlife. It also does not sufficiently protect sensitive cultural heritage sites.  Strategies in Alternative D do.
  • Ask that the strategies and management decisions that have served the SPRNCA well for 3 decades largely be retained and not cast aside or altered significantly.
Express your concern that Alternative C would:
  • increase areas open to livestock grazing in the SPRNCA
  • increase areas open to the discharge of firearms for hunting in the SPRNCA
  • allow the widespread use of bulldozers and other heavy equipment that will alter the landscape and impact wildlife
  • increase roads open to motorized vehicular traffic
  • increase fencing that will interfere with wildlife corridors
  • continue to allow the cruel practice of trapping wildlife which will likely increase with more cattle grazing the SPRNCA
  • allow toxic herbicides and pesticides in the uplands to treat grazing allotments that will degrade water quality
  • leave cultural heritage sites like Charleston, Fairbank, Murray Springs Clovis Site and Presidio Santa Cruz de Terrenate unprotected from many consumptive uses
Ask how the BLM still can achieve natural resource objectives if the strategies in Preferred Alternative C are implemented.
Your comments might include further considerations (choose one or two bullets below):
  • Voice concern about safety risks from opening high visitation areas near San Pedro House and Fairbank Townsite to hunting with firearms or bows.  Suggest closing the Rural Recreation Management Zone (RMZ) to hunting.  Lawful hunting is likely safest in Primitive and Backcountry RMZs in the SPRNCA.  Mention your desire to avoid harming threatened and endangered wildlife.  You might also discuss that arms fire disturbs visitors and discourages multiple other uses.  Insist that safety prevail over all other considerations.
  • Mention that published science repeatedly demonstrates that livestock grazing in the arid desert Southwest has adverse impacts on natural landscapes.  Cite erosion, soil compaction, conversion of healthy grasslands to woody scrub, and reduction of food and cover for wildlife. Assert the benefits of removal of cattle from the SPRNCA to restore these lands.
  • Elaborate on how conversion of now undisturbed areas to grazing will open them to vehicular traffic, degrade wildlife habitat and water quality, and result in a return to the resource-depleted landscape that existed before the SPRNCA was protected in 1988.  Ask how BLM can manage these new grazing areas to avoid adverse effects to riparian areas if they do not receive the resources nor budget to do so effectively. Ask how BLM can assure the needed oversight despite these uncertainties.
  • Emphasize your support for the strategies in Alternative D, the one most consistent with the purpose of the enabling legislation.  Ask that BLM preserve the characteristics of the natural landscape identified in the inventories of Lands with Wilderness Characteristics and Wild and Scenic Rivers.  Recognize that fire management strategies that limit the risk of catastrophic fires are desirable, but the implementation must be measured and limited to preserve native mesquite bosques and the cottonwood/willow gallery forest.  Insist that BLM tread lightly on the landscape in managing the SPRNCA as it has the past 30 years.
  • Tell BLM that the SPRNCA shelters diverse wildlife and contains the largest remaining riparian corridor in Arizona.  Mention that it is vital to the survival of millions of migratory birds and other wildlife.  Describe the rich recreational and educational opportunities close to local communities.  Cite the SPRNCA as an asset to the local economy given the renewable source of revenue associated with eco-tourism.  Insist that these values be reflected in the management strategies in the preferred alternative.
  • Ask that BLM promote the protection of the cottonwood/willow gallery forest, mesquite bosques, and other sensitive habitats essential to wildlife.  Encourage BLM to put conservation first in management decisions.
  • Insist that BLM protect riparian and other sensitive areas by prohibiting cattle grazing in and near the river channel itself and tributaries.  Ask that BLM exclude washes from areas open to grazing, since fencing would prevent wildlife moving along these corridors to and from the river.  Request that BLM continue to prohibit off-road motor vehicle use away from designated roads, particularly in the river channel itself.  Suggest that BLM seek an inter-agency agreement with Border Patrol, since off-road and helicopter patrols disturb wildlife and damage the landscape.  Noise and high-intensity lighting within SPRNCA should be limited where possible.
Finally, stress that you are a local/volunteer/out-of-state visitor (as appropriate) who values the events and activities/volunteer opportunities offered in the SPRNCA.  Mention that you consider the SPRNCA a treasure, a diverse resource, etc.  Insist that the RMP reflect that.

Submitting Comments to BLM for SPRNCA RMP
A reminder that you can submit comments under the Documents & Reports page on the BLM ePlanning website.

Comments also can be submitted by any of the following methods:
Fax:     (520) 258-7231
Postal Mail:
Amy Markstein
Team Lead–SPRNCA RMP
BLM Tucson Field Office
3201 E. Universal Way
Tucson, AZ  85756

[NOTE: Before including your address, phone number, email address, or other personal identifying information in your comments, please be advised that your entire comment – including your personal identifying information – may be made publicly available at any time.  While you can ask BLM in your comment to withhold from public view your personally identifying information, BLM cannot guarantee that they will be able to do so.]
We appreciate your time and commitment to the river and the wildlife it supports!  If you have any questions, please ask.  Thanks for submitting comments to BLM!!