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REPORT ON
MANAGEMENT OF THE MOQUITH MOUNTAIN WILDERNESS STUDY AREA WITH AN EMPHASIS ON THE CORAL
PINK SAND DUNES
III. TEAM FINDINGS REGARDING IMPLEMENTATION OF 1994 MOQUITH MOUNTAIN WSA MANAGEMENT GUIDANCE AND SCHEDULE
The team reviewed the action items identified in the Guidance (USDI, BLM, 1994) and determined whether or not they had been implemented. The team then evaluated the items that were being implemented to ascertain if impairment of wilderness values or undo degradation of any resource values was occurring.
The Guidance lists eight general issues. Four of these issues list additional specific action items. The issues and action items are listed as described in the Guidance. The findings of the team follow each listing.
ISSUE ONE
Numerous trails lead into the sand dunes portion of the WSA from the Hancock Road. Only two trails can be documented prior to the passage of FLPMA (1976). One of these two trails leads to a grazing allotment fence which crosses the sand dunes. Numerous pull- out areas have been formed to accommodate large motorized camping parties.
Action:
TEAM FINDINGS FOR ISSUE ONE
The team found that "Road Closed" and "Wilderness Study Area" signs have been placed along the south side of the Hancock Road from the junction of the Sand Springs road west to the junction of the Yellowjacket road. OHV traffic is being directed into interior of the dunes through clearly signed access points (Figures 1 and 2). The trail identified in Figure 1 is a pre-FLPMA trail. Compliance has been successful in most areas, however, the signs have been ignored in others (Figures 3 - 7).
OHV travel is occurring on both sides of the Hancock Road. There is substantial use of the utility right-of-way located adjacent to the south side of the road as well as use on the north side of the road as OHV users travel from the Ponderosa Campground and dispersed camping sites to the authorized access points into the dunes (Figures 8 and 9).
"No Campfire" signs have also been posted and appear to be successful. Campfire signs have disappeared as few charcoal traces were observed in the old camping areas located along the south side of Hancock Road. Motorized camping activities on the south side of the road have also largely stopped. Access and camping restrictions have been implemented by the use of signing and increased patrols. No physical barriers have been erected but will be necessary in certain areas to ensure proper compliance. The team also found that since the implementation of the camping restrictions on the south side of the Hancock Road, the area is beginning to recover as demonstrated by an increase in vegetation.
One unintended impact has resulted from implementation of the Guidance. During heavy use periods, such as the Memorial Day weekend, substantial (but unquantified) camping now occurs on the north side of Hancock Road outside of the WSA. Impacts to the landscape are starting to become noticeable in areas where camping repeatedly occurs (Figures 10 and 11).
ISSUE TWO
The dry lake bed (northwest portion of the WSA) has been used historically as a staging area and access route into the dunes for motorized camping parties and ORVs. This use has been documented prior to the passage of FLPMA.
Action:
TEAM FINDINGS FOR ISSUE TWO
The team found that imposing the 50 party limit on camping at the dry lake bed has not been implemented and is that the limit is exceeded on heavy use weekends. The weekends in which the recommended limit is generally exceeded are Easter, Memorial Day, Fourth of July and Labor Day. What constitutes an "individual party" has not been defined and could cause confusion if limits are attempted.
A "Fire Pan Only" restriction has been implemented and has been effective. Instructions for visitors are clearly provided by a large sign located at the entrance to the "dry lake bed" (Figure 12). Repeated visits to the site have revealed only one occasionally used campfire area. The dry lake bed was carefully examined following the latest Memorial Day weekend (May 23-25, 1998) use and was found to be clean of debris and a strong wind and dune movement eliminated any physical evidence of campers (Figures 13 and 14). Therefore, the team believes that no impairment has resulted on the dry lake bed proper, however, the presence of trails in the surrounding sagebrush and on the face of the adjacent dunes are of concern.
Access to the dunes from the dry lake bed has not been signed and multiple access points have been used (Figure 15).
The team found that signing the WSA boundary across the dunes is not feasible. There is no obvious division between the State Park and BLM administered lands. Much of the boundary crosses active sand dunes and any markers or fences placed in this area would be ineffective. There is also a safety concern regarding placing fencing or other structures on the faces of dunes where they would not be visible from all directions.
ISSUE THREE
Historical use of motorized camping and ORV staging area at Sand Spring and authorized access into the eastern portion of the sand dunes.
Action:
TEAM FINDINGS FOR ISSUE THREE
BLM has not improved or repaired the road into Sand Spring although it was bladed by Kane County in 1996. Two sign have been placed at the junction with the Hancock Road identifying camping and OHV restrictions (Figure 16 and 17). However, no other signing regarding access restrictions or identifying the dunes as a WSA were present along the Sand Spring road and several access routes into the dunes are evident (Figures 18 and 19). An examination of aerial photographs reveals that the evidence of these trails are likely a result of increased vegetation cover that has developed since 1974. Because OHV use was occurring in the area in 1974, the trails were likely present but were not as visible as they are now.
ISSUE FOUR
Wilderness inventory ways onto Moquith Mountain plateau, Lamb Point, Water Canyon overlook, and Hell Dive.
Action:
TEAM FINDINGS FOR ISSUE FOUR
These ways continue to be monitored on a regular basis. New trails have been signed and closed. A portion of these routes were bladed by Kane County in 1996. Trespass charges have been filed and the case is being resolved.
ISSUE FIVE
Continue to sign the boundary of the WSA.
TEAM FINDINGS FOR ISSUE FIVE
The team observed less than five "WSA Boundary" signs. There is a clear need to place several more signs along the boundary all the way from the boundary of the State Park on the west, past the dry lake bed, along Hancock Road, and down the Sand Spring road on the east. There are closed routes where signing should be supplemented by physical barriers.
ISSUE SIX
Continue scheduled monitoring of the WSA. Utilize maps and photo documentation.
TEAM FINDINGS FOR ISSUE SIX
The team found that this action item is being implemented.
ISSUE SEVEN
Notify the public and Moquith Interdisciplinary Team (ID) members of the guidance and schedule actions. Incorporate the Coordinated Resource Management Plan efforts into the Escalante/Kanab Resource Management Plan (RMP). Analysis and decisions will occur during the RMP process. Allow for intense public involvement during the planning process with the Moquith Mountain/Parunaweap Canyon Multiple Use Steering Committee and ID Team members.
TEAM FINDINGS FOR ISSUE SEVEN
The team found that many of the recommendations developed by the Coordinated Resource Management Plan Steering Committee which were documented in the Issues and Recommended Actions for Management of the Moquith Mt. and Parumuweap Study Area (USDI, BLM, 1991)were carried forward to the Guidance. Some were not. The final decision on which action items to carry forward was ultimately made by the local BLM Field Manager. The Kanab/Escalante RMP process has been halted, therefore it is necessary to begin work on a land use plan amendment for the area. This process is currently underway. It is anticipated that the amendment will be completed by the end of April, 1999. The process will provide an opportunity for extensive public involvement and review of proposed management decisions.
ISSUE EIGHT
Continue close coordination with the Coral Pink Sand Dunes State Park.
TEAM FINDINGS FOR ISSUE EIGHT
The team found the close coordination continues to be maintained with Park and other State of Utah Officials. BLM recognizes that actions taken on the sand dunes has a direct impact on the State Park. State of Utah personnel are current members of the planning team or are consulted on a regular basis.
IV. AFFECT ON RESOURCE VALUES FROM IMPLEMENTATION OF 1994 MOQUITH MOUNTAIN WSA MANAGEMENT GUIDANCE AND SCHEDULE
After reviewing available data, including aerial photographs and old documents, and conducting on-the-ground inventories, the team addressed the affect that implementation of the 1994 Guidance has on resource values, including whether or not unnecessary and undo degradation of resources was occurring or would occur in the future.
A. Wilderness Values
If Moquith Mountain were a designated wilderness, motorized vehicle use would not be allowed. But BLM is not charged with managing WSAs as if they were designated wilderness. Section 603 of FLPMA directs the BLM how to manage lands under wilderness review in these words: " During the period of review of such areas and until Congress has determined otherwise, the Secretary shall continue to manage such lands according to his authority under this Act and other applicable law in a manner so as not to impair the suitability of such areas for preservation as wilderness...." This language is referred to as the "non impairment mandate".
The general standard for interim management is that lands under wilderness review must be managed so as not to impair their suitability for preservation as wilderness. This is the "non impairment" standard".
The criteria for assessing whether or not a use meets the non impairment standard are: 1) The use, facility, or activity must be temporary. This means a temporary use that does not create surface disturbance or involve permanent placement of facilities may be allowed if such use can easily and immediately be terminated upon wilderness designation. Surface disturbance is any new disruption of the soil or vegetation, including vegetative trampling, which would necessitate reclamation; and 2) When the use, activity, or facility is terminated, the wilderness values must not have been degraded so far as to significantly constrain Congresss prerogative regarding the areas suitability for preservation as wilderness.
The IMP also states that it is BLM policy to minimize the establishment of new discretionary uses in WSAs that would be incompatible with possible wilderness designation, even when the uses would not in themselves exceed the non impairment standard. New uses, if authorized, must be temporary.
The team assessed 1) the affect that implementation of the Guidance is having on wilderness values within the Coral Pink Sand Dune portion of the WSA, and whether the non impairment standard is being met, and would be met in the future under the Guidance; and 2) the affect that OHV use controlled by implementation of the Guidance is having on the "new discretionary use policy" stated in the IMP.
IMP EVALUATION
Impacts on Naturalness: The IMP allows for continued use of motorized vehicles on routes that existed prior to implementation of FLPMA and for cross-country travel on sand dune areas, as long as impairment is not occurring.
In order to determine whether or not impairment of naturalness is occurring with implementation of the 1994 Guidance, the team deliberated on the question: Are new routes/disturbances occurring as a result of OHV use in addition to what existed at the time of the inventory?
Many of the routes within the Moquith Mountain WSA, both inside and outside of the Coral Pink Sand Dunes, can be documented as being in existence prior to 1976. These include trails originating off of the Yellowjacket (including use of the entire dry lake bed area), Hancock and Sand Spring roads, the Hell Dive route, and the routes to Lambs Point and Indian Canyon. These routes were verified through the examination of aerial photographs.
The Coral Pink Sand Dunes are active dunes, and vehicle tracks are transitory except where defined by vegetation. A comparison of 1974 and 1994 aerial photographs shows that while general vegetation patterns have not substantially changed since 1974, vegetation cover on certain portions of the dunes has increased. Because these are active dunes, it is not clear to what degree OHV use is the change agent for localized vegetation changes.
Trails do not persist in the less vegetated portions of the dunes, and in such areas, naturalness values are not being impaired by OHV use.
Trails located through vegetation and wet areas tend to persist. Review of the 1974 aerial photographs indicate that the dry lake bed was used for camping and routes to and from the dunes existed prior to FLPMA. Wilderness impairment is not occurring on the dry lake bed itself, as current OHV and camping use and any resulting disturbance, is no different to what occurred prior to the wilderness inventory. Still, in many locations in peripheral areas in the northern portions of the dunes, new trails are becoming established. In some cases, especially in the vicinity of Sand Spring, it appears that some of these trails are visible as a result of new vegetation expanding into vehicle use areas that were previously less vegetated. For example, an investigation of the Sand Spring site shows that vegetation patterns at that site have changed over the years as a result of several factors including water availability and sand movement, as well as OHV use. Large scale vegetation has increased in the area. This change in vegetation has been documented in a series of photographs depicting the face of the sand dune adjacent to Sand Spring. Photographs taken in 1979, 1985, and 1987 show a decrease in vegetation. However, photographs taken during 1998 show an increase in vegetation, especially perennial species. In other cases and especially in the area contiguous to the dry lake bed, the area containing OHV trails has expanded from what had existed at the time the inventory was completed in 1980.
The Guidance limits OHV use to designated pre-FLPMA routes and to sand dune areas in order to prevent the proliferation of new routes. Although the Guidance has not been fully implemented, naturalness values have benefited somewhat from the partial implementation efforts to date. Some routes have healed since being closed. Some closed routes appear to still be receiving vehicle use, however and formation of new trails is occurring in the northern peripheral portions of the dunes, which is leading to a cumulative loss of naturalness values that is impairing wilderness suitability. Unless the Guidance is fully implemented and additional measures taken including emergency closure of the peripheral area of the northern portion of the dunes, development of new OHV trails is expected to continue to be a problem. The public can not be expected to stay off of closed access routes if they are not posted as closed, or to know the area they are visiting is a WSA if it is not posted as a WSA.
Naturalness values have been affected historically by OHV use, and 70 acres of pre-FLPMA disturbance in the vicinity of the dry lake bed has been described in BLM reports both as substantially noticeable and substantially unnoticeable. According to the IMP, substantially unnoticeable means that an action must be so insignificant as to be only a very minor feature or it not distinctively recognizable by the average visitor as being human made or human-caused because of age, weathering or biological change. Either way, because of the free-moving nature of the dunes, most disturbed areas would eventually return to a natural appearance, probably without need for rehabilitation should Congress designate the area as wilderness. If continued OHV use is controlled according to a fully implemented Guidance, and if the additional measures proposed in this report are also applied, such use should not result in loss of naturalness that would further constrain Congress from designating the area into the national wilderness preservation system. (Temporary closure of the periphery of the dunes except for the dry lake bed and specific designated pre-FLPMA access routes, would control access further, and allow for the Guidance to be fully implemented and further reduce potential for loss of naturalness values.)
Aerial photographs also show that trails may be forming in the non sand dune portion of the WSA, although no on-site visit was made to verify such disturbance.
Impacts on Outstanding Opportunities for Solitude: OHV activity reduces the quality of opportunities for an individual to experience solitude. The loss is temporary, occurring only during the period of OHV activity. Should Congress designate the area as wilderness, OHV use would be eliminated and opportunities for solitude would remain outstanding.
Impacts on Outstanding Opportunities for Primitive Recreation: OHV activity reduces the quality of the primitive recreation experience. The loss is temporary, occurring only during the period of OHV activity. Should Congress designate the area as wilderness, OHV use would be eliminated and opportunities for primitive recreation would remain outstanding.
Impacts on Supplemental Values: Full implementation of the Guidance would protect the WSAs supplemental values. Although the existence of plant and animal communities within the dunes do not appear to be threatened by the OHV use currently occurring, full implementation of the Guidance would further assure that no unnecessary or undue degradation is occurring. Temporary closure of the periphery of the dunes except for the dry lake bed and specific designated pre-FLPMA access routes, would further benefit the Coral Pink Sand Dunes Tiger Beetle by eliminating any cross country motorized travel in BLMs portion of the Tiger Beetle habitat.
Consistency with the IMPs New Discretionary Policy: OHV use was established in the WSA long before the area became a WSA. OHV use has fluctuated since the passage of FLPMA. In 1978-1979, OHV use of the dunes was approximately 11,000 visits (State of Utah, 1997a). The use increased to a peak of about 35,000 OHV visits in the 1986-1987 year. Increased OHV use during the 1980s likely resulted in increased disturbance, resulting in the need for the Guidance. Present use is more in line with the 1978-1979 figures. Use estimates prior to 1978 are not available.
Because of the historic use of the area, allowing OHV use to continue in the WSA in the manner controlled by the Guidance is not inconsistent with the IMP policy concerning new discretionary uses. The Guidance does not advertise or identify the WSA as an OHV area. Any temporary structures such as signs and barriers are for the purpose of protecting wilderness values.
Findings Regarding The Non impairment Standard:
Continued OHV use of the Coral Pink Sand Dunes, if controlled by a fully implemented Guidance and with the additional measures proposed in this report, would not result in creation of new surface disturbance which would require reclamation. Wilderness values would not be degraded so far as to significantly constrain the Congresss prerogative regarding the areas suitability for preservation as wilderness.
B. Special Status Species
The team reviewed the available data on Welshs milkweed and Coral Pink Sand Dunes tiger beetle. Several findings were identified and are summarized below.
Welshs Milkweed (Asclepias welshii)
(1) Welshs milkweed is an early seral stage species which prefers open dune areas to those stabilized with vegetation. (2) The species prefers areas with reduced plant competition. Natural or accelerated sand movement provides the necessary habitat for the milkweed.
(3) Population numbers have fluctuated over the years and appear to be a reflection of climate rather than physical disturbance. Counts are difficult to maintain because of uncertainty of what constitutes a single plant and because plants tend to migrate in response to sand movement. (4) The loss of an aerial stem does not result in the death of an entire plant, rather it is more like pruning the branch off of a tree. (5) OHV use has not substantially reduced milkweed population and may, in fact, create additional habitat. (6) Inventories have located additional Welshs milkweed populations in dune areas outside of the Coral Pink Sand Dunes. In summary, the team found that OHV use was not causing unnecessary or undue degradation to this resource.
Coral Pink Sand Dunes Tiger Beetle (Cicindela limbata albissima)
(1) Exhaustive inventories have failed to locate the beetle in any other dune areas in Utah. (2) Nearly 95 percent of the known population and majority of habitat is located in the State Park. (3) Tiger beetle populations have fluctuated but generally declined since the studies began in 1991. The reasons are not totally clear but Dr. Knisley postulates that climate may be the primary factor in this decline although OHV use could be a lesser but contributing factor (Knisley, et. al. 1998a). However, new preliminary data reveals that the adult tiger beetle population substantially increased in the spring of 1998. This was a surprise as the predictions were that the population would continue to decline (Knisley, 1998b). In summary, the team did not find that OHV use was causing unnecessary or undue degradation to this resource.
C. Other Resource Values
1. VEGETATION. Aerial photographs were studied to determine the current status and any changes occurring in vegetation and vegetation communities over time, especially on the dunes.
The team found that large scale vegetation communities have not substantially changed
since 1976. However, in some areas, such as the dunes adjacent to Sand Spring, large scale vegetation cover has increased. The team determined that increases in large scale vegetation since 1974 have made some existing trails more visible. Herbaceous and grass cover varies annually with precipitation. Additionally, associated with the movement of sand is the movement in location of small scale vegetation. Thus monitoring of such small scale vegetation is extremely difficult. Vegetation change, as viewed from aerial photographs, will continue to be documented.
2. ANIMALS. The team found that generally OHV activity was not having an obvious detrimental effect on animal species that inhabit or visit the dune area. The dunes represent only a minor portion of the habitat of most of the species. However, the potential impact on invertebrate species that may be restricted to the dunes is unknown. Additional studies are needed. This work has begun with the issuance of a challenge cost share agreement to Dr. Richard Bauman of Brigham Young University to identify the invertebrate resource located in the Coral Pink Sand Dunes.
3. VERNAL PONDS The vernal ponds are cyclic in nature, therefore it is difficult to ascertain whether detrimental effects occur from OHV activities. However, OHV users tend to avoid the ponds. Since the bedrock associated with these ponds is at or near the surface and vegetation arises within the duff it is unlikely OHV activity within these areas would have lasting effects. Additionally, areas associated with water tend to recover quite quickly upon removal or any disturbance. However, since these ponds are a rather unique feature with this system, it is recommended that OHV activity at and adjacent to the ponds be discouraged.
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