January 24, 2008
Monument Manager
Canyons of the Ancients National Monument
27501 Highway 184
Dolores, CO 81323
Canyons of the Ancients National Monument
27501 Highway 184
Dolores, CO 81323
Dear Monument Manager,
The National Rifle Association appreciates the opportunity to comment on the draft resource management plan (RMP) for the Canyons of the Ancients National Monument. Our single concern is that the BLM is proposing to close the Monument to recreational shooting in its preferred alternative. We do recognize that the Monument will not be closed to hunting.
We are as concerned as the BLM about protecting the irreplaceable cultural resources found in the Monument from damage that has occurred because of the thoughtless actions of some visitors, including some who recreationally shoot in the Monument. Vandalism, litter, and safety concerns are examples of problems that prompted the NRA to spearhead the establishment of a working group (roundtable) made up of representatives from the land management agencies and national sporting organizations. The purpose of the roundtable was to identify problems associated with recreational shooting and solve them together. The original roundtable eventually led to the Federal Lands Hunting, Fishing, and Shooting Sports Roundtable MOU signed by the BLM, Fish and Wildlife Service, Forest Service and 40 organizations.
It would have been helpful, in the spirit and framework of the MOU, if we had been advised of these problems long before they were used as reasons to close the Monument to a recognized recreational activity on BLM lands. In the alert that our organizations received about the RMP, it states that "we look forward to working with you to address any concerns you may have related to recreational shooting activities. Through your participation in this effort, we can move toward a common goal of improved management of public lands administered by the Canyons of the Ancient National Monument." That would be a laudable objective but for the fact that the BLM has moved ahead with its RMP and preferred alternative to close the Monument to recreational shooting. It is unclear how we as signatories to the MOU can participate with the BLM in this effort.
The plan does not explain how many people recreationally shoot in the Monument and what is available to them outside of the Monument in terms of travel distance and accessibility to alternative sites. The plan states that" there are currently no organized recreational shooting groups with Special Recreation Permits nor are there BLM-designated areas for recreational shooting in the Monument." It is not clear what is meant by that statement. We believe BLM would agree that few recreational shooters on BLM lands are affiliated with a group or club. We are also not aware of any such groups receiving special recreation permits unless those permits are in association with formal shooting facilities. In that case, it is our understanding that BLM's policy is to use the Recreation and Public Purposes Act to transfer public land to some entity, like a local government body, rather than manage and maintain infrastructure such as a shooting range on its own property. We have also been advised through our participation in the Roundtable that BLM does not designate areas for recreational shooting because of concerns over liability and hazardous materials (a separate issue altogether).
The MOU Roundtable offers technical assistance to public land managers and one of the elements of that assistance is to have an area examined for its suitability for recreational shooting. Both BLM and Forest Service managers have taken advantage of this service. Such expertise provides support to management in making decisions about the suitability of sites or areas, such as an entire monument, for recreational shooting. To unilaterally close the Monument without such a site review raises concerns about how BLM is addressing recreational shooting across the landscape. If the Monument by its terrain, by encroaching development, or other factors cannot provide properly for recreational shooting, then that should have been clearly articulated in the plan. To use vandalism, litter, and safety as the reasons to close the Monument bespeaks of BLM's disinterest in working with its MOU partners to help solve these problems and raises significant concerns because the reasons used in the RMP for closure could easily be used for BLM lands elsewhere.
We have found that the BLM's general approach to resolving issues related to recreational shooting is to close a problem area. The MOU was and is designed to identify approaches that resolve management issues and ensure the future of recreational shooting, which in many areas of the country is largely dependent upon access to federal lands. It would seem that in an area encompassing nearly 165,000 acres, some of those acres could be made available for recreational shooting, but again there is no way to assess that without some acknowledged professionals conducting a site visit. It is apparent that it was not BLM's plan to do so.
The NRA recommends that the preferred alternative be amended to require a professional site visit and report before any final decision is made about recreational shooting in the Monument. The NRA and other MOU partners would be pleased to provide the BLM with a list of people who have experience in the field of recreational shooting to assist in this effort. That action would give credence to the statement above about working with your MOU partners to move toward a common goal of improved management for the Monument.
Again, thank you for the opportunity to comment on the RMP.
Sincerely,
Susan Recce
Director
Conservation, Wildlife and Natural Resources
Director
Conservation, Wildlife and Natural Resources
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