Dear Ms. Rodriguez and Congressional staffers,

A belated thank you for the gift of your time in hosting the Truckee Meadows Public Lands Management Act all-day stakeholder discussions last month (1/24). No small feat! And an extra thank you for including us, as well as our representative from national Backcountry Hunters & Anglers (BHA). We apologize for the lateness of this response, but as volunteers, sometimes life & day jobs intervene to keep us from the computer.

For your reference: Attached to the bottom of this letter are our comments submitted to you in early January. Much of what stated at that time is still relevant to our current thinking. 

Thoughts in general re: the 1/31 meeting:

* The updated proposal definitely is an improvement over the 2018 effort in both the disposal and conservation pieces. The closer scrutiny of both those pieces of the proposal was beneficial. Although not included in the previous go-around with map decisions, NvBHA was pleased to see adjustments had been made to accommodate some concerns in significant places, parallel to our concerns.

* Well conducted and facilitated meeting with an array of experts at hand!

* The full representation of our Congressional delegation gratified us that they are not only well engaged in this process, but playing an appropriately leading role, along with the county and cities.

* The stakeholder group was larger than we had hoped, holding propensity for most numerous and loudest to hold sway.

* Despite that, the meeting was more inclusive than those of the past from which we were excluded :-)

* It was a key benefit to hear concerns (beyond those of ours re wildlife & Wilderness values) of tribes, mining & ranching, enabling NvBHA to better shape our comments in trying to address concerns of which we were not fully aware.

Specific concerns re: 12/31 meeting:

* The maps were significantly insufficient in details such as topography to at be able to easily identify specific sites with which we are familiar and/or to understand rationale for boundaries in areas with which we were less familiar.

* Lacked a Wilderness law expert re: both the law & the NDOW/BLM MOU to firmly, authoritatively answer repeated concerns that would otherwise been dispensed with immediately. Concerns especially re: access to private inholdings and to fire fighting capabilities were voiced repeatedly. Those issues are clearly spelled out in both the law & MOU: access continues in manner it did pre-designation and bulldozers can be used vs fire when necessary. Much more time could have been gained to grapple with more uncertain matters had such concerns been definitively addressed immediately. 

* Any further meetings should have such an expert to give a quick Wilderness facts/myth-busting session so as to keep deliberations of the meeting on a productive and relevant path.

* As an adjunct to that, we suggest clarification at the start of any public meeting that Wilderness is multiple use. We suggest any further meetings start with an expert on the Multiple Use, Sustained Yield Act to explain/list the multiple uses defined in the law. Additionally to clarify the intent of the act: all uses are not meant to occur at the same time on every acre of public land, just that opportunity is to be provided for each on public land in general. The Wilderness Act precludes (from the list of multiple uses) only motor/mechanical vehicles and new mining claims. We would be gratified to never hear “returned to multiple use” in any future discussions (or maps) re: potential release of any WSA.

The following are our evolving comments & concerns within the 2 portions of the proposed bill:

Disposal:

* Disposal areas to be released from BLM management must have a plan re: fire, including liability, prevention measures, means to fight fires, analysis of numbers of fire personnel and stations (including a budget) to replace previous BLM responsibilities. 

After hearing more about the purpose & need for each proposed conveyance, plus concerns expressed by other entities, our position currently  is to exclude the following areas from within the boundary of the disposal area:

* The Peterson & Dogskin Mountains (under stringent wildlife protection management direction) with a sizable buffer zone on all sides to provide for connectivity and wildlife migration.This would bolster assurance the dwindling wildlife populations in these areas have a chance at rebounding and habitat degradation minimized.

* The Bedell Flats in it’s entirety. This is a vast chunk of public land within the proposed boundary creating public wariness as to potential loss of access. We contend public use will be better protected if this area is outside the boundary. We do recognize and support the needs of TMWA. However, the intended TMWA purposes can still be realized through the regular BLM NEPA process, while assuring science-based scrutiny of potential impact to all resources and opportunity for public participation.

* The entirety of the Pahrah Mountains. Again, the BLM NEPA process should be employed for any future proposals within that range, including a road across the southern end. The many significant wildlife, cultural and roadless resource values at stake deserve a cautious deliberative legal process, the certainty of science-based scrutiny and an inclusive public process.

Conservation/Wilderness:

* As in our previous comments we emphasize the reality that new unroaded areas will never be created in future, the existing WSAs are all that remain of such areas in our county. As such, they are a quality of life and recreation opportunities attraction to folks living in our county and in our state. They are of import as a symbol of our frontier heritage to public land owners across our nation. Having more public land than any other lower 48 state, NV can capitalize on our reputation as the last of the wild west and wild lands. Not only do folks from other states come here to experience that atmosphere under our big skies and broad open valleys, but also folks from around the world. ALL public land owners and those who appreciate our wilds deserve a very cautious, deliberative process, taking all the time necessary for visionary decisions on what lands in Washoe County shall remain wild and extend as such into the unforeseeable future.

* Roadless areas are typically where wildlife habitat is least disturbed & wildlife thrive, thus typically where our members seek to hunt, fish and trap. We support decisions that conserve & protect as much of the existing roadless qualities as possible, while making site-specific adjustments to accommodate essential wildlife management that cannot be legally accomplished within Wilderness. We seek to foster administrative reforms in BLM to rid the NDOW frustrations of legal management activities that are either not applied or applied inconsistently. We all lose in that existing scenario: humans, wildlife and wildlife habitat.

Area Specific thoughts to date:

Fox Range: 

*The significant roadless qualities of this area must have some form of strong protection. 

* Concerns and recommendations of the Pyramid tribe need be paramount, as the WSA is contiguous with the south end of the range within the reservation.

* We share the Pyramid tribe's hope that the recently introduced bighorn sheep will migrate to the Fox Range before too long. 

* Bighorn sheep will require the protection such roadlessness provides for them to thrive into the future. 

* Selenite Mountains: the slice of the Selenites within Washoe Co. must not be released without considering the entirety of the Range.

Granite-Banjo: 

* The recent acquisition of significant portions of private within this area has been celebrated by our members who have always valued the wilderness qualities of this iconic area.

* High elevations of this range enhance the resilient/resistant qualities, triggering fewer habitat management concerns.

* The roadless quality of the southern portion in particular is rare and valuable. This piece should be added to the current proposal.

* While a road in the far north almost severs that section from the rest of the range, it does include a number of the parcels purchased for conservation purposes. We’d like to brainstorm ways this section could be permanently protected. 

* We have serious concerns about the motor route that extends along the ridge-line  It is troublesome in terms of potential wildlife motor sight/sound disturbance, loss of wildlife security screening, increased hazards of fire, weeds & route proliferation that motor travel brings. That said, it is access to private and thus problematic in devising a solution. This concern should be discussed with the owner and perhaps a solution could be found, such as seasonal restrictions. At the very least, the south-most private parcel should be high priority for acquisition. 

Dry Valley Rim, Burro Mountain, Twin Peaks, Buffalo Hills, Poodle Mountain:

* There are excellent roadless and Wilderness qualities in each of these areas and, except for Burro, each have some problematic issues related to wildlife management, rancher concerns and fragmentation by routes to resolve.

* The proposal maps show many, if not all, of these concerns have been resolved: such as carve-outs for active wildlife management, adjustments for rancher ease of access, elimination of the center of Poodle with it’s problematic tangle of routes.

* All of these areas have high wildlife values enjoyed by our members: chukar, sage grouse (SG), antelope, mule deer, raptors.

* Many springs and riparian areas, important to SG brood-rearing and all other wildlife in general, are within each.

* For the above reasons, all of those existing WSAs, plus connecting surrounding lands, must have firm protective designations.

* In general, we support the proposed Wilderness proposals, with possible adjustments, plus and/or minus, as we take a closer look.

* We oppose the smaller size NCAs around and/or connecting a few of these areas.

* We support the concept of a much larger, single NCA surrounding all of the above areas, boundaries to be determined by a deliberative stakeholder process. Having been closely involved in the Black Rock-High Rock NCA designation and the subsequent BLM RAC advisory committee in formation of the management plan, NvBHA believes this larger vision will lead to more effective on the ground management and the cost/time-effectiveness of a single management plan. The NCA must have as it’s over-riding purpose: Wildlife Habitat Management, coupled with direction for a strong travel management plan.   

Wall Canyon:

* We do not support release from WSA status for Wall Canyon.

* The acquired private parcels within this area for conservation purposes increases the value of the public lands in this area.

* Wall Canyon is a key NV area by virtue of it's critical SG habitat & leks.

* Archeological values are extensive.

* Many of the problematic (to Wilderness values) existing routes were informally created and/or extended since the time of WSA designation. For that reason, without a protective designation, more user-created routes would be expected to continue to fragment the habitat in this area, diminishing critically sensitive wildlife & archeological resource values.

* For all the above reasons, this area deserves strong conservation protection, such as that provided by a sizable NCA to both wildlife habitat and cultural resources, while allowing current motor access and minimizing further route proliferation.

Massacre Rim:

* We are not convinced that the entire large size of NCA Wilderness proposal portion is completely necessary for adequate juniper management purposes. We had hoped for a smaller more surgical proposal. We agree that stage 1 and some stage 2 juniper incursion is definitely problematic, but a field trip could allow this discussion to be made while on the ground. There are a significant number of impressive old growth juniper within this area.

* Our members highly prize the unsurpassed solitude, ruggedness, endless vistas, abundant antelope, extensive petroglyph panels this area provides. It is worth our most creative visionary ideas re: how to protect those values for the future.

* While understanding the benefits to local economy the rare International Dark Sky Area designation brings, NvBHA's main concern is for providing as much solid Wilderness protection for this area as possible so it does not get “loved to death".  

* Because of the above concerns, coupled with the extremely high SG habitat values, we oppose ACEC designation for the small east-side portion of Massacre. Rather, we propose that all the land from the northeast corner of the proposed Wilderness over to the Sheldon Refuge west boundary have a more lasting, tighter designation than an ACEC. ACECs are administrative and can be changed in a management plan revision. This too deserves our careful creative thought.

Sheldon Contiguous:

* This is yet another high value SG area. While we support the current proposal, we support looking carefully to see if any accommodation can be made to extend it into the portions to the west that have degree of roadlessness. Again, a field trip could be beneficial to both understand and potentially allay management concerns.

* We oppose releasing any of the proposed release area without significant protections against new developments such as mineral leasing & concurrent rights of way.

Sheldon Refuge:

* We share the concern of the Wildlife Coalition (of which we are a board member) that Wilderness designation could be an unnecessary overlay to wildlife habitat management.

* That said, large areas were designated as potential Wilderness by FWS almost 40 years ago. They are managed as Wilderness until they are released or designated by Congress. Some of those areas are in need release to facilitate a higher level of management. 

* We are open to the idea that the Washoe proposal may be a vehicle to assist in resolving those issues. This idea should be explored and discussed. Again, a field trip would be beneficial.

Conclusion:

NvBHA is pleased that the decision-making process re: proposals in this bill have improved since the previous attempt in 2018. The recent stakeholder meeting on January 24 was large and intense, but educational for us. We greatly appreciate being included and given an opportunity to speak and interact. The effort of the staff members of Washoe Co. and the cities of Reno & Sparks in pulling that critical meeting together is impressive and appreciated. It was very encouraging to have staff from our Congressional delegation at this critical meeting. Their presence was essential. Our hope is that adequate time will be provided for continued discussions, map-work and field trips in the near future to keep this process moving forward in a positive, productive way. We definitely look forward to continued participation in this important process with you, our Congressional delegation and all stakeholders. Washoe County residents stand to benefit in so many ways, particularly enhanced quality of life and recreational opportunities. 

Thank you for this opportunity to comment, 

David Ricker: Conservation Policy Chair

Karen Boeger: Conservation Policy Committee

Backcountry Hunters & Anglers, Nevada Chapter