The Nevada Chapter of Backcountry Hunters & Anglers has been involved with the issue of the Silver State Trail (SST) since 2004 when we submitted comments on the Lincoln Co. SST proposal, continuing through the 2006 White Pine (WP) Co. SST proposal and the subsequent 2010 Ely BLM EA which evaluated alternatives and finally, the decision not to designate the SST.

In advance, NV BHA wishes to emphasize: we strongly support the multiple use mandate for public lands, coupled with the sustainable use mandate. We understand and are sympathetic to the valid concerns and need of rural communities to bring additional economic benefits to their communities. Many of our members live in those communities. All of our NV members, and many national members, treasure the opportunities for our traditions provided by the valuable wildlife resources of NE NV.

Our assertion is that the most effective benefits will accrue when science-based cost/benefits study of destination ORV trail systems is made before soliciting additional motor-focused recreational use. Secondly, that effective management capabilities must be in place and wildlife impacts adequately addressed. Taking these advance precautions should result in the win-win of increased benefits & lower costs to wildlife, wildlife habitat, recreationists and rural communities. These are the primary reasons, NV BHA supports the No Action alternative in the WP Co. SST DEA.

The following information, requested in our NV BHA scoping comment, is not provided in the DEA:

* A science-based cost/benefit analysis of existing designated destination ORV trail systems, such as: the UT Paiute Trail, the Lincoln Co. SST, the Egan Crest Trail & the Ward Mountain ORV Trail system. 

* A monitoring data-based evaluation of BLM/FS management capabilities, in WP & adjacent counties, for current motor-focused recreation, including enforcement, restoration, sage grouse PHMA protections, seasonal closures, fire/weed issues, maintenance, education re ORV use, management of user-created routes, informal campsites, antler shed hunting, etc.

* A more detailed report on the current status of BLM & FS Travel Management Planning in WP than was provided in this DEA, including adjacent counties, signage, restoration of closed and/or multiple routes, development of maps, user-compliance.

* County resources in WP & adjacent counties be assessed re: current capacities for road maintenance, safety, search & rescue, EMT abilities, enforcement, clear delineation of legal routes for ORV use.

* Statistics provided re: numbers of motor-centered recreationists & non-motor focused recreation, assessing the balance of recreation opportunities in WP & adjacent counties, assessing the cost/benefits of both motor-centric recreation & wildlife-centric recreation.

Conversely, we DO support the actions proposed below:

Ely BLM adopt the WP Co. Public Lands Committee (PLUAC) Public Lands Policy Plan side-bars for OHV regulation & expanded recreation opportunity, p.40, Section 7.1-7.3. http://www.whitepinecounty.net/DocumentCenter/View/3930/WPCPublicLandsPolicyPlan2018

For future recreation EA’s, Ely BLM include data from the informative new study of the economic value of wildlife to NV and our rural counties, “Quantifying the Economic Contributions of Wildlife-Related Recreation on BLM Lands (https://www.pewtrusts.org/-/media/assets/2018/09/whitepapereconomic-contributions-of-wildlife-on-bureau-of-land-management-landssept2018.pdf?la=en&hash=042D9501D5FB6ADA5F1212692D1B4D179BC61588),” along with the Nevada fact-sheet highlighting the economic impacts of hunting, fishing, and wildlife watching on BLM public lands. WP Co. is rich in wildlife resources. This data should be included in any economic analysis.

BLM & FS public distribution of detailed maps of the thousands of miles of current existing designated routes for motor recreational use in WP & adjacent counties.

Work with the NV OHV Commission to:

* Issue an RFP call, providing grant $$, to neutral scientific bodies (such as DRI, Resource Concepts, ENLC) to study existing destination ORV trail systems. Entities such as NDOW, the Biodiversity Initiative and SHPPO must be consulted in such a study.

* Prioritize grants to public land agencies to assist in ORV education, monitoring, restoration and management.

* Prioritize grants to improve enforcement through public land agencies, NDOW, counties, state.

* Postpone further promotion of such trail systems until studies are complete and management capabilities are in place.

Thank you for your consideration of our comments. 

For healthy wildlife, wildlife habitat and the recreationists who enjoy them.