Stop permanent OHV route expansion across 344,000 Utah acres

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• The document assumes implementation of minimization measures (signing, enforcement, monitoring) will reduce unauthorized OHV use on closed routes to near zero, yet Section 1.1 explicitly documents that "routes that have not been formally evaluated by BLM to determine appropriate designation exist on the ground" and that implementation challenges from the 2008 RMP have resulted in "more routes than were designated...receiving use." This assumption contradicts the agency's own experience showing that formalized designations have failed to prevent unauthorized use. The EA should explicitly analyze what happens if the Implementation Guide's measures are ineffective, as they were under the 2008 plan, or extend the monitoring period to establish baseline compliance rates before drawing conclusions about route closure effectiveness.
• The document presents visual resource impacts from route use as only occurring during the time of vehicle use (temporary and localized), yet offers no analysis of how increased route designation under Alternatives C and D (637 and 694 miles vs. 279 miles in Alternative A) affects the cumulative visual footprint on the landscape. While individual trips may be temporary, the permanent expansion of the visible route network by 130-149% represents a permanent change to landscape character that the document dismisses without quantitative visual impact modeling or comparison across alternatives.
• The EA assumes all 699 miles of routes currently exist and are in use regardless of alternative, so designating routes closed will not create new disturbance (Section 3.2.7). However, this reasoning inverts the causality of effects: the 2017 Settlement Agreement and the EA itself document that poor implementation of the 2008 TMP created the current condition where undesignated routes are receiving unauthorized use. The document fails to analyze whether opening currently closed routes through Alternatives C and D will normalize and legitimize the unauthorized use patterns that have already damaged those routes, versus the potential for reclamation and recovery if routes remain closed.
• The document states that cultural resources within 300 feet of routes could experience adverse effects including erosion, dust, vandalism, and looting. Table 3-3 shows Alternative A has 9 potential adverse effects to historic properties, while Alternative D has 48. Yet the document provides no analysis of the significance of this 433% increase in cultural resource sites at risk, nor does it explain why it is acceptable to expose 39 additional historic properties to demonstrable adverse effects when the purpose and need can be met with fewer openings.