Dear Mr. Zale,
Please accept this letter as the official comments on behalf of the American Sand Association (ASA) in reference to the Imperial Sand Dunes Recreation Area (ISDRA) Business Plan (BP) and fee increase. The ASA is a nonprofit organization representing over 35,000 members and 225 businesses that are Off- Highway Vehicle (OHV) related. The majority of our members recreate at the ISDRA. Our primary focus is to maintain access to public lands for motorized recreation. After a lengthy process of obtaining comments from our members, opposing the first BP draft, and initiating several meetings with BLM staff for improved ISDRA operating data, the ASA feels that the revised BP is well written and an improvement upon the previously released version. The ASA also acknowledges that this version of the BP addresses some of the concerns that had been brought up in the previous version. Please consider the following comments: • The BLM has not provided all of the financial data the ASA requested and was agreed upon by the BLM state director. We were only provided with a chart of FY2012 expenditures. Additional data was supposed to include: historical ISDRA expenditures, the cost to manage ISDRA considering levels of service with lesser amounts of funding with assumptions, and a future needs assessment. • The way fee collection is being conducted is not in compliance with the Federal Lands and Recreation Enhancement Act. • The cost for fee collection is excessive. • Although we feel the sticker proposal for season permits is a good idea, we feel it will negatively impact visitors who utilize multiple vehicles for their ISDRA trips. • The ASA believes the proposed permit fee increase, which equates to 66%, is an overly excessive amount. The increase in fees should not exceed the government’s published rate of inflation. • The one day visitor permit and second vehicle permit for seasonal visitors needs to be revisited. • The ISDRA Desert Advisory Council Subgroup should be utilized as a resource for future fee implementation strategy and/or fee rate adjustments. The ISDRA is one of the largest recreation areas of its kind in the United States with the least amount of funding. Section 3.2.1 of your Business Plan states that appropriated dollars are to be the primary funding source for BLM operations relating to the provision of recreational opportunities and experiences. According to this BP, the majority of ISDRA revenue will be coming from permit sales. The ASA feels that the ISDRA should receive its fair share of Federal appropriations to help offset the cost of BLM operations. We appreciate the opportunity to comment on this issue. Sincerely Nicole^licholas Gilles Executive Director 2
