The public comment period having ended Friday for the Imperial Sand Dunes Recreation Area draft business plan, the Bureau of Land Management nonetheless acknowledged a desire to continue to hear from the public.

The proposed business plan is calling for a permit and vendor fee increase for the 2013-2014 dunes season, with season visitor permits doubling in price from $90 to $180, weekly permits rising $25 to $40.

Vendor fees would also go from having three price structures in place corresponding to the weekend, midweek or a major holiday, to a flat rate for short- and long-term vending.

The bureau signaled that its next move would be to analyze the 236 comments that the agency had received via email, as well as the dozen or so made during a Desert Advisory Council meeting Saturday.
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John Stewart, of the California Association of 4-Wheel Drive Clubs, said the business plan lacked “clarity of purpose and a clear definition of expectations.”

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Saturday was the public meeting portion of the DAC meeting where a major agenda item was the proposal to increase the user fees at Imperial Sand Dunes Recreation Area. Action by the DAC on this issue is advisory only as the formal proposal is required to be presented to the Recreation Resource Advisory Council in accordance with the Federal Lands Recreation Enhancement Act (FLREA).

The proposal will be updated with comments received and is expected to be resubmitted to the DAC at the next meeting (Spring 2013). The proposal calls for the fees to be in effect beginning October 1, 2013.

Following are my comments about this issue presented to the DAC:

BLM has stated that public safety - top goal and they are seeking to achieve a zero deficient budget for Dunes operations.

Within that framework, the draft business plan lacks clarity of purpose. It needs a clear statement of purpose followed by clear definition of expectations. The definition of expectations require more concise costing with respect to current costs and the projected cost increase.

A major concern not addressed and should be addressed is the increase in fees will drive some users to other locations. Basically, you will be changing visitation patterns. Moving recreation to other areas will increase impacts there and increasing operating costs for that area.

There is factual data supporting this concern as that occurred when fees were implemented about 10 years ago.

Rather than an immediate fee increase, implement phased approach with gradual increases over several years so as to not severely impact many of the visitors.

Day use - provisions for single day use should be included within the proposal.

Second vehicle - it appears that a single pass is required but it is unclear as to how a family with multiple vehicles would be accommodated. And, a second vehicle pass has been requested by users for several years and should be included in the proposal.

The business plan appears to address current operations; however, there the existing contract that is due to expire and it is not clear as to how the proposed draft will encompass the new contract.

FLREA prohibits fees collected from being used for monitoring. Costs and discussion of monitoring are included within the draft and should be deleted as those costs are not, and cannot be, associated with fees.

There is an excessive concern over "enforcement" to ensure "compliance". It seems more practical to just do it (single day pass and second vehicle pass) as it is a means of providing a reasonable expectation for the increased cost to beincurred by the recreationist.

Opportunities for cost reduction are not defined. Look at "cost recovery" from those that are involved in incidents as a means to offset the need to raise costs to the responsible recreationist.

Friday featured a tour of the BLM El Centro Field Office resource area. The tour began with a stop at Overlook for a brief description of the Imperial Sand Dunes Recreation Area. That was followed by a stop in the Indian Pass area to view an area of Native American cultural significance. Okay, the area does have a rich history of culture and the tour today pointed out prehistoric, historic and current viewed at five different stops.

I encourage everyone to take the time or make the effort to learn about the Native American culture that is within their favorite recreation area. I do have some interesting pictures that will be posted within a couple of days showing some culturally important points.

And, historic culture such as transportation and mining are important precursors to current recreation.

From Native American trails several thousand years old to the Plank Road of the early 1900s, transportation has shaped the history and culture of this portion of the southern California Desert.

Saturday will feature the public interaction portion of the DAC meeting. One important topic on the agenda is the "business plan" for the Imperial Sand Dunes Recreation Area (Glamis). For almost 10 years, ISDRA has been under a user fee structure. On tap is a potential doubling of the user fees.

After a brief review of the proposed "business plan" developed by BLM El Centro, I find several serious problems. First, the plan begins with the assumption the users need to pay a certain level for their recreation access to the dunes. This is a fatal flaw as it does not account for the cost incurred by the BLM to provide the recreation opportunity enjoyed by many.

In fact, it appears to use the fees imposed at Glamis to subsidize other non-fee areas of the southern California Desert.

Second, the plan does not address the "flee the fee" potential. In other words, the current fee is accepted by a majority of the dunes recreation user as a reasonable fee to enjoy their recreation opportunity. If that fee were to double, how many would still feel it is a reasonable expense to enjoy their recreation opportunity.

History tells us that there are a certain number of recreationists that would choose to move to an area where a fee is not assessed. That instance was demonstrated when the initial fees were established at Glamis. That leads to an under estimate of fees based on income fro fee receipts. And, that transfers visitor days from a fee area to a non-fee area.

In short, that is a disaster in the making.