Wonder Valley CSA 70-M with Wildlife Linkages
To: Bureau of Land Management
California Desert District
Attn: WMRNP Plan Amendment
22835 Calle San Juan de Los Lagos
Moreno Valley, CA 92553
email to cawemopa@blm.gov
May 23, 2015
Dear BLM,
We ask that the BLM designate all routes within CSA 70 M (Maps 18 & 19) and those within the residential
areas within the red ovals (Map 17) as open for street-legal only. To avoid confusion this designation should
be indicated with a different color on final maps. All routes that access washes should be closed, as they are
the wildlife linkage highways, and anyway are difficult for street legal vehicles to access safely.
Wildlife Linkage
The Wonder Valley area of 5 acre homesteads is crossed by washes draining from the Cleghorn Wilderness and
Bullion Mountains to the north (TMA3-18). The washes are integral to the integrity of A Linkage Design for the
Joshua Tree -Twentynine Palms Connection (SC Wildlands 2008), an ecological corridor not included in this DEIS
but visible on the map above.
 Please add A Linkage Design for the Joshua Tree -Twentynine Palms Connection (SC Wildlands
2008) to the final EIS analysis.
Wonder Valley, a community and CSA
Wonder Valley is an unincorporated community within the jurisdiction of the County of San Bernardino.
Wonder Valley is not a ‘lightly scattered residential’ area but a community of people, families, children, and
singles, of all ages and occupations, including artists, musicians, professionals, and the retired, who love living
in a beautiful, peaceful desert valley. There is a Fire Station and a Community Center where residents gather
for meetings and other gatherings.

Wonder Valley is a County Service Area (CSA70 M) for road improvement and residents pay taxes for
this support. Off-highway vehicles are hard on roads making the surface difficult for standard vehicles
to navigate. Additional taxes to support increased OHV travel would be borne by the residents.
 Please include an analysis of effects of Transportation Network on the County Service Areas, road
maintenance and funding in the Final SEIS.

The County Supervisors passed the OHV Ordinances 3973 (2006) and Ordinance 28.040 (2010) to curb
the noise (55 Dba is the threshold of comfort) dust, smoke and fumes from OHV riders in rural areas.
The BLM OHV Route Network would encourage a return of riders. The DEIS states there would be no
increase in riders but ongoing experience by residents does not support that assertion. Please see
Appendix 1.

The Ordinance makes it illegal to ride on county roads and illegal to ride on the private property of
others without permission of the owner in hand. This ordinance helped to curb illegal OHV riders in the
county.
 Your analysis must account for the OHV ordinances in the Final SEIS.

Designating all BLM routes within CSAs/communities as open for street-legal vehicles only would
conform to San Bernardino County’s Code Enforcement brochure explaining the OHV Ordinance. The
brochure shows legal OHV riding areas in the Morongo Basin.

A designated OHV Route Network through the Morongo Basin is an externality that realtors would
have to report before the sale of property, possibly lowering property values, and, by extension, sales.
It would also lower property taxes paid to the county.
 Your analysis must account for the effects of the Transportation Route Network on property
values, resale, and tax assessment in the socioeconomics sections of the Final SEIS.

The passage of the OHV Ordinance helped convince realtors to stop advertising “buy cheap and bring
your toys” that encouraged staging in large numbers and riding through residential areas. The
designation of an OHV Route Network could encourage a return to this practice.
 Your analysis must account for the change in community character with the designation of a
Transportation Network.

San Bernardino County desert areas are in non-attainment for PM10 and PM2.5, both exacerbated by
OHV riding on dirt roads. All residents in rural communities can be considered ‘sensitive receptors’.
Residents are captive unless they relocate, especially during holiday weekends. Captive residents were
not analyzed in the DEIS.
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 The Air Quality report incorrectly characterizes the ‘real life’ air quality, experienced by residents
and visitors in the Basin, caused by the current level of off-road riding on the dirt roads and dry
lakes in the Basin. The analysis in the final SEIS must be updated to accurately reflect our reality.

San Bernardino County Law enforcement faces several hurdles when answering complaints: there is
limited staff and funds; the county area is large, making a timely response difficult in remote
residential areas; OHV complaints are 4th on the list of priorities (the list only has 4 priorities); and
those who would complain may fear retaliation (it happens) so they keep silent.
 The Final SEIS must anticipate the increase in complaints and funding for staff in the Final SEIS.

BLM Law Enforcement is similarly challenged.
 The DEIS makes lots of promises for BLM monitoring, mitigation, and law enforcement. Please
provide an appraisal of staffing and funding for these tasks.
Tourism Economy

WEMO is exclusively concerned with recreation and the ability of OHV riders to have vehicular access
to public lands. The scant mention and provisions made for bird watchers, photographers, naturalists,
and hikers overlooks the value tourism provides to the economy of our Gateway Communities. Please
refer to Appendix 2 for more on tourism.
The checkerboard pattern of BLM land with private and state lands is an artifact of our homesteading and
railroad lands history. BLM Routes designated as ‘open to street-legal vehicles’ is not denying access to public
lands but respecting the rights of private property and the jurisdiction of San Bernardino County.
Thank you for your attention.
Name
I am a resident of Wonder Valley
Address
I am a resident of the Morongo Basin
I am a tourist from
Appendix 1 – Mileage, Riders, and GHG emissions
According to the BLM WEMO DEIS analysis, Alternative 3
1. Would have the” largest mileage of motorized routes available to support recreation. The increase in
the mileage of motorized routes would allow recreational users to be more dispersed, increasing their
recreational experience…” (See WEMO ES-16)
2. “None of the alternatives would lead to a change in the motorized vehicle use or miles traveled in the
planning area.” (See WEMO 4.15-2)
3. None of the alternatives would lead to a change in the motorized vehicle use or miles traveled in the
planning area, and therefore none of the alternatives would result in any increase or decrease in
direct or indirect GHG emissions from motorized vehicles. (WEMO ES-11)
From these claims we are asked to accept, without supporting documents, that a new Transportation Route
Network, crossing from Juniper Flats to Sheephole Pass, will be basically unused by the riding public, either
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locally or from out of the area. The BLM analyses assumes no new riders in the future (zero population growth,
heretofore an unattainable goal) – just riders dispersing away from each other to increase their recreational
experience.
These assumptions are utterly contradicted by the BLM analysis for the power of social media to reach a wider
audience that ever before. And that audience is a mere 90 minutes away.
“Publicity about an area’s recreational opportunity often attracts users. …The popularity of the web
(organizational websites, Facebook) and similar mechanisms to share information have further
increased sharing of information about locations and destinations in the desert. Computer apps can …,
and have further expanded the reach of information beyond club members and small groups of
individuals. This promotes discussion about specific areas and facilitates increased recreation at those
sites.” (WEMO 3.6-3)
The BLM has a phone app that will make the 10,428 miles of routes available to riders wanting “greater
freedom from regulations” “to try new forms of recreation while not having to worry about bothering others”.
The following paragraph skillfully describes the audience for the WEMO Transportation Network that is located
just 90 minutes away in Los Angeles. The population is young and will enthusiastically use social media outlets,
including the BLM phone app, to achieve recreational highs in the West Mojave.
“Located only 90 minutes from downtown Los Angeles, the WEMO Planning area is the recreational
backyard of the metropolitan area’s 21 million residents, of which nearly 2 million participate in OHV
activities and an even greater number camp, hike, or drive for pleasure.
The types of recreation provided in the WEMO Planning area are highly varied. Due to the vastness,
many visitors feel a greater freedom from regulations that encourages them to try new forms of
recreation while not having to worry about bothering others. Given the scale of the desert and this
sense of freedom, it is not surprising that many of the recreational activities centered around vehicles,
speed events or activities that require a great deal of acreage and separation from other visitors.
These activities include motorcycle activities, four wheel drive exploring, sightseeing, target shooting,
hunting, using experimental vehicles/aircraft, model rocketry, and dry land windsailing.” (See WEMO
3.6-1) (My italics)
What can be said here? It appears there were many different contradictory viewpoints in operation during the
DEIS planning process. The lack of consensus is an inherent weakness that has ended with a grossly incomplete
analyses of both the affected environment and the environmental consequences.
 The effect of doubling the transportation mileage has been incorrectly analyzed throughout the
DEIS, possibly a fatal flaw, and must be entirely redone.
Appendix 2 – Gateway Communities in the Morongo Basin and the Tourism Economy
Gateway Communities and their tourism economy are ignored in the socioeconomic analysis.
 This oversight has serious consequences and must be remedied in the Final SEIS.
IN 2013 THE MOJAVE DESERT WAS RECOGNIZED BY NATIONAL GEOGRAPHIC IN TWO SPECIAL TRAVEL ISSUES.
 The Mojave Desert – One of the world’s 100 most beautiful places and unforgettable destinations
 The Mojave National Preserve – One of the world’s 100 best kept secret journeys and hidden adventures
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Why do visitors come to the Mojave Desert?
Views without development
90%
Clean Air
89%
Natural quiet/sounds of nature 87%
Desert plants/wildlife
83%
Native wildlife
81%
Solitude
73%
Dark, starry night skies
65%
See Visitor Surveys at Joshua Tree National Park by the University of Idaho 2010.
Socioeconomics
Visitor spending resulting from visits to the national parks and other scenic public lands is a prime economic
engine supporting residents, businesses, and jobs in Mojave Desert communities. This economic relationship is
significant and ongoing as long as the conditions which invite visitors are ongoing. Please refer back to the
‘Why do visitors come?’ above. Businesses dependent on tourism understand that visitors can decide to go
elsewhere – the national parks and conservation lands in Nevada, Arizona, Utah or New Mexico – if conditions
no longer offer the amenities they crave. The tourism based communities are geographically isolated and
individuals have few alternative job choices. Tourism dollars enrich communities because they stay in the
communities.
2014 Survey
Joshua Tree National Park
Visitor Spending
1,589,905 visitors
Spent in communities
$73 million
Jobs supported
1,030 local area
Cumulative local benefits
$97 million
30.6% Visitor spending for lodging
20.3% Food and beverages
11.9% Gas and Oil
10.2% Admissions and fees
9.9% Souvenirs and other expenses
To download the report visit http://www.nature.nps.gov/socialscience/economics/cfm
Off-road recreation, at the scale TMA 3 Alternative 3 proposes for the area from Juniper Flats through Wonder
Valley (Maps 5-24), would literally convert the Morongo Basin into an open riding area. This would be
especially true on holiday weekends when tourists also flock to the desert.
 An analysis of the effects of the WEMO Route Network Plan on the tourism economy of the desert
gateway communities must be included in the Final SEIS.
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