Dear Supervisors and Planning Department:
As I will not be the Great Basin Air Pollution Control Districtí’s Air Pollution Control Officer on December 30, 2014, the date of the rescheduled hearing on the Eastern Sierra ATV Adventure Trails Project, I am submitting these comments on the project for the record.
Ted Schade
The Great Basin Unified Air Pollution Control District is the regional government agency that works to protect the people and the environment of Alpine, Mono and Inyo Counties from the harmful effects of air pollution.
As its Air Pollution Control Officer, it is my responsibility to enforce clean air laws to ensure that our people and environment are protected.
These comments from Great Basin regarding the proposed Eastern Sierra ATV Adventure Trails Project address only the potential air quality impacts of the proposed project. Others have or will weigh in on the other positive and negative impacts caused by the proposed project.
As the Air Pollution Control Officer, I have no opinion as to whether or not Inyo County should approve the Adventure Trails Project. My only concern is the project ís the impact on our air quality.
As required by law, Inyo County conducted an analysis of the environmental impacts of the Adventure Trails Project. That analysis identified a number of potentially significant environmental impacts and the project requires mitigation measures to reduce those impacts to less than significant levels.
However, the County’s own analysis concludes that, even with two proposed air quality mitigation measures (reducing speed limits and dust ìknock-offî grates within one-half mile of residences), the Adventure Trails Project will have significant unmitigated impacts to air quality. In fact, air quality is the only resource area that the County’s analysis shows ongoing significant environmental impacts from the project.
When discussing the environmental impacts of air pollution, ìnsignificant environmental impacts actually mean impacts to human health. These are not impacts to plants or animals or cultural resources or soil or water. These are impacts to our most vulnerable residents ór our youngest, our oldest and our sickest residents.
In the 24 years that I have been with Great Basin, we have done so much to reduce air pollution in the Eastern Sierra. We have controlled wood smoke in our communities; we have paved roads and parking lots; we have adopted agricultural practices that reduce air pollution on our farms and ranches; and we have nearly controlled the dust from our dried lakebeds. Yet, we continue to have days in Inyo County when we are exposed to air pollution that exceeds state and federal air quality standards. This air pollution impacts all the communities in Inyo County.
We cannot undo this progress and threaten the health of any of our residents that live on or near the proposed ATV routes by approving a project that has any significant air quality impacts. You probably read the letter in the December 2, 2014 Inyo Register from the California Association of 4-Wheel Drive Clubs supporting the project. It agrees that the project will have significant impacts air quality impacts, but concludes that the air quality issues noted are not in excess of existing air quality issues. This statement is untrue; air pollution is additive ór more air pollution equates to more impacts. These significant impacts cannot be ignored by county decision-makers.
The proposed project will increase local sources of air pollution where people live, work and play. As such, it will have adverse impacts on their health. Unless or until Inyo County modifies the project to reduce all air quality impacts to less than significant levels, I would implore your Board to not approve the project. Direct your staff to work with Great Basin to develop real mitigation measures that reduce all air quality impacts to less than significant levels, even if it means modifying the scope and requirements of the project.
To not do so will mean that you did take all reasonable precautions to protect our health. That would not only be the wrong thing to do, but would also mean that the project will inevitably be doomed through litigation.
Please do the right thing for everyone that breathes. Thank you.
Sincerely,
Theodore D. Schade, P.E.
Air Pollution Control Officer
Well folks, after 70+ posts, everyone is saturated! So, I’ll give a parting shot. I supported Adventur Trails because Randy Gillespie of Golden State Cycle wa.nted it. Now that his shop is closed, I have no major reason for supporting AT. Now I want to keep the Eastern Sierra trail… Read more »
Wayne: It just hasn’t happened! These areas up here that you mention have been open to ORV’s for decades and I don’t believe for one minute that opening a few paved roads for people to buy gas and food are going to do what was done down south. This plan… Read more »
BobK….Not so much fiction….If you think what I say is “fiction”,take a couple days off and visit the Antelope Valley…I lived in Lancaster,Quartz Hill and Rosamond from 1962 till 1991,and saw FIRST HAND what ORV’ers did back in the 70’s and 80’s and do to much of that area to… Read more »
Come on Deja there’s a bit of fiction in there. Littlerock Dam was closed due to a federally protected and endangered species the Southwestern Arroyo Toad. The OHV area has since reopened, however the canyon is still closed upstream of Rocky Point to all access. I’d also like to point… Read more »
Trouble I’m not talking about legal, I’m talking about “RESPONSIBLE'”. In a nation of finger pointing this is one more argument that he who shouts the loudest wins. A very few will prosper from this ill conceived bill. I hope some day we will meet so that I can kick… Read more »
Desco- I live next to the route and I can’t wait to be able to hoop on my quad and just go. I’m not worried about your other desires!
W Deja: You need to a apply for a job with National Enquirer with all of the fiction that you write. The Buttermilks (where the deer migrations occur) have been open for years and there has been no problems that I am aware of, and I live real close. The… Read more »
I saw one of these law abiding, outdoor fun loving dirt bikers in Bishop the other day. I was going west on Maciver and he was making a right off Main at the pizza place. When I first saw him he was leaned over so far I thought he had… Read more »
Desco- Enduros are already allowed to go on all these roads legally. They still will be when this law really goes into effect on the 30th!
HAHAHA… Whoever started this Jawbone and Cal City nonsense needs to give it a rest. Jawbone, Dove Springs, Cal City, Randsburg, etc are all VAST spaces with endless miles of riding. I personally go out every Thanksgiving with 20 RV’s just outside Randsburg to ride all of the miles and… Read more »
At roughly 100 miles long by 5-20 mile wide, the Owen’s Valley is vast area as well. Not to mention the scenery is far better here than in the Mojave Desert. And many of those thousands of groups you describe would love to get away from the crowds you’ve experienced.… Read more »
The EIR also describes “links” to and includes combined use routes (& signs are already going up which implies the decision is considered bought and paid for) to Casa Diablo, Little Cowhorn Valley, Deep Springs Valley, Coyote Plateau, Alabama Hills, Foothill Road, Silver Canyon and the top of the Whites… Read more »
When this project starts local law enforcement, CHP & SO, will have to strictly enforce absolutely everything due to liability issues. CHP made the discretionary call that 36 of 38 combined use routes are completely safe. Including multiple paved mountain roads at Independence, Lone Pine and Big Pine (that determination,… Read more »
CHP will probably be enjoying their now found freedom on their days off.
I think the California Highway Patrol Boys and Inyo County SO will be scrambling to enforce absolutely everything when they realize they have approved a use as safe that even Inyo County has said is unsafe (such as when Inyo County has closed Tuttle Creek Road to downhill traffic during… Read more »
The CHP isn’t going to be liable for anything. The state ends up paying the bill for any lawsuits that are won. No matter what happens the CHP is unaffected. They gave their professional opinion but they are not the ones approving the plan. I don’t have a high regard… Read more »
One windy day in the valley does more than what ATV, UTV, or Motocycles would do in 100 years. Give me a break. The biggest source of pollution is the Owens Dry Lake. Why doesn’t the air pollution control board focus on the big stuff first rather than the less… Read more »
Anyone who has seen the steady stream of toy haulers heading back to LA after a weekend at Jawbone Canyon/California City/Dove Springs would hang the supes if they approved this project….and Bishop has much nicer trails, dirt roads and scenery than those places. It will mean a serious decrease in… Read more »
i can just imagine the looks on the faces of the hunderds of thousand maybe more people that have come up here and spent their money here to camp in the sites around bish op that come up here for the peace and quiet, to fish hike , bike ride… Read more »
pite……The smell of gas and exhaust…..hard to find quiet….dust in your bacon….How about glass from broken beer bottles in your tires…biker-men popping wheelies on your town streets at 6:00 A.M. Sunday morning…loud groups of confrontational off-road boys filling the campgrounds and causing late-night trouble for others….beer-runs at Saturday 2:00 A.M….animals… Read more »
Thank you, Ted, for providing the public with real information on the fugitive dust increases that this proposed project will bring. There is a lot of misinterpretation in these letters about your statements. Most of this valley is federally designated non-attainment area for PM10. Los Angeles has spent well over… Read more »
“With 37 million people in California”
Exactly!
That’s the real problem the environmentalists don’t talk about.
That’s a huge carbon foot print.
Exactly is right! So what do you propose? Those 37 million people aren’t going anywhere. So we need to have practical land management in place for that many folks. And those 37 million are exactly why the examples of Utah’s trails program don’t hold any water. Utah has a population… Read more »
Spangler & Jawbone are designated open riding areas. They have large staging areas to camp and are relatively close to So Cal. That’s why those places look the way they do and I’m fine with that. The area near Poleta pits is an open riding area but the terrain is… Read more »
@CFP, Like you, I used to do my best to ride and behave responsibly when I rode bikes on our public lands. Unfortunately from my experiences that isn’t always the case with others. I don’t share your opinion on how many riders will potentially travel to this area though. The… Read more »
More humans being born into the welfare system every day. It’s not sustainable. Population increase is the biggest factor when it comes to humans destroying the environment.
Jawbone is thinking too small. That’s why the concern about no numbers or analysis in EIR. There are what, at least 15 million people in the LA to San Diego area? Look at the toy-hauler traffic jams on weekends heading out on 15 and 10. They are getting pushed back… Read more »
Horse Guy…..You say “Adventure Trails is going to be a BIG money maker for Inyo County,at least that’s what we’re being told”….wanna bet ?….First off,the ORV’ers are quite content tearing up Jawbone Canyon and Cal City without adding another 2 hours or so extra drive-time to come up farther into… Read more »
Whoever makes the decision to approve the Adventure Trails System, you better be right because you will never un-do your decision.
Actually Ken, what everyone fails to mention or notice is that the Trails System is only a pilot program (strange since its in the title of the proposal). It has a two year lifespan. If implemented, after two years, it will be null in void. Then it must be revisited… Read more »
Actually not null or void. The program will still be there and the Board of Supervisors will have the discretionary authority to decide: 1-continue; 2-continue with revisions; or 3-discontinue. The EIR does not include a monitoring plan, schedule, or budget and no baseline data has been collected. So they are… Read more »
More like leaving themselves an out later on since there will be no hard data to refute regardless of what decision they make. Hey, just saying ………………
is somebody jumping the gun , im seeing new signs poping up on posts from round valley school to bishop creek and ed powers, these are small brown arrows pointing the way to bishop, round valley pleasant valley, and one to ohv area etc.
pite…..Just like I’ve been saying….Once the foot gets in the door,look out !!!…..I’m sure the residents of Round Valley and Pleasant Valley are looking forward to this influx of “rider-guys” coming soon…..maybe…..to their pleasant(pardon the pun) little areas and their choice of quiet,rural living.Do they still have that major deer-migration… Read more »
It was the Ravens that did in the Tortoise in the Antelope Valley ‘Deja’.
Ravens and tortoises co-existed for thousands of years. As human populations increased the mobile omnivores such as ravens increased as well, due to being able to seek out food at dumps, campsites, along roads (people toss an apple core saying it is biodegradable, for example). Ever seen the ravens raiding… Read more »
Mark….Check the facts,buddy…..maybe the newborn tortoises had to deal with the ravens,but the majority of the grown -ups were driven away and killed by the “ORV” boys…..I’m busy today,so not time to get the facts posted here,….”Google” it and see the fight that takes place to this day trying to… Read more »
I’ll check it out Deja. As an avid off roader and owner of four wheelers and dirt bikes I believe the ATP will bring more people to ride in the area and have a direct negative impact on all trails and the environment. I’ve rode all those areas you mentioned… Read more »
There are signs now in the Westgate Pass, Little Cowhorn Valley, Deep Springs Valley, and Eureka Valley roads areas as well.
Ted is just another person in the long line of folks who want all off road vehicles banned in Calif. The proven way to do so is to eleminate riding areas. His “Air Quality” argument resonates with those who agree with his philosophy, for he effectively creates an image of… Read more »
I’ve never met Mr. Schade but the article states he’s been in his position for 24 years. 24 years of his life has been committed to monitoring and protecting the air quality for the residents and visitors of the OV. I hardly believe that he spent all that time and… Read more »
Adventure Trails is going to be a BIG money maker for Inyo County, at least that’s what we’re being told. Why would they be spending hundreds of thousand of dollars on it, just for locals, I dont think so. We’re talking promotion in outdoor mags, news stories in SCAL and… Read more »
I do think of Jawbone Canyon, (or any of the many other similar spots) and that’s exactly what I’m opposed to this idea. I don’t ride dirt bikes anymore, but I used to, and I’ve seen first-hand what happens with excessive use. And isn’t that the point, to market the… Read more »
I’m not disingenuous, a significant increase in usage will absolutely have an impact.
My biggest concern is erosion and trail damage due to people not staying on marked trails. The landscape never really does recover Jawbone is proof of that.
Mr Schade states “I have no opinion as to whether or not Inyo County should approve the Adventure Trails Project.” Yet he askes the Supervisors to make the right decision. The body of his letter gives me the impression he does have an opinion. I beleive the main point of… Read more »
That’s why he’s “Slime Shade.”
I read the whole letter but found it extremely strange, in the first paragraph Mr. Schade states “As the Air Pollution Control Officer, I HAVE NO OPINION as to whether or not Inyo County should approve the Adventure Trails Project.”…. Then in the last paragraph he states, “I would implore… Read more »
Take a look at the region between Ridgecrest, Randsburg, Red Rock Canyon and Cal City and then try to say with a straight face there will be no environmental impacts. The degradation of air quality in Fremont Valley on long weekends due to ORV dust is palpable, you can taste… Read more »
In response to Eastern Sierra Mom saying ‘ I hate to think of the dust that will be added to the playground they play in each day’ … So youre saying that your school is on a dirt road? If so, I think you have more to worry about than… Read more »
I’m going to start a new organization, it’s called Mothers Against People Having Fun! The cool part is you don’t have to be a mother to join. Just against all indoor and outdoor activities in which people gather to enjoy themselves.
But Trouble those entities already exist, and the acting players are; Law Enforcement and nosy neighbors. LOL.
But of course impacts to our environment is always a worthy conversation.
I’d join but it sounds like fun.
Trouble ….How about “MAOAPTUTLAW”…Mothers and others against people tearing up the land and wilderness..
How about figuring out that it’s already legal to ride on all these roads and has been forever. People just playing on peoples fears as far as I can see here. I think I’ll go stir up some dirt right now. All these dirt roads have been there for over… Read more »
Interesting this Air Pollution Control Officer doesn’t list any actual facts or numbers about how this air pollution will increase. how much air pollution can these things really produce? Additionally the people that own atv’s and motorcycles are already riding them so I really cant imagine that any new pollution… Read more »
The whole purpose of Adventure Trails program is to bring in new business and stimulate the economy in these small towns. I have not seen any numbers just heard the planners say at meetings “lots of money, significant increases in ATV visitors, and some of the end points in smaller… Read more »
Ask California City how it has worked for them?
Desert Tortoise….Better yet,ask how it worked out for the Desert Tortotise population there in Cal City…..no pun intended.
I was surprised to find that my child’s daycare is located on one of the streets proposed in this plan. I hate to think of the dust that will be added to the playground they play in each day. I’m even more concerned with the added noise that these kids… Read more »
Harley’s are louder then most wheeled OHV vehicles. Nearly every OHV’s also has USFS approved legal exhaust now days.
Unlike Harley’s which almost all have modified ‘illegal exhaust’ and exceed the noise limit and never get pulled over and cited for illegal exhaust.
USFS or other off road noise standards do not apply on the designated combined use routes. The EIR states that the Public Road standards from the Calif Vehicle Code apply. These are a lower decibel level. Users of the combined use routes must also be licensed with the appropriate class… Read more »
USFS approved spark arrestor mufflers also meet noise regulation standards
USFS, BLM, Calif Green or Red Sticker, and California Vehicle Code all specify a decibel level and monitoring method. What are they, how do the monitoring methods compare and what does the Adventure Trail EIR specify will apply on combined use segments?
Wayne, there are maximum decibel limits for all production vehicles including on road motorcycles, but they are routinely violated. Many of the “mufflers” one finds on motorcycles you encounter on the road will have something along the lines of “for off road use only” or “for closed course use only”,… Read more »
Deja I also think the County needs to address how they are going to guarantee the public that the ATP won’t be putting more uninsured motorist on our public roads. Checkpoints are not practical, and law enforcement can’t pull over vehicles and check for insurance without a reason. I guess… Read more »
Regarding Off Highway Vehicle insurance GEICO sent out a press release (just search on geico press release stay off paved roads). GEICO thinks that the vehicle is insured for OHV use, at the check point the owner shows proof of insurance card for the OHV. When there is an accident… Read more »
Mark….Very true….I’ve said the very same thing before…If LE does start stopping and checking for drivers licenses and insurance,here will come those in ORV land saying their “rights” are being violated….same with if they do have “check-points”…that and taking Law Enforcement off the highways and onto the trails baby-sitting these… Read more »
Based on what I can find under California law, Street legal cars and motorcycles produced after 1985 have to be lower than 80 db. (85 db is where you begin to see ear damage.) I’m not saying that all street bikes follow this law but I am saying that they… Read more »
There are several different plans that can be approved. If your really concerned about one street you ought speak up at the meeting on the 30th. They already took Hanby Ave off the chalk board, mainly because one one the main opposition leaders husband works for the county! I do… Read more »
Trouble….You say “very few people carry insurance on their quads”….O.K……Then what happens if one of those that doesn’t happens to cause a vehicle accident while riding on the proposed town streets ?…..Do we just suck-it-up and pay for the damage to our vehicle ourselves ?…or maybe waste some time and… Read more »
@Trouble, California has a population more than twelve times that of Utah. The two states are apples and oranges. It would be wonderful if CA had population less the 3 million like UT does, but it’s just not a reality. I’ve ridden in Utah many times and I’ve yet to… Read more »
Eastern Sierra Mom and Mark, the various agencies across Calif and the US have virtually given up on enforcing noise limits for street motorcycles. My perception tells me it’s possibly because the sheer numbers of bikes (hundreds of thousands) with modified exhaust, are simply overwhelming. That and other priorities have… Read more »
Law enforcement has looked the other way for years when it comes to illegal exhaust on Harley’s. Why do you think the OHV’s that will be driving down our streets will be louder? Any dirt bike made prior to 1995 is considered vintage and are rarely seen out riding in… Read more »
Those are the State decibel requirements for street versus off road. I think the federal decibel max is 91 on BLM land . The EIR fails to specify which level is to apply on public road combined use segments. The literature indicates that permanent hearing damage occurs at 90 to… Read more »
I don’t think noise will be an issue. But there are enough real issues to be concerned about the impact of the ATP. Most off roaders drive 4-strokes now days. Most manufactures use the same engines for street legal dirt bikes as they do off road only dirt bikes, meaning… Read more »
Please Slim Shade, your organization does nothing but fine companies and kill any businesses wanting to operate. I wonder if you ever worked in the private sector? You leach off the hard work and endeavors of others and through the process of fines (which is taken from people by force)… Read more »