SEMA Seeks to Protect “King of the Hammers” OHV Event at Johnson Valley, CA
August 27, 2012
Naval Facilities Engineering Command, Southwest
Attn: 29Palms EIS Project Manager
1220 Pacific Highway
San Diego, CA 92132-5190
RE: SEMA Comments Opposing Alternative 6: 29Palms Training Land Acquisition/Airspace Establishment Final EIS
Dear Project Manager:
The Specialty Equipment Market Association (SEMA) submits the following comments in opposition to Preferred Alternative 6 contained in the U.S. Marine Corps’ 29Palms Training Land Acquisition/Airspace Establishment Final Environmental Impact Statement (FEIS).
SEMA represents the $30 billion specialty automotive industry of 6,500 member companies. It is headquartered in Diamond Bar, California. The industry provides appearance, performance, comfort, convenience and technology products for passenger and recreational vehicles, including a variety of products for the off-highway vehicle (OHV) market. SEMA also coordinates the activities of the SEMA Action Network (SAN), a nationwide grassroots partnership of car clubs and individual enthusiasts who work together on legislative and regulatory issues that affect auto enthusiasts of all kinds, including the OHV community.
Approximately 189,000 acres of Johnson Valley OHV area is used year-round by OHV enthusiasts, as well as mountain bikers, equestrians, hunters and others. The area is home to numerous motorized-recreation events such as “King of the Hammers” that draw thousands of competitors and spectators every year. Under Alternative 6, the Marine Corps is proposing to incorporate 146,667 acres of Johnson Valley within the 29Palms Marine Corps base. Of that land, it would provide the OHV community with only limited access to less than 40,000 acres for 10 months a year.
SEMA has long supported working with the Marine Corps to reach a compromise intended to allow shared use of the Johnson Valley OHV area in a manner that satisfies the needs of all interested parties. Under Alternative 6, the Marines only need access to the Johnson Valley OHV area for two months a year for large-scale training maneuvers. Rather than taking ownership of the land, SEMA contends that the current land owner, Bureau of Land Management (BLM), is in a position to issue special use permits to the Marines, as is done for OHV events such as King of the Hammers. The BLM permit solution would guarantee continued shared access to the land by the Marines and the OHV community.
The Johnson Valley OHV area was created by the 1980 California Desert Conservation Plan. Only 2% of the California desert is currently open OHV area and Johnson Valley represents half of those motorized recreation opportunities. Under Alternative 6, the OHV community would lose access to 56% of Johnson Valley. Given that OHV recreation is one of the fastest growing categories of outdoor activity in the United States, especially in southern California, this proposal would represent a significant hardship to these users.
At least 200,000 visitors attend events at the Johnson Valley recreation area on an annual basis. The BLM estimates that OHV recreation at Johnson Valley contributes $71 million annually to the local economy while other OHV analysts place the estimate closer to $191 million. Permanent closure of much of the land by the Marine Corps is unnecessary and will impose a significant negative economic impact on the local economy.
The suggested solution of issuing BLM special-use permits to the Marine Corps provides additional benefits as well. It relieves the Marine Corps from having to post signage, install barriers, secure and patrol the land for the 10 months a year that it is not needed. The issue is not hypothetical. OHV users frequently enter the existing 29Palms Marine Corps base by mistake due to inadequate signage and patrols.
With a present size of 596,000 acres, 29Palms is the second largest military base in the world. The proposed expansion would make it the world’s largest base, exceeding nearby Ft. Irwin’s 642,000 acres. Rather than pursue land ownership, there is an opportunity to take a different approach and use BLM special permits to unite the two facilities for joint training exercises.
SEMA also recommends that alternative locations be identified for live-ammunition training other than on the Johnson Valley land. SEMA is concerned that the existence of ordnance, even non-dud producing ordnance, would be cited as a future reason for closing access to lands otherwise authorized for OHV activities. Already, an estimated 11 million acres of land across the United States (about the size of Florida) is currently restricted due to ordnance contamination.
Absent a decision to allow the BLM to issue special-use permits, more time is needed to investigate viable alternatives to the FEIS and to develop a workable solution for both the Marine Corps and the OHV community. Local and state authorities and thousands of citizens have already expressed this sentiment. Toward that goal, SEMA supports an amendment passed by the U.S. House of Representatives to the Fiscal Year 2013 National Defense Authorization Act (HR 4310) that requires the Secretary of the Navy to submit a report on the economic impact of the Marines’ land acquisition and alternative opportunities for land sharing and cooperation.
SEMA has partnered with several land-use organizations to advocate a mutually beneficial result to this proposed land acquisition at 29Palms/Johnson Valley. On behalf of our membership engaged in recreational and economic activity at the Johnson Valley OHV Area, we look forward to working with the Marine Corps and BLM to develop a reasonable alternative that maintains recreational access and military training programs.
Thank you for the opportunity to comment on the 29Palms Training Land Acquisition/Airspace Establishment Final EIS. Please do not hesitate to contact me if you have any questions.
Stephen B. McDonald
Vice President, Government Affairs
Specialty Equipment Market Association
202/783-6007, ext. 31; firstname.lastname@example.org