SUTA is providing information for those interested in submitting comments about the proposed target shooting safety closure for locations on Anderson Butte. Many of you may have been following this issue and previously received information and submitted comments on the Anderson Butte Safety Project Environmental Assessment that was issued earlier this year. At this time, notice of the proposed project has been published in the Code of Federal Regulations and announced a final public comment period. Public comments are due by 4:30 PM January 3, 2022. Following is the text of the email sent by Lauren Brown, the Ashland Field Manager for the BLM. The EA is available on the BLM’s e-planning site (select the -accessible copy of the EA to open or download).

BLM email notification text from Lauren Brown, Ashland Field Manager: I am writing to provide an update on the Anderson Butte Safety Project. I am excited to report that as of this morning (10/28/21), the long-awaited Federal Register Notice has published in the Federal Register. As you are aware, publication of this Notice and the associated comment period is one of the final steps in the requirements laid out by the Dingell Act when considering recreational shooting restrictions. The notice details the BLM’s proposed decision regarding restriction of recreational target shooting at specific sites in the Anderson Butte area, and also initiates the final 60-day comment period, at the conclusion of which, the BLM will issue the final decision. A link to the Federal Register is below:  

https://www.federalregister.gov/documents/2021/10/28/2021-23495/notice-of-proposed-restrictions-on-public-lands-in-jackson-county-or

The associated project documents are available online on the BLM’s National ePlanning register at:  https://eplanning.blm.gov/eplanning-ui/project/123432/510

If you would like to submit comments during this final 60-day comment period you can do so by one of the following methods: clicking on the Participate Now button on the ePlanning website; mailing comments to  BLM, Attn: Tye Morgan, 3040 Biddle Road, Medford, Oregon 97504; or emailing comments to BLM_OR_AFO_anderson_butte_sp@blm.gov

 (Subject: Anderson Butte Safety Project). For comments to be considered before a decision is made on this proposal, please submit them by 4:30 p.m. on January 3rd, 2022. 

During the proposed two-year restriction to recreational target shooting, the BLM will be monitoring recreation uses and site conditions to determine if target shooting restrictions resolve safety issues. The findings will help guide long-term solutions to these land management challenges. During this time we will also be continuing our ongoing on-the-ground efforts including law enforcement and recreational staff patrols. 

SUTA is submitting comments and provides the following notes for anyone interested in submitting individual comments. As always, if you have any personal experiences to relate that are relevant to the shooting that occurs on Anderson Butte please feel free to include them, they can help to emphasize all your comments.

We support the proposed safety closure of target shooting locations on Anderson Butte, and offer additional general and specific comments on the EA:

  1. General: There must be a strong monitoring and enforcement effort to ensure this closure can be effective. In addition to patrols by BLM law enforcement and/or Jackson County Sherriff’s department, surveillance cameras are recommended to document any continued unsafe shooting activity. This is not described in any detail in the EA and if there is no mechanism established for increased law enforcement, the closure will be ignored by some target shooters. Monitoring and enforcement plans, and pursuit or allocation of funding for law enforcement patrols must be clearly described in the ROD.

There must be a clear and well-publicized process for residents or recreation users to report continued unsafe activities to BLM and/or Jackson County Sherriff’s Department, and for law enforcement to rapidly respond to any reported incidents. The signs posted in the area should provide a phone number for law enforcement to make it easier for members of the public to report unsafe activities. Due to the limited closure, and the fact that shooting can still occur at other locations nearby the closed areas, it is likely that continued incidents can be reported only if individuals directly observe illegal activities.

  • Closing only the most frequently used target shooting locations will only be likely to push target shooters to other areas. This was not analyzed in the detailed analysis in the EA with the justification that it cannot be known what impacts the closures may have with regard to shooters moving to other locations on Anderson Butte, but unsafe shooting at locations other than the 11 areas planned for this closure has been observed and reported previously. This includes instances where target shooters simply stop in or along the road and select a random target (tree, gate, etc.) without regard for the presence of trails, residences, or a suitable backstop or any backstop at all. In some cases, this has included shooting across the road. For this reason, we recommend increased patrols by BLM and Jackson County law enforcement to monitor conditions on the ground after the closure order goes into effect to discourage unsafe practices. In addition, providing information to local residents and users of the public roads and trails about how to report any observed continued unsafe activities either within the closed areas or other locations where these activities may occur elsewhere on Anderson Butte.
  • Section 3.1.4. This planned closure would be in effect for only 2 years. Considering that it has taken well more than 2 years for this EA to be completed, planning for a permanent solution to this issue must begin immediately. There is little information beyond a brief discussion in Section 3.1.4 noting that once the restriction expires (in 2 years), conflicts are likely to return if no future actions are proposed and that a RAMP may be considered as part of moving toward a permanent solution. The language of the ROD should provide additional description and present specific actions that will be undertaken to reflect BLM’s commitment to developing a long-term resolution to this public safety issue.  We appreciate the fact that this is a sensitive and controversial issue, however, the risks to public safety must take precedence.
  • Section 1.1, Public Education. There will need to be a strong public education component to this closure to reinforce the need for taking this action, as well as clearly describe what comprises a safe shooting location. This must emphasize that the closure is a public safety issue, and not a 2nd amendment issue. Nobody would be prohibited from lawful possession of a firearm. Education is mentioned in passing in Section 1.1, but no additional detail is included in the proposed action description.
  • Section 1.7, #7, pg. 10. The statement in the EA text about either alternative not causing any restrictions to access to user-created OHV trails and officially approved non-motorized trails fails to point out that the closure alternative will significantly alter how many people use the Jack-Ash Trail. There have been numerous reports from people who came up to hike on the trail, and experienced unsafe target shooting at trailheads or while on the trail and said they would not come back until the unsafe shooting issue was resolved.  Therefore, under the closure alternative it is highly likely that all other recreational use on Anderson Butte under a successful closure would increase. The BLM owes it to themselves and to the public to support the trails on Anderson Butte since recreation is such an important part of life for residents and visitors to the area, and for the local economy.

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