November 7, 1997
Pete Wilkins
Grand Staircase-Escalante National Monument Planning Office
Bureau of Land Management
337 South Main
Cedar City, Utah 84721
SUBJECT: Grand Staircase-Escalante National Monument Management Plan and EIS
Dear Mr. Wilkins:
The Resource Development Coordinating Committee (RDCC), representing the State of Utah, has reviewed this proposal. State agencies' comments are as follows:
Utah Geological Survey
The Utah Geological Survey has three principal recommendations to the BLM concerning the management of the Grand Staircase-Escalante National Monument (GSENM).
1. Focus on Science: the monument was created for its scientific values; make it easy for scientists to work there and promote scientific endeavors in the monument.
The Presidential proclamation created the monument largely for its scientific attributes. The GSENM can serve as an international outdoor natural laboratory for geology, archeology, and the various branches of biology and ecology.
The economic benefit to local communities from scientific teams that spend weeks, months, or many field seasons in the area and their infrastructure needs could be significant, especially compared to drive-through tourism and camping.
2. Make it a 'working monument': allow development of the coal, oil, gas, and other minerals in the monument and divert the federal share of royalties to a trust fund for the benefit of the nation's parks and monuments.
The GSENM is unique in having a producing oil field on federal lands within its boundaries and in being managed by a multiple-use agency. Take advantage of the vast resources and this unique situation to create a legacy for the entire park system. Creation of a trust fund would require congressional action. The BLM can accommodate that by including the potential for mineral development in its master plan.
Full development of the Kaiparowits coal field would generate an estimated $220-330 billion in resource value produced (based on the product of current prices and all mineral resources within the monument and assuming all development occurred today), resulting in $9+ billion in royalties to the federal government, and an equal amount to the state of Utah.
3. Establish national strategic resource reserves: if mineral and energy development is not allowed in the near term, set aside prime areas for use in time of national emergency.
Congress would need to establish a National Strategic Coal Reserve, a National Strategic Petroleum Reserve, and a National Strategic Mineral (titanium) Reserve inside the monument, to be tapped by Presidential order in a national emergency. The BLM would need to consider that potential in its management plan and adopt management policies that would not hinder or preclude those uses, when required.
Division of Parks and Recreation
1. Since NEPA is a data based decision making process, begin compiling data now in cooperation with state and local agencies as part of better, more well informed decision making. While it is unknown if this is a problem, recreational use data is oftentimes not collected in sufficient quantity relating to OHV use, Visitor needs and expectations, economic and resource impacts, etc to make well informed recreation management decisions. Consider partnering with the Utah Division of Parks and Southern Utah University to begin measuring recreational demand and impacts both within and adjacent to the monument at recreation sites such as Escalante, Kodachrome, Coral Pink Sand Dunes and Anasazi State Parks through social surveys. Also consider carrying capacity analysis to understand developmental thresholds as well as social thresholds related to planning for the monument.
2. Off-Highway vehicle use is a longstanding use in the monument for both animal husbandry associated uses as well as recreational activities. OHV use is a valid and existing right and must be proactively planned for. This includes:
Transportation planning needs to include loops for OHV use.
OHV use should be adequately provided for, based on present use levels in the monument boundary. Utilizing grants and partnershipping with the Utah Division of Parks to identify riding areas/ trails, fund trailheads and disseminate information as a means of educating users and protecting resources.
Consider OHV use adequately to include special populations such as the elderly, the disabled (ADA), and all types of recreation activities including motorized.
3. Impacts to the Utah Division of Parks and Recreation units, in proximity to the monument, are somewhat anecdotal but data is available to support the concern as follows:
Escalante State Park has experienced a 29.6 % increase in visitation for the nine months October to June of 1997. Coral Pink Sand Dunes State Park has experienced an increase of 12.3% and Kodachrome State Park has experienced a 6.8% increase in visitation for the same time period. This occurred in the face of dropping visitation at both Bryce Canyon (-11%) and Southern Lake Powell (-14%) and a very strong dollar valued against the German mark. Germans make up a large percentage of the out of state tourist profile (50% last year) and state park managers are reporting a noticeable drop in German tourists this season.
Currently the occupancy rate at Kodachrome State Parks campground is 27.5 units per night. The capacity of that campground is 27 sites plus 2 group sites. The issue of the parks being at capacity during the peak and shoulder seasons is proven. Increased visitation to the park will undoubtedly occur and there needs to be consideration for some mechanism to jointly expand park infrastructure while also addressing development and visitor needs within the monument. This idea also needs to be considerate of entrepreneurial (private) development opportunities.
State Park staff answer many questions about the monument daily. They also documented responses to emergency situations within the monument. The BLM should consider offsetting current expenses incurred by state parks or at the very least provide park staff with printed materials for distribution as a means of providing accurate information to help visitors make informed decisions about what to do in the monument and the level of risk they are exposed to. This should occur immediately until the BLM has staff in place to better address these issues.
The general public already have a hard time distinguishing between Utah State Parks and the Bureau of Land Management. Many visitors to the area do not recognize boundaries and/or agency differences. For this reason we have the obligation to work more closely and partnership more effectively through whatever means available. Consider partnering with other agencies and entities to meet common goals and/or similar goals. This could include the joint development/expansion of campgrounds and interpretive programming to accommodate demand while educating tourists about the monument experience while minimizing physical development within the park.
4. Focus on customer needs and expectations before planning, during planning and during implementation. This relates to point number 1, above but also relates to consistent tracking of resource condition, trend, and use. Any planning must discuss how resources will be monitored and how plan amendments will be made relevant to new resource information. "Resources" as used in this discussion, refer to cultural, natural or physical resources. Compilation and monitoring of resource condition/trend will be important to analyzing cumulative effects, understanding secondary effects and acknowledging the uncertainty related to resource management issues and proposed actions. Also make resource studies, which are not considered proprietary, available to agencies and the general public as part of enhancing knowledge of those resources.
5. Plan to utilize extant capital investments such as roads, state parks, USFS/BLM facilities to reduce physical impacts within the monument.
6. Recognize that the local culture is part of what defines the monument, including historical land uses. Basically, please plan as though man were part of the ecosystem considering the human community structure as well as socioeconomic. Provide for resource conservation (use) along with preservation as a means of sustaining an economically stable climate for the culture to survive in.
7. Develop a backcountry permit and fee system now to help address impacts and costs with user groups who have not traditionally been helping to offset recreation management costs. This includes permits to compile data such as tracking areas of use, measuring resource impacts and identifying mitigation/development measures.
8. Consider air quality issues as part of viewshed protection in all transportation planning. Studies consistently show that scenic beauty is an important component to a good recreational experience and consider air quality degradation as part of resource development planning.
Division of Water Quality
We have only relatively brief and general suggestions to make at this time as you undertake this important planning effort.
First, there may be major impacts on the immediately surrounding small communities from the growth and tourism that will be generated by the Monument. We suggest that these impacts be fully considered and evaluated, especially with respect to the limited water and wastewater infrastructure of these communities. Some communities may need to consider relatively expensive new or expanded community-wide wastewater disposal systems in the future to adequately protect ground water and public health.
Secondly, we remind you of the importance of protecting water quality in and around the Monument to maintain State water quality standards and protect the beneficial uses of water for fisheries, recreation, irrigation and drinking water supply. These water quality standards include the basinwide salinity standards for the Colorado River Basin.
For your information, we are currently conducting an intensive monitoring survey of surface water quality in the area of the Monument, to be completed in June 1998, as part of our watershed management approach. We will be happy to share any of our water quality data with you. We will be preparing a water quality assessment shortly after completion of the monitoring, and we will be inviting your agency's participation in the review of that assessment report. We would also anticipate jointly preparing management plans to address any water quality problems that may be identified in that assessment.
We will be interested in following the progress of your planning effort, and will provide more detailed comments at appropriate future times as the planning proceeds.
Division of Water Rights
The Division of Water Rights issues three comments with regard to GSENM scoping:
First, make sure that valid water rights inside and adjacent to the GSENM are not impaired and the right holders enjoy full access rights for repair and maintenance as per the executive order.
Second, ensure that any needed data sites will be allowed in the GSENM as per the executive order.
Third, the towns of Tropic, Henrieville, Cannonville, and (to a lesser extent) Escalante and Boulder are starting to experience growth as a result of increased tourism. To allow this growth to continue, they will need access to water. As a last resort, they need to have access to resources in the outer fringes of the GSENM. Accommodations should be made to facilitate this access.
Division of Water Resources
The Division of Water Resources notes that future water storage needs for the may have been impaired by designation of the GSENM. Consequently, the Division suggests that future storage needs be identified and considered in the scoping process.
Utah Division of Wildlife Resources
The enabling legislation for the Grand Staircase Escalante National Monument is explicitly clear that the State maintains the right to manage the wildlife resource and hunting and fishing . It is important that planning decisions do not dilute that ability. UDWR is particularly concerned that a full range for our ability to stock, transplant or reintroduce wildlife be maintained.
UDWR is optimistic and expects that BLM will take necessary action to insure that sufficient instream flows exist to maintain and enhance riparian habitats as, well as associated aquatic and terrestrial biota. Of course, all additional water allocations must be done pursuant to state water law. Protection and consideration to enhance habitats for insects, mollusks and the full array of vertebrates must be planned. Additionally, BLM must plan to maintain or improve terrestrial habitats, providing opportunity for sensitive plant management and vegetation manipulations in order to manage selected areas at a desired seral stage.
There is no question that future activities, particularly man-made developments, within the Monument will challenge the wildlife resource and its habitats. The Monument's Management Plan must be flexible and dynamic to ensure a safe future for wildlife. Current challenges revolve around appropriate access and road management along with mineral development. The Plan must provide opportunity to mitigate for impacts to wildlife and habitat, when impact avoidance or minimization practices cannot be achieved.
Utah Department of Agriculture and Food
The Utah Department of Agriculture and Food strongly supports the ability of Utah livestock owners to continue their historic use of grazing lands within Garfield and Kane Counties situated within the Grand Staircase -- Escalante National Monument. Such continued use of the land thereby preserves the local custom and culture established more than a decade ago.
The inability of cattle and sheep ranchers to use traditional grazing lands currently included within the National Monument would force ranchers to rely on more costly feeding methods, and would contribute to the bankruptcies of numerous family-owned livestock operations.
The cattle and sheep industries in Garfield and Kane counties generate more than $11 million in revenue, and are major economic forces in the region. Eighty-five percent of the agriculture revenue generated in Kane and Garfield counties comes from the livestock industry.
Statewide, Utah's livestock industry contributes more than $600 million of the $838 million in raw farm products produced in Utah.
Continued livestock grazing within the National Monument supports the department's philosophy of renewing our natural resources through appropriate and managed harvest practices.
Utah Division of Travel Development
Using the Scoping Worksheet format distributed by the BLM in the Visions Kit, the Division proposes strong consideration of the following for the monument plan:
Section 1 - VALUES
Creativity and Innovation
We believe the times dictate that non-traditional methods of management, joint decision making, and partnerships be employed to create a unique experience for economic gain, individual discovery, and resource protection. We also believe this value is shared by the monument proclamation's authors and by the decision to assign management responsibility to the BLM
Innovative management concepts include:
-Joint operation of visitor information facilities to include guide sign-up counters, interpretive materials and locally produced crafts for sale. Other light retail and commercial activities should also be considered. Among the benefits of including commercial partners is their contribution to the facility's maintenance and operations costs.
-Transparent boundaries to avoid the stark contrasts that occur between gateway corridors and protected land. Instead the key themes of the monument should be consistently applied in design standards set jointly between monument and non-monument corridors. Ideally (and creatively) the visitor's "sense of arrival" occurs before the monument boundary is encountered, ensuring a smooth transition to sensitive areas.
-Scientific research is integrated into the visitor experience in at least two ways: 1) Research and data collection and interpretation would be conducted in open laboratory conditions where visitors and scientists have opportunities for daily interaction, and 2) Delivery of papers, colloquial symposia, and other scientific conferences should be conducted in a destination think-tank environment such as the Aspen Institute.
Destination Development
There is considerable economic justification for a monument plan that prefers the destination model to a "windshield," or pass-through visitor experience. This represents higher quality earnings for local communities, higher quality jobs for local residents, better visitor management, lower impacts on the resource, and the development of a sense of place.
Discovery and Recovery
The Division's qualitative research has identified a strong visitor motivation for learning about and developing an appreciation for the monument's unique natural environment and the charm of surrounding local cultures. This is coupled with the need for escape from the stresses of modern, urban lifestyles. Representing those consumers as stakeholders, we support those values for monument planning consideration.
Historic landscapes
The monument is rich in historical resources. These histories are the base of the interesting stories that will be told in a marketing vein as a key to visitor enrichment and community earnings. Some of these historic themes include ranching heritage, water and range conservation, pre-Columbian life, film making, the National Geographic caravan, and mining.
Pay-to-Play
The value of an attraction, respect for the resource, and the development of a sense of ownership and place are all enhanced when the user pays a fee for access. This helps mitigate the costs of visitor management and service provision. Dynamic fee management will also serve as a control mechanism to reduce use in highly sensitive areas . Fairness dictates that recreational users pay a share along with livestock grazers and mineral extractors.
Modest Scale and Exclusivity
Though not necessarily popular, it is important to establish a monument ethic that discourages mass visitation and large scale development. This coincides with the natural environment which cannot tolerate hordes. It will convey to the monument a special status that will serve as a differential advantage and will protect it from being trampled to death.
Section 2 - PURPOSES AND MANAGEMENT
The monument should be managed as a multiple use, multi-zone partnership between public and private stakeholders. At least three zones of access should be identified with corresponding fee differentials. Issue permits for all uses.
Zone 1 - Open access - accompanied and unaccompanied
Visitors using Zone 1 would be offered self-guided interpretive trails, highway turnouts, short term horseback trail rides, hunting, and limited overnight use. The emphasis is on first time or first day use. It is also meant to accommodate windshield tourists by offering an introduction to monument themes and allowing them to be on their way to elsewhere.
Zone 1 non-recreation uses include livestock grazing, mineral and fossil fuel extraction, and general exploration. Roads and motorized vehicles would be permitted though paving should be avoided. If absolutely necessary, paved roads should loop and return to their origination point. Under no circumstances should paved roads transverse the monument.
Zone 2 - Limited access - mostly accompanied
The emphasis here is on a high quality visitor experience with key elements of discovery and recovery provided by a certified local guide/outfitter. Though on land, the management model here is federally managed river recreation where a combination of space limitations, leave no trace, and customer convenience yields to a preference for the interpretive guide. Experienced users could qualify for unaccompanied access but would have to demonstrate, in a permit application, a proficiency to provide for their limitedby-size party with all traces of their use removed.
Scientific exploration and guided hunting would be allowed as above but grazing and mineral extraction would be prohibited in Zone 2. Roads and motorized vehicles would be discouraged; to be used only in special cases.
Zone 3 - Extremely limited - accompanied use only
For sensitive, truly wild lands, party size would be limited and use of a guide/interpreter would be mandatory. Roads and motorized vehicles would be disallowed and in all considerations, a higher level of protection than the current wilderness standard would be required. Accompanied scientific access would be allowed. Hunting would not be permitted.
Section 3 - COMMUNITY
The Division's submission in the values section above suggests a preferential role for the monument's local communities. They hold the key to the integration of the human elements with scientific values. They are the content providers and the story tellers. They own the folklore which should be as protected under federal law as any other intellectual property.
Members of the monument's local communities also play a key role as stewards. They will provide the necessary services and human resources. For taking business risks as well as stewardship responsibilities, they should be eligible for a greater share of the financial rewards.
Under the direction of a Joint Management Trust, local communities should be full partners with the BLM for monument management.
In addition to being right and proper, it will be necessary to engage in local financial partnerships because Congress seems unable to provide for the comprehensive management, maintenance, upgrades, capital refurbishing, and operational expenses for such a vast tract of landscapes.
Section 4 - OTHER CONCERNS
•Search and Rescue
Mentioned often as a burden on local communities, we would be well advised to explore creative solutions and utilize the monument planning process as a laboratory for innovation.
In this case, a perfect opportunity exists while issuing permits and collecting fees to offer optional search and rescue insurance. This gives notice that access has some risks and those electing not to pay the premium will sign an admission of responsibility for search and rescue costs. Those who elect to pay the modest premium will, upon a claim of service, will have the search and rescue costs paid by the underwriter. This puts the responsibility on the user rather than on the government, local or otherwise.
•Theme Coordination
To avoid duplication and unhealthy community rivalries, consider matching monument themes with individual communities. Also consider certifying local communities and providing a package of rewards for use of monument themes in planning & zoning, architectural standards and building codes.
•Coordinate the transition between the monument and it's neighboring attractions.
Planning attention should be paid to the design of a transition between the Grand Staircase/Escalante National Monument and Kodachrome State Park, Glen Canyon National Recreation Area and Capitol Reef National Park.
School and Institutional Trust Lands Administration
The School and Institutional Trust Lands Administration has the following comments regarding the future planning and management of the Grand Staircase - Escalante National Monument:
A. Trust Lands Status
The exterior boundaries of the Grand Staircase - Escalante National Monument (the "Monument") enclose approximately 1.9 million acres. Of this area, the School and Institutional Trust Lands Administration (the "Trust Lands Administration") manages over 176,000 acres of fee lands, together with an additional 24,000 acres of mineral estate where the surface is owned by others. These school trust land inholdings make up approximately 1/9th of the Monument, generally in the form of square mile sections scattered throughout the Monument.
Congress expressly granted the school trust lands to the State of Utah for the support of public education. The United States Supreme Court has referred to this land grant as a "solemn compact" between the United States and the State of Utah. The grant has also been held to constitute a trust to which standard trust principles apply. As grantor of the trust, the United States is bound to act "for the support of common schools" that were the beneficiaries of the grant.
The State of Utah has a legal duty to manage the trust lands in the most prudent and profitable manner possible for the financial benefit of the state's public schools. The Trust Lands Administration is therefore required to maximize the commercial gain from trust land uses consistent with long-term support of the trust beneficiaries. In furtherance of this goal, permitted activities on trust lands within the Monument include mineral leasing and development, recreational subdivision development, grazing, rockhounding, surface leasing for commercial activities, and land sales to private entities.
The Trust Lands Administration recognizes that many of activities on trust lands will directly conflict with the purposes for which the Monument was established. It is the strong desire of the Trust Lands Administration to exchange all of the existing school trust lands out of the Monument for federal lands of equivalent value, but lesser environmental sensitivity, elsewhere in Utah. In this regard, the Trust Lands Administration welcomed President Clinton's promise that "creating this national monument should not and will not come at the expense of Utah's children" and the President's directive that the Secretary of Interior create an exchange working group to facilitate such an exchange, and resolve all reasonable differences in valuation in favor of the State.
A successful exchange of the school trust lands out of the Monument would eliminate the direct conflict between Monument "values" and the Trust Lands Administration's legal duty to manage the hundreds of scattered school trust parcels for commercial gain. A unified planning process could then proceed for the Monument without the uncertainty and huge potential impacts associated with the trust lands.
Conversely, the Monument planning process is doomed to failure if trust lands are not considered. The Trust Lands Administration's legal right to access to its scattered holdings, ongoing development of mineral leases, commercial activities, and land sales are all factors that could dramatically impact Monument management. Yet the BLM has stated that it will defer to a process outside the Monument planning process the question of state lands inholdings, thus ignoring all activities that will otherwise occur on those lands. This is the equivalent of trying to create a comprehensive plan for urban development where one of every nine city blocks is exempt from zoning -- it makes the entire planning endeavor almost pointless. Unless the school trust inholdings issue is addressed, the ultimate Monument plan will be inadequate and ineffective.
The Trust Lands Administration accordingly believes that pursuit of a successful exchange of state school trust lands out of the Monument must be one of the primary goals of the Monument management team and the Department of Interior during the planning process.
Unfortunately, the Department of Interior has yet to create the promised exchange working group, or to agree even to commence exchange negotiations. In recognition that an exchange of trust lands out of the Monument may not occur, the Trust Lands Administration submits the following comments with respect to the Monument planning process:
1. The Monument Plan Must Provide for Continued Access to Trust Land Inholdings.
Federal courts have ruled that access must be allowed "to the state school trust lands so that those lands can be developed in a manner that will provide funds for the common schools." Furthermore, such access to trust lands "must be allowed by the [United States] which is not so narrowly restrictive as to render the lands incapable of their full economic value."
Additionally, the Monument Proclamation states, "[t]he establishment of this monument is subject to valid existing rights." Valid existing rights include trust lands, active mineral leases, RS 2477 rights-of-way, mining claims, and Recreational and Public Purpose (R&PP) leases. Holders of these rights have legal rights to extract and remove minerals, build, repair and upgrade roads, and any other activities necessary for the realization of the valid existing right. Therefore, the Monument management plan must include the maintenance of existing access routes, and incorporate and facilitate the establishment of additional transportation corridors, and access and utility corridors. Accordingly, the Monument management plan:
The Monument management plan must honor and adhere to the language contained in the Monument Proclamation. The Trust Lands Administration is concerned by BLM's rewording of, or adding to, the Monument Proclamation's language in its Interim Management Guidance document and in BLM Monument newsletters. In particular:
The language contained in the BLM Interim Management Guidance document stating that valid existing rights will be recognized fails to adequately represent the intent of the Monument Proclamation. Accordingly, the Monument management plan must not incorporate the language in the BLM Interim Management Guidance document, but must adhere to the specific language of the Monument Proclamation that the Monument is "subject to valid existing rights." The Monument management plan cannot and should not impose any restrictions upon any valid existing right.
This attempt to impose additional restrictions upon such uses exceeds the intent of the Monument Proclamation, and should not be incorporated into the Monument management plan.
The United States Geological Survey has estimated that the coal reserves within the Monument exceed 62 billion tons in-place, of which 11.3 billion tons are estimated to be economically recoverable. In A Preliminary Assessment of Energy and Mineral Resources Within the Grand Staircase - Escalante National Monument (January 1997), the Utah Geological Survey estimated the gross value of the mineral resources within the exterior boundaries of the Monument (using 1997 prices) as:
Coal $221 billion to $312 billion
Coalbed Methane Gas $2 billion to $17.5 billion
Petroleum $20 million to $1.1 billion
Other minerals $4.5 million - unknown
Precise estimates of the gross mineral value specifically attributable to the trust land inholdings are not currently available. Rough estimates would indicate that the value of these trust lands would be in the neighborhood of 1/9th of the total value of the mineral resources within the Monument, because the trust land inholdings comprise approximately 1/9th of the lands within the exterior boundaries of the Monument.
Both federal and state mineral leases have been issued within the exterior boundaries of the Monument, including federal and state coal leases. These mineral leases constitute valid existing rights. The Monument Proclamation declares that the Monument is "subject to valid existing rights," which gives priority to such rights. The holders of existing mineral leases have the right to construct surface and underground facilities, to obtain access and utilities corridors for roads and transmission lines, and ancillary rights such as the right to subside the surface through underground coal mining.
To ensure that these valid existing rights are not infringed upon, the Monument management plan must allow unhindered exercise of such rights. Guiding Principle No. 8, which states, "[t]he Monument plan will describe activities that are compatible with the Monument's varied ecosystems," incorrectly implies that BLM has the authority to restrict any development right associated with a mineral lease that BLM believes is incompatible with the Monument's values. The Monument plan should not impose any regulations which attempt to restrict development of any existing federal mineral lease within the Monument.
The BLM Preliminary Planning Criteria dated August 14, 1997 state that the Monument plan will be completed under the planning authority of the Federal Land Policy and Management Act ("FLPMA"). The BLM newsletter dated July 9, 1997, implies that FLPMA land-use plans only require addressing areas of environmental concern. For example, the BLM newsletter indicates FLPMA requires land-use plans to "[g]ive priority to the designation and protection of areas of critical environmental concern." In creating the Monument management plan, BLM must adhere to all provisions of FLPMA, such as:
The BLM newsletter dated July 9, 1997, indicates that Wilderness Study Areas ("WSAs") will be managed "to ensure that their potential wilderness values are not impaired." The Trust Lands Administration recognizes the validity of the non-impairment management standard. However, pursuant to FLPMA, this non-impairment management standard is only applicable to those lands that have been officially designated by BLM as WSAs. Consequently, those lands under consideration for wilderness designation pursuant to H.R. 1500, which have not been officially designated by BLM as a WSA, are not subject to the non-impairment management standard. Accordingly, the Monument management plan must honor the language and intent of the Monument Proclamation and manage such H.R. 1500 lands under the principles of multiple use.
The Monument Proclamation states that BLM shall manage the Monument "pursuant to applicable legal authorities." Therefore, the Monument planning process must comply with all applicable laws, including the National Environmental Policy Act ("NEPA"), FLPMA, the Mining Law of 1872, the Mineral Leasing Act, other applicable statutes, and judicial interpretations of those statutes.
The Antiquities Act authorizes the President to declare "historic landmarks, historic and prehistoric structures, and other objects of historic or scientific interest that are situated upon the lands owned or controlled by the Government of the United States to be national monuments." It is clear from the language of the Antiquities Act that a national monument designation applies only to "objects" situated upon federal land, and not to the federal lands themselves. Accordingly, any national monument designation pursuant to the Antiquities Act only protects specific ascertained objects, not general unknown resources. Therefore, any restrictions imposed by the Monument management plan must be directed at those objects specifically identified in the Monument Proclamation, and not imposed generally upon the federal lands within the exterior boundaries of the Monument for the purposes of non-Monument values such as wilderness.
The Trust Lands Administration is sensitive to community concerns that commercial development be localized in or near existing communities outside Monument boundaries. A number of trust lands parcels within the Monument are located in proximity to these communities, and the plan should recognize that development may occur on these parcels. However, the plan should also recognize that as trust lands deeper within the Monument are sold off or leased over time, other non-mineral development (individual cabin sites, backcountry lodges, etc.) will also occur. Planning consideration should be given to such development, including road access needs, utilities, emergency services, etc.
9. Traditional Lifestyles of Area Residents, Including Grazing, Should Be Maintained.
The communities surrounding the Monument should not bear the expenses associated with the Monument. Costs associated with tourism-related impacts created by the Monument, such as water and sewage treatment, garbage removal, and search and rescue, should be reimbursed through federal grants. In addition:
Governor's Office of Planning and Budget
The Governor's Office of Planning and Budget believes that the Bureau of Land Management (BLM) should construct at least one alternative which captures local cultural and historical values. Included in this alternative would be elements such as:
It is also important for the monument plan to recognize the monument as a showcase for environmental planning and intergovernmental cooperation. It should be thought of as a model for future state and federal partnerships and other multi-jurisdictional efforts, and should be sensitive to the unique demographic and economic circumstances of the area.
The management plan should outline very detailed alternatives and be specific about what uses are allowed or not allowed within them. In other words, it should be very clear to the public what the various alternatives mean for specific geographic areas, including what can and cannot be done in these areas.
Finally, the Governor's Office of Planning and Budget would like to see the monument management plan include a bold new equitable user entrance fee system, where entrance fee revenues are shared by local governments being impacted by the monument and also used for maintenance of the resources within the monument.
The Committee appreciates the opportunity to review this proposal. Please direct any other written questions regarding this correspondence to the Utah State Clearinghouse at the above address or call Carolyn Wright at (801) 538-1535 or John Harja at (801) 538-1559.
Sincerely,
Brad T. Barber
State Planning Coordinator