Bureau of Land Management
GSENM RMP Project Manager
BLM Paria River District
669 S Highway 89A
Kanab, UT 84741
RE: Grand Staircase-Escalante National Monument RMP (DOI-BLM-UT-P010-2022-0006-RMP-EIS)
Dear BLM Planning Team:
Please accept this correspondence from the above organizations as our official comments regarding the Grand Staircase-Escalante National Monument (GSENM) Draft Resource Management Plan (DRMP).
1. Background of Our Organizations
In our comments, the “Organizations” will refer to the following four groups:
Colorado Off Road Enterprise (CORE) is a motorized action group based out of Buena Vista Colorado whose mission is to keep trails open for all users to enjoy. CORE achieves this through trail adoptions, trail maintenance projects, education, stewardship, outreach, and collaborative efforts.
The Colorado Off-Highway Vehicle Coalition (COHVCO) is a grassroots advocacy organization of approximately 2,500 members seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of off-highway motorized recreation throughout Colorado. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations.
Ride with Respect (RwR) was founded in 2002 to conserve shared-use trails and their surroundings. Since then, over 750 individuals have contributed money or volunteered time to the organization. Primarily in the Moab Field Office, RwR has educated visitors and performed over twenty-thousand hours of high-quality trail work on public lands.
The Trails Preservation Alliance (TPA) is an advocacy organization created to be a viable partner to public lands managers, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of motorized trail riding and multiple use recreation. The TPA acts as an advocate for the sport and takes necessary action to ensure that the USFS and BLM allocate a fair and equitable percentage of public lands to diverse multiple-use recreation opportunities.
2. Introduction
The GSENM encompasses a vast area with over a thousand miles of motorized routes that are of high quality for responsible riding and driving. In addition to providing access to remote places of varied geology among other resources, the motorized routes provide opportunities for exploration, a sense of harmony with nature, camaraderie with one’s group, and even some exercise or challenge from the roughest routes. These primitive routes and even the graded roads to some degree are the very types of opportunities described in Proclamation 10286, which states “The Grand Staircase-Escalante region retains the frontier character of the American West, providing visitors with an opportunity to experience a remote landscape rich with opportunities for adventure and self-discovery.”
3. Context of National Monument Designations
The designation of GSENM, then scaling it back, and most recently expanding it were quite political acts, and this context should not be ignored when revising its RMP. On January 16th, 1997, Deseret News published “Making a Monument” that stated:
When BLM state director Bill Lamb announced [the appointment of Jerry Meredith as Monument Manager], he seized the occasion to speak in conciliatory tones to those who opposed the preserve, suggesting long-established land uses such as grazing and hunting will continue beside “various types of recreation” in the area.
“We have an opportunity, if not the obligation, to try to build something completely new and fresh here – something that adds diversity to the forms of land management heretofore found on the federal lands of the West,” said Lamb.
“If we do it right,” he said, “(the monument will) protect some of the most remarkable land on Earth while sustaining the cultural identity that makes the region so special and rare. We just need to work together.
Accommodating various types of recreation and forging a different path than the NPS has done with national monuments took a setback shortly thereafter, as the BLM attempted to prohibit OHV use of graded roads, similar to the NPS policy in national parks (although NRAs now allow OHV use). In fact, back then GSENM staff discouraged some of the Organizations’ members and contributors from riding routes designated open in the 2000 MMP even though their motorcycles were registered for interstate highway use. This attempt to ban OHVs and discourage registered motorcycles failed but, over two decades later, the DRMP attempts to adopt a much more concerning aspect of NPS policy, which is route density. At least one of the DRMP alternatives for OHV area designations would almost certainly result in a route network that’s as sparse as the ones in each district of Canyonlands National Park.
Meanwhile there’s cognitive dissonance south of GSENM in the Baaj Nwaavjo I’tah Kukveni National Monument that was designated just a few months ago. On August 17th, 2023, the Moab Times-Independent published “Biden’s new Arizona national monument exposes Grand Canyon-like divide between supporters and critics” that stated:
Amber Reimondo, energy director for the environmental nonprofit Grand Canyon Trust, said such assertions are just plain wrong. She said the monument will not involve the seizure of private property, threaten existing livestock or water rights or limit access to recreation.
“If these [claims] were true,” she said, “they’d have legitimate ground to stand on. But they are just not true.”
So Baaj Nwaavjo is touted to not limit access to recreation while GSENM would further limit access to recreation, and dramatically so. It’s not too late for GSENM planners to prove the Grand Canyon Trust representative or the former BLM state director right. Fix the DRMP to provide far more diverse recreation opportunities than Canyonlands National Park provides.
4. OHV Area Designations
The Organizations are very concerned by the extent of areas proposed to be closed to OHV travel in all three action alternatives, which would force the subsequent travel planning to severely reduce motorized recreation opportunities that are already lacking when one considers the sheer expanse of GSENM. All three action alternatives would force the closure of some motorized routes by zoning their locations are closed to OHV travel. This enormous impact of travel planning isn’t even addressed let alone analyzed at the route-specific or cumulative scales, which violates NEPA and hampers our ability to meaningfully review and comment. Even where the route is “cherry stemmed,” boundaries are so tight that it sort of straitjackets the route and hobbles potential management actions such as a reroute. Further, the closed area designation prohibits even the mere consideration of adding a route in future. Obviously approving any additional routes has proven very difficult, as few routes have been added across the entire GSENM over the past couple decades. Nevertheless it’s important to preserve this flexibility for future planners to discover those instances when adding a route may be appropriate to benefit recreation or mitigate its negative effects. After all, such routes could be as minimal as an e-bike trail, or as useful as a short road to cluster campsites in order to close dispersed sites elsewhere. This RMP may be in effect for decades, by which time the majority of motorcycles and possibly automobiles may become electric and even quieter. The organizations accept some scrutiny when it comes to subsequent travel planning and certainly when new routes are proposed, but area designations at this highest level of land-use planning should only be closed to motorized use outright if it’s certain that the given area won’t ever become suitable for any extent of e-biking or other emerging uses. The fact that the BLM can manage more proactively than the NPS is a distinction that could help GSENM achieve the aspirations of the former BLM state director.
5. Coordination with Resource Advisory Councils
When developing the current RMPs for GSENM and the KEPA in June of 2019, the BLM consulted its Utah Resource Advisory Council (RAC), which deliberated to reach a set of recommendations focused on making management more effective for conservation, recreation, and other uses so that they would be optimal plans regardless of national-monument status. Most of this work is discarded by the action alternatives, which is disappointing because the current RMPs’ reliance on active management and adaptability achieved the kind of consensus espoused by the former BLM state director.
6. Coordination with Motorized Trail Groups
Local OHV groups such as the UT/AZ ATV Club are key partners, as they perform countless hours of service work, provide the unique perspective of motorized trail enthusiasts, and promote responsible visitation that’s peer to peer. In particular the UT/AZ ATV Club’s exceptional work on Inchworm Arch has been a model partnership that should be nurtured, yet it’s jeopardized by the DRMP, which should be rectified immediately by ensuring that Inchworm Arch and all other routes will get a fair shake when it’s actually time for travel planning. Please see the enclosed comments from UT/AZ ATV Club’s DRMP, which the Organization’s fully incorporate as our own comments to the BLM.
7. Coordination with Garfield and Kane Counties
In the GSENM, perhaps the most important partners to recognize are Garfield and Kane Counties. The general public greatly benefits from their maintenance of the road network that’s owned jointly between the counties and State of Utah. Both of these counties have been outstanding in their assistance with motorized routes of all kinds. The DRMP must be improved to honor the critical role these counties play in successfully managing GSENM. Please see the enclosed comments from Garfield County regarding motorized routes, which the Organization’s fully incorporate as our own comments to the BLM.
8. Conclusion
The Organizations urge GSENM planners to recognize the motorized route network and its stewards as vital to providing diverse recreation opportunities, which are indeed compatible with Proclamation 10286.
Sincerely,
Clif Koontz
Executive Director
Ride with Respect
Chad Hixon
Executive Director
Trails Preservation Alliance
Marcus Trusty
President/Founder
Colorado Off Road Enterprise
Scott Jones, Esq.
Authorized Representative
Colorado Off-Highway Vehicle Coalition