Coalition and NPCA Concerns at Big Cypress National Preserve Logo


Matt Betenson, Associate Monument Manager
Bureau of Land Management
Grand Staircase-Escalante National Monument and Kanab Field Office
669 South Highway 89 A, Kanab, UT 84741

April 13, 2018

RE: Public Scoping Comments for Grand Staircase-Escalante National Monument Management Planning

Dear Mr. Betenson,

The National Parks Conservation Association and the Coalition to Protect America’s National Parks submit the following scoping comments for the Environmental Impact Statement that will address the development of four resource management plans for the Grand Staircase-Escalante National Monument (GSENM), including the Grand Staircase, Kaiparowits, and Escalante Canyon Units. We also recognize that the management of these lands will inherently impact the lands adjacent to the units created by December 2017 Proclamation 9682 and appreciate your consideration of how these management plans may impact lands formerly within the original Grand Staircase-Escalante National Monument.  We are thankful for your consideration of our input and look forward to working with you to ensure our national parks and monuments, their connected cultural landscapes and surrounding public lands are protected and remain the special places that draw visitors from across the country and the world.

National Parks Conservation Association
The mission of the National Parks Conservation Association (NPCA) is to “protect and enhance America’s National Park System for present and future generations.” Founded in 1919, NPCA is the leading citizen voice for the national parks. We are a national non-profit with headquarters in Washington, DC, and 29 regional and field offices across the country, including our Southwest Regional office in Salt Lake City, Utah. NPCA represents over 1.3 million members and supporters who care about America’s shared natural and cultural heritage preserved by the National Park System.

Coalition to Protect America’s National Parks
The Coalition to Protect America’s National Parks (Coalition) is a non-profit organization composed entirely of retired, former, or current employees of the National Park Service (NPS). The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System (System). With over 1,500 members, the Coalition represent more than 35,000 years of experience managing and protecting America’s most precious and important natural and historic places.

Grand Staircase-Escalante National Monument Legal Status
A top priority for NPCA and the Coalition is protecting the resources within national parks but we aim to do so within the larger landscape in which they are embedded, and the air and water on which they depend, to enhance their ecological and cultural integrity. With that in mind, we continue to be strong supporters of President Clinton’s Proclamation 6920 creating the original Grand Staircase- Escalante National Monument over 21 years ago on September 18, 1996, and as ratified and enlarged by Congress on multiple occasions. Proclamation 6920, under the president’s legal authority explicitly bestowed to him under the Antiquities Act, protects lands rich in geological, paleontological, ecological and cultural resources, as well as scenic views and recreation opportunities in the iconic canyon country adjacent to and surrounded by Capitol Reef and Bryce Canyon National Parks and Glen Canyon National Recreation Area.

On December 4, 2017, President Trump signed Proclamation 9682 excluding nearly 862,000 acres from the original GSENM boundaries and separating the landscape into three smaller national monument units: Grand Staircase, Kaiparowits, and Escalante Canyon. NPCA and the Coalition maintain that Proclamation 9682 is an unlawful revocation of the existing GSENM and will be overturned. The president only has the authority to create a national monument under the Antiquities Act and Congress alone can revoke or reduce a national monument.

As such, the illegal proclamation issued by President Trump is being challenged in a court of law and the Bureau of Land Management’s (BLM) rush to develop four new management plans based on the reduced boundaries of GSENM is premature and illegitimate. Moving forward with the planning processes at this time will likely waste time and resources of an already strapped agency, recognizing that the new proclamation is expected to be overturned by the courts.

This submission of scoping comments from NPCA and the Coalition in no way constitutes acceptance of Proclamation 9682 or management changes that may result from this process, and by participating in the public comment process we are not waiving any rights to contest the underlying proclamation or processes flowing from that act. We assert that the BLM should abstain from planning efforts under the new proclamation (9682) for GSENM until the legitimacy of the proclamations are fully settled in federal court. We recommend the BLM instead spend time and resources ensuring the protection of the natural and cultural resources within the entire landscape under their jurisdiction, including the lands within the original monument (Proclamation 6920), safeguarding it for current and future generations.

Commitment of NPCA and the Coalition to the Grand Staircase-Escalante Landscape
The GSENM landscape provides significant protection for adjacent national parks, including Capitol Reef National Park to the northeast, Bryce Canyon National Park to the northwest and Glen Canyon National Recreation Area to the south and east. In addition to safeguarding critical historical and scientific resources inside the GSENM landscape, the protection of land adjacent to park boundaries removed some of the external threats to park resources including those from irresponsible off-road vehicle use and resource extraction. Potential resource development threatens not only the views from within the parks, but dark night skies, natural sounds, air quality and water resources—all critical resources and values of our national parks. Realistically, protection for National Parks can be assured only when their adjacent lands are well managed and host compatible uses. Simply, constricting GSENM boundaries under Proclamation 9682 eliminates the security for adequate protections through the management of Southern Utah’s public lands, including its national parks. Any modifications to the 2000 GSENM Management Plan by BLM through the current planning process should not risk the integrity of resources inside the three smaller monument units, as established under Proclamation 9682, on lands excluded from the monument or adjacent national parks.

Our scoping comments address lands within the GSENM landscape, particularly those adjacent to Capitol Reef and Bryce Canyon National Parks and Glen Canyon National Recreation Area. We value the entire connected landscape and the historic and scientific objects, as well as recreation opportunities within the current monument units, however, our greatest concerns and expertise are focused on park adjacent lands, recognizing that these park units remain critical to the region and management planning process overall.

Input Regarding Selected Planning Criteria

The following comments apply to the information provided in select planning criteria as described in the scoping notice provided by the BLM through the Land Use Planning Register.

(1) The public planning process for the RMPs will be guided by Presidential Proclamation 6920 as modified by Proclamation 9682 in addition to FLPMA and NEPA.

On three separate occasions since 1996, Congress passed legislation revising the boundaries of GSENM, purchasing territory to add to the monument, and/or purchasing mineral rights within the monument from the State of Utah or private parties. Given this Congressional activity with respect to GSENM, any modification to the management and uses of the whole GSENM landscape must comply with the actions of Congress as well as FLPMA, NEPA and Proclamation 6920 or Proclamation 9682, should it be upheld in federal court.

(3) The BLM will use current scientific information, and results of inventory, monitoring, and coordination to determine appropriate management.

The BLM invested significant time and resources in the collaborative planning process to develop the 2000 General Management Plan for the original GSENM. This included five professionals on the planning team nominated by the Governor, 30 public workshops with 2,000 participants, science symposiums, dozens of meetings with tribes, local, state and Federal agencies and private organizations.  This extensive public engagement, in addition to the best available scientific information and monitoring, should continue to form the foundation for current and future management of the GSENM landscape, and not be wholly replaced by the narrow, expedited public process in response to Proclamation 9682. We are particularly concerned that the BLM plan to proceed with one Environmental Impact Statement in the development of four resource  management plans within one year is too complicated and rushed for the public to adequately participate.

(4) The BLM will strive for consistency of management decisions with other adjoining planning jurisdictions, both Federal and nonfederal.

Given their proximity to and connection with National Park System sites, it is our hope that the BLM managers will utilize, under this criterion, the expertise of National Park Service (NPS) officials to help shape the management of the adjacent landscape. Such collaboration will likely help prevent impacts from incompatible uses, while also sharing NPS expertise in visitor management and interpretation. The NPS has strong authority to protect its resources from harmful impacts on  nearby lands. The significance of park resources, including scenic values, at our national parks and the responsibility of NPS to protect them was clearly articulated in the Organic Act of 1916:

… to the fundamental purpose of the said parks, monuments, and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.

Further, because national parks are not islands of protection, and their scenery and fundamental resources are more often at risk from adverse impacts originating outside national park boundaries, the NPS Management Policies 2006 (§ 4.1.4) outline well the responsibility of NPS to engage with other agencies and decision-makers:

… the Service will seek the cooperation of others in minimizing the impacts of influences originating outside parks by controlling noise and artificial lighting, maintaining water quality and quantity, eliminating toxic substances, preserving scenic views, improving air quality, preserving wetlands, protecting threatened or endangered species, eliminating exotic species, managing the use of pesticides, protecting shoreline processes, managing fires, managing boundary influences, and using other means of preserving and protecting natural resources.

In addition to specific issues outlined below, we emphasize the importance of ensuring management of the lands both included and excluded from the monument that are adjacent to the national parks complement and are consistent with park management.  In particular, management of the Waterpocket Fold area that will remain under BLM jurisdiction in the GSENM landscape must be consistent with the adjacent primitive and semi-primitive zones in the Waterpocket Fold District of Capitol Reef National Park as defined in the park’s General Management Plan.

In Capitol Reef National Park, the primitive zone represents the highest order of wilderness qualities, where isolated landscapes remain in an essentially wild and undeveloped condition…The primitive zone provides abundant opportunities to experience wilderness solitude and natural quiet.  The area is substantially free of modern human influence and alteration…natural processes and conditions are perpetuated…The National Park Service maintains close control over resource-damaging activities.[1]

Capitol Reef National Park’s semi-primitive zone is:

…similar in nature to the primitive zone, except that evidence of human activity is more pronounced, road corridors are more abundant, and access is easier.[2]

Similarly, Bryce Canyon National Park’s Foundation document identifies the resources and values that make Bryce Canyon National Park nationally significant and worthy of designation as a national park. Significant resources and values that could be affected by development on park adjacent lands, including those under consideration by the BLM in the current scoping process, include the park’s viewshed, clean air, dark night skies and natural soundscapes. Bryce Canyon National Park’s Foundation Document states:

The location of the park at the summit of the Grand Staircase, surrounded by a system of nationally protected lands, and combined with the exceptional clarity of the air and natural quiet, provides a multisensory experience. The outstanding views often extend more than 100 miles and begin with the colorful and intricately carved Claron Formation and include panoramic vistas of cliffs, canyons, and forested landscapes.

With a nearly pristine night sky, thousands of stars shine brightly at Bryce Canyon National Park. As one of the darkest publicly accessible places in North America, the Milky Way Galaxy can be viewed from horizon to horizon. The clear, clean air and a lack of artificial light in the park and the region are essential to this unparalleled nighttime experience. The darkness is also an important resource for nocturnal wildlife.[3]

The constriction of GSENM boundaries under Proclamation 9682 could have the greatest impact on Glen Canyon National Recreation Area (GCNRA) given the significant stretches of land adjacent to its boundaries that were excluded from the new monument units. Management decisions made on land near GCNRA should be consistent with the park’s purpose and protect its recommended wilderness as identified in the GCNRA Foundation Document:

Glen Canyon National Recreation area, located at the center of the Colorado Plateau, provides for public enjoyment through diverse land- and waterbased recreational opportunities, and protects scenic, scientific, natural, and cultural resources on Lake Powell, the Colorado River, its tributaries, and surrounding lands.[4]

Glen Canyon National Recreation Area includes 588,855 acres of proposed wilderness and 48,955 acres of potential wilderness. Together this represents 51% of the total land area of Glen Canyon National Recreation Area, containing a variety of culturally and ecologically unique landscapes where visitors can experience the character and solitude of wilderness within a recreation area.[5]

(7) A baseline reasonably foreseeable development scenario will be developed for oil and gas and other mineral resources for Federal lands previously included in the GSENM that are now excluded from monument boundaries.

NPCA and the Coalition have significant concerns that a quickly drafted new or amended Resource Management Plan (RMP) for the Kanab Field Office for the new GSENM landscape may take away protections from mineral and energy development that should remain in place until the legal boundaries are decided in court. Like many concerned stakeholders, we fear that, should the landscape be affected by such incompatible uses, and later determined to be necessarily under protection based on federal court proceedings, they may be forever damaged and unable to be restored.

Further, any oil and gas drilling or tar sands development on lands excluded from GSENM, as noted in the planning criterion (7), would not only harm objects of historic and scientific interest for which the original monument was established, but also affect the resources of the remaining monument units and nearby national parks. Industrial development and access roads could impact natural and cultural resources, scenic views, dark night skies, natural soundscapes, clean air and the overall visitor experience, tourism economy and nearby community health and quality of life.

If the BLM proceeds in developing a reasonably foreseeable development (RFD) scenario for oil and gas, the RFD must account for 21st century impacts including drilling of multiple wells on a single pad and their associated emissions – not a single well per pad, per parcel. The RFD must also accurately represent the impact and number of hydraulically fractured wells and include the number of injection wells associated with potential development and their anticipated water extraction from the Colorado Basin.

(8) The BLM will consider changes to off-highway vehicle (OHV) area designation

For many years, across the nation, NPCA and the Coalition both have advocated for NPS management action to prevent illegal off-road vehicle use and reduce environmental impacts through appropriate planning, visitor education, outreach and enforcement. We have also consistently raised concerns with off-road use outside park boundaries that cross illegally into national parks, which can negatively impact wildlife, crush fragile desert soils and plant life, and increase wind and water erosion. Therefore, we continue to urge the BLM to consider appropriate levels of OHV use both within the GSENM boundaries and within the larger landscape adjacent to national park units. We have significant concerns about increased pressure on our public land managers to expand OHV use, particularly nearer to our national parks. With literally thousands of miles of designated OHV routes, NPCA maintains that allowing for increased use within and adjacent to protected landscapes risks resource damage.

According to Grand Staircase Partners:

There are approximately 908 miles for street legal motorized vehicle routes, and 553 miles of this includes non-street legal ATVs and dirt bikes. There are also around 192 miles of administrative routes for authorized users such as grazing permittees, researchers, State or Federal agencies, Native American Indians accessing recognized traditional cultural properties, and others carrying out authorized activities under a permit or other authorization.[6]

(10) Parties interested in leasing and development of Federal coal in areas that are excluded from the monument should provide coal resource data for their area(s) of interest.

On November 29, 1999, Congress enacted the Consolidated Appropriations Act of 2000.[7] This Act not only appropriated funds for “planning and operation” and “construction” for the original GSENM, but also appropriated $19.5 million that “may be used to acquire mineral rights within the Grand Staircase-Escalante National Monument.”[8] The federal government used these funds to buy out coal and mineral claims within Grand Staircase that were held by private parties and had been in existence and preserved when President Clinton designated it as a national monument.[9] All of the holders of coal rights inside the original GSENM voluntarily pursued an exchange of their rights for compensation or other lands or resources outside of the monument area. Any attempt by the current administration and land management agencies to allow for mining and extraction activities would contravene Congress’ purpose, and if the BLM leases parcels for extraction before the courts issue a final ruling on current national monument boundaries at GSENM, they are setting up the American public to pay yet again to prevent coal and mineral development inside the monument.

Furthermore, industrial development and heavy truck traffic for coal mining in the heart of the GSENM would not only threaten and destroy cultural, archeological and paleontological sites as well as scientific resources, but also adversely affect the health and well-being of nearby communities, negatively impact regional tourism related businesses, increase nighttime skyglow, elevate ambient noise levels and release haze causing and toxic air pollutants. These impacts could harm the very resources and visitor experience of the three GSENM units as well as nearby national parks and BLM managed lands.

Input Regarding Other Issues

Economic Benefits of National Parks and Monuments
National park and monument visitors are flocking to Utah in record numbers. According to the National Park Service, 14.4 million people visited Utah’s national parks in 2016. Those visitors come to experience not only Utah’s Mighty Five national parks, but the mosaic of spectacular public lands across our state, including Bryce Canyon and Capitol Reef National Parks and Grand Staircase- Escalante National Monument. According to the Outdoor Industry Foundation, that visitation also translated into a contribution of $12.3 billion to Utah’s economy. As a result, it is imperative we recognize the importance of preserving the natural and cultural resources that are protected by our national parks and monuments, along with the celebrated dark night skies, intense quiet and the spectacular vistas that continue to draw more and more visitors. To maintain the robust economy of Utah’s public lands, we recommend the BLM protect the resources of the original GSENM.

(Proclamation 6920) and the nearby national park units, including air and water quality, cultural resources, dark night skies, natural sounds and viewsheds.

Key economic indicators show the communities in both Kane and Garfield counties have continued growth trends that began before monument designation. According to a report from Headwaters Economics, in the Grand Staircase-Escalante region from 2001 to 2015 the population grew by 13 percent, jobs grew by 24 percent, real personal income grew by 32 percent and real per capita income grew by 17 percent.[10] While traditional jobs in agriculture, mining and timber have held steady in the Grand Staircase region, most employment growth has been in the service industry, particularly lodging, restaurants, healthcare, finance, and professional and administrative services.

We ask the BLM to assess potential impacts to economic growth and sustainability that might result from new management plans for a landscape surrounded by Bryce Canyon and Capitol Reef National Parks and Glen Canyon National Recreation Area. Research has shown that natural amenities, such as the protected landscape of GSENM, help attract new investments and maintain property values [11] and improve quality of life for local residents.

Maintain Protections for the Original Monument Landscape
While the scoping document primarily requests comments on the current monument boundaries, under Proclamation 9682, it is important to recognize that the elimination of original protections and separation of the previously contiguous national monument created by Proclamation 6920 undermines the value of the GSENM landscape as a whole.  It is crucial that these remarkable natural resources and historic sites remain connected under the national monument designation, as proclaimed in 1996. It is in keeping with the Antiquities Act that these objects must receive “proper care and management,” and in order to do so, the landscape and the resources it hosts must be considered in its entirety, with an appropriate all-encompassing management plan.

Therefore, any actions proposed within the original and valid boundaries of the GSENM should only substantially advance the proper care and management of the objects of interest as set forth in Proclamation 6920. The BLM should put forth alternatives in its management plans for land both included and excluded in the monument under Proclamation 9682 that protect the important and sensitive resources of the original monument including cultural, natural/ecological, paleontological, geological resources as well as Tribal sacred lands. Such alternatives will ensure the monument management plan consistently covers both the areas in the original proclamation, as well as the reduced areas. In the interim, NPCA and the Coalition urge BLM to protect the entire GSENM landscape from looting and destruction of cultural sites, irresponsible off-road vehicle use, energy and mineral extraction, hazardous levels of grazing, and other threats from inappropriate use and development.

National Park and Monument Resources of Concern
Cultural Resources/Landscape and Traditional Knowledge
We urge the BLM to look beyond the current reduced monument boundaries when planning for the protection and interpretation of cultural resources and traditional cultural knowledge. Meaningful consultation with Native American tribes and other cultural resource stakeholders throughout the public lands management planning process is necessary to identify traditional cultural properties, sacred landscapes, and other issues and concerns within the original monument boundaries. We urge the BLM to consult closely with Native American tribes to better inform modified monument management within the original monument boundaries.  In addition, we urge the BLM to incorporate traditional cultural knowledge and tribal representatives in the interpretation of monument history, cultural sites and traditional uses.

Dark Night skies
The Colorado Plateau is one of the last sanctuaries of darkness amidst a rising surge of light pollution. Many visitors go to national parks and monuments to experience the dark, starry skies, which brings economic benefit to the parks and monuments and surrounding communities. In addition to the visitor experience, wildlife species depend on natural patterns of light and dark for navigation, to cue behaviors, or hide from predators.

NPS has recognized dark night skies as an important resource that plays a critical role in natural resource processes and the evolution of species, as well as contributing to the national park visitor experience (NPS Management Policies 2006, § 4.10). Capitol Reef National Park is designated an International Dark Sky Park, a designation reserved for parks with “exceptional” and well-preserved night sky resources. People visit these places just to experience their dark, night skies, to learn about them through ranger-led interpretive talks and view them through high powered telescopes. Therefore, it is critical that the BLM continue to ensure that these qualities are maintained on the park-adjacent landscapes to GSENM.

Similarly, the BLM is also required to manage public lands in part for “scenic values,” which include night skies.  43 U.S.C. § 1702(c). Under the National Environmental Policy Act (NEPA), the BLM must account for the direct, indirect and cumulative impacts of “past, present, and reasonably foreseeable future actions” on night skies. 40 C.F.R. §§ 1502.16, 1508.7, 1508.8.  In addition to reducing impacts on night skies and protecting the purity of dark, night skies within the original monument boundaries, we urge the BLM to celebrate and interpret this dwindling resource for monument visitors.

Natural Sounds
Like the incredibly dark night skies, the natural quiet of this remote landscape is worthy of recognition and protection by the BLM in their monument management plan and within the proposed landscape removed from current monument protection adjacent to national park units. NPS manages park units to protect natural, cultural, and historic sounds they consider fundamental to the purposes and values for which the parks were established.  The NPS Natural Sounds Program Mission is “…to protect, maintain, or restore acoustical environments throughout the National Park System.” Noise impacts the acoustical environment by obscuring the listening environment for both visitors and wildlife. An appropriate acoustical environment is also an important element in how we experience the cultural and historic resources in the national parks. Places of deep quiet are most vulnerable to noise. Therefore, wildlife in remote wilderness areas and park visitors who journey to these quiet places are likely to be especially sensitive to noise. In addition, soundscapes are part of the “human environment” subject to the requirements of NEPA. 42 U.S.C. § 4331 (C); see also Wyoming v. United States DOI, 674 F.3d 1220, 1236 (10th Cir. 2012) (upholding NEPA analysis in part because NPS properly considered “soundscapes”).

As you know, the Colorado Plateau is a vast, wide, open landscape that affords incredible views, in some cases 360-degree views of undeveloped land for 100 miles. Public land management boundaries are indistinguishable to most visitors. Part of the unique experience of visiting this remote area of Southern Utah is the opportunity to seemingly travel back through time to learn about ancient history and more modern pioneers to the area, as well as the expansive views and vistas across the mosaic of public lands. Incompatible development on land within the GSENM landscape and within view of the national park units and the Proclamation 9682 monument units could significantly impact that experience. Therefore, BLM must ensure the national parks’ and monuments’ visual resources will be protected from incompatible development in the region. This can include infrastructure such as drill pads and stock tanks, truck traffic, new roads and more.

Air Quality
Bryce Canyon and Capitol Reef National Parks are designated as Class I areas under the Clean Air Act. Class I areas are places where the law requires the air quality to be at its most pristine, unaffected by human-made or human-caused pollutants. Clean air enhances the color and contrast of landscape features; allows visitors to see great distances; and safeguards ecosystem, visitor, and public health. Any allowance for mining or other energy development in the GSENM region may release particulate matter (PM), nitrogen oxides (NOx), sulfur dioxide (SO2) and volatile organic compounds (VOCs). These haze-causing pollutants would obscure scenic vistas in adjacent national parks by impairing a viewer’s ability to see long distances, color and geologic formation. They also contribute to unhealthy National Ambient Air Quality Standard pollutants, ozone and particulate matter.

Visitors to national parks and wilderness areas consistently rate visibility and clear scenic vistas as one of the most important aspects of their experience.[12] In coordination with other agencies, we recommend the BLM consider how to best manage the GSENM landscape and monuments to ensure clean air for both visitors and monument and park resources.

Water Resources
Water is a precious resource in the West. Certain activities including mining, oil and gas development, grazing and irresponsible off-road vehicle use can have significant impacts on its quality and quantity. Preserving and protecting key watersheds and water sources should, therefore, be a clear priority for monument managers. The BLM needs to accurately determine potential impacts to water quality or quantity from monument uses including grazing, off-road vehicle use, timber management, wildfire management, and more to develop an appropriate plan for water usage and protection.

Paleontological and Geological Resources
The unbroken and exposed stratigraphy and structures in the GSENM geologic landscape are central to its significance for scientific research and to understanding the processes that formed the earth. The interconnected and protected landscape of GSENM completes protection of the Waterpocket Fold formation, most of which lies within Capitol Reef National Park, and is also critical to the experience of nearly every visitor who stands at the rim of the plateau in Bryce Canyon National Park looking across the geologic stairway, Grand Staircase, dropping over 5,500 feet in a series of cliffs  and plateaus.

Grand Staircase also encompasses one of the most densely fossilized dinosaur areas in the world. There are literally thousands of dinosaur fossil sites within the monument and new discoveries still taking place with ongoing research. The Kaiparowits Plateau region in particular has yielded over 2,000 newly documented Late Cretaceous vertebrate localities and scientists have inventoried only 20 percent of them.[13] We encourage you to consult the Society of Vertebrate Paleontology and other experts in geology and paleontology to ensure these internationally significant resources are protected from any new incompatible uses.

Vegetation and Wildlife Resources
The protection of the GSENM landscape is critical to the protection of each component or object within the individual national monument units. As noted in Proclamation 6920, “Most of the ecological communities contained in the monument have low resistance to, and slow recovery from, disturbance. Fragile Cryptobiotic crusts, themselves of significant biological interest, play a critical role throughout the monument, stabilizing the highly erodible desert soils and providing nutrients to plants.”[14]

The GSENM landscape includes five life zones, from low-lying desert to coniferous forest, providing opportunities for biological study of an area that is “perhaps the richest floristic region in the Intermountain West” and “characterized by a diversity of species” such as mountain lion, bear, desert bighorn sheep and over 200 species of birds.[15] The BLM should identify and protect wildlife corridors, migration pathways and critical habitat for both wildlife and vegetation.

It is crucial that historic sites, geological and paleontological resources and remarkable natural resources in the GSENM landscape remain connected and uniformly managed whether they were included or excluded from the current GSENM boundaries.

Levels of grazing within the GSENM landscape have stayed nearly the same as they were prior to the 1996 monument designation by Proclamation 6920. Over 95 percent of the original monument remains open for grazing with 76,957 Animal Unit Months (AUMs, the federal measure for grazing permits) available today versus 77,400 AUMs available at the time of the designation.[16] The slight reduction in AUMs is attributed to voluntary relinquishment of permits due to drought or buyout from a conservation organization to protect fragile riparian areas.

Livestock grazing within and adjacent to protected landscapes, if poorly managed, can affect the health of key water sources and watersheds, vegetation communities, important wildlife habitat, and entire ecosystems. When addressing livestock grazing levels and administration within the GSENM landscape, we urge the BLM to base management decisions on scientific data, robust monitoring of forage availability, rangeland and ecosystem health and to take an adaptive approach to ensure the resiliency of our public lands in the face of a changing climate.

We emphasize the critical importance of protecting threatened and endangered species, native cold desert plant and animal communities, streams and riparian areas, biological soil crusts and archaeological and historic resources. We are particularly concerned about the concentration of livestock in fragile perennial streams, wetlands and riparian areas.

The BLM should clarify how this management planning process will incorporate the GSENM and Glen Canyon National Recreation Area (GCNRA) Grazing Management Plan process already well underway. NPCA has ongoing concerns regarding potential impacts to recreation area resources from the alternatives already proposed for grazing inside and near GCNRA. The BLM must consider the full suite of tools and alternatives available, including management of AUM numbers, adjusting the timing of trailing and grazing and mitigation of direct and indirect impacts from livestock on sensitive habitat and species. Building in adaptive management is important for testing management tools to ensure they help managers meet their conservation goals without unintended consequences, especially in a fragile desert ecosystem subject to drought and climate warming with the potential to alter the forage and water regimes.

NPCA and the Coalition also encourage the BLM to work closely with Capitol Reef National Park   staff to ensure livestock grazing and trailing in the GSENM landscape is consistent with the Livestock Grazing and Trailing Management Plan currently under development for the park. This is particularly important as three traditional stock trails crossing Capitol Reef National Park connect  the GSENM monument to lands east of the park.  Therefore, any alteration to the number and management of AUMs in this area could have direct impacts on sensitive park resources.


The National Parks Conservation Association and the Coalition to Protect America’s National Parks urge the administration to maintain, at minimum, the current protections of the unique, rich GSENM landscape both included and excluded in Proclamation 9682. We ask the BLM to move forward with a plan that embraces this “vast and austere landscape”[17] and its scientific and historic resources in a manner that protects neighboring national parks, is consistent with existing law, preserves our natural and cultural history and allows the growing outdoor recreation industry to flourish.

Thank you for your consideration of these comments and those of our members and supporters. In addition to these comments, NPCA has also signed on to comments of our allies, including The Wilderness Society. Should you have any questions or concerns regarding comments or positions described in this letter, please contact NPCA staff, Cory MacNulty at 801-834-3125 or cm*******@np**.org.


David Nimkin
Southwest Senior Regional Director
National Parks Conservation Association
307 W 200 S, Suite 5000
Salt Lake City, UT 84101
Cory MacNulty
Utah Senior Program Manager
National Parks Conservation Association National Parks Conservation Association
307 W 200 S, Suite 5000
Salt Lake City, UT 84101
Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
201 I Street, NE #805
Washington, DC 20002

1. Capitol Reef National Park General Management Plan at 28 (1998), available at

2. Id.. at 29

3. Bryce Canyon National Park Foundation Document at 8 (May 2014), available at

4. Glen Canyon National Recreation Area Foundation Document at 1, available at

5 Id. at 6

6 Grand Staircase Partners factsheet, 13.pdf.

7 Pub. L. No. 106-113, app. C, § 601, 113 Stat. 1501 (1999).

8. Id.

9. See Lee Davidson, Grand Staircase, Deseret News (Sep 17, 2006), available at (federal government bought out one company’s claims for $14 million and another company’s claims for $5.5 million).

10. Grand Staircase-Escalante National Monument: A Summary of Economic Performance in the Surrounding Communities, available at content/uploads/Escalante.pdf

11. Deller, S.C., H. Tsai, D.W. Macrouiller, and D.B.K. English. 2001. The Role of Amenities and Quality of Life in Rural Economic Growth. American Journal of Agricultural Economics 83(2): 352-365.

12. Out of Sight: Haze in our National Parks, Clear the Air, available at

13. See http://vertporg/GlobalPDFS/Comments-from-Society-of-Vertebrate-Paleontology.aspx at 7.

14. Proclamation 6920, 61 Fed. Reg. 50223 (Sept. 18, 1996).

15. Id.

16. See United States Department of the Interior Bureau of Land Management, Grand Staircase-Escalante National Monument Grazing on the Monument: an Introduction, at 1 (July 28, 2015), available at

17. Proclamation 6920, 61 Fed. Reg. 50223 (Sept. 18, 1996).