ATTN: GSENM RMP Project Manager 
BLM Paria River District 
Grand Staircase-Escalante National Monument 
669 South Highway 89 A, Kanab, UT 84741

November 9, 2023 

RE: Public Comments for the Draft Resource Management Plan (RMP) and Environmental Impact Statement (EIS) for the Grand Staircase-Escalante National Monument (DOI-BLM-UT-P010-2022-0006-RMP-EIS) 

Dear Adé Nelson, Scott Whitesides and the Resource Management Planning Team, 

The National Parks Conservation Association (NPCA) and the Coalition to Protect America’s National Parks (CPANP) submit the following comments for the Draft Resource Management Plan and Environmental Impact Statement for the Grand Staircase-Escalante National Monument as designated by Presidential Proclamation 10286. These comments are in addition to joint comments we have signed with Grand Canyon Trust (GCT), Southern Utah Wilderness Alliance (SUWA) and other conservation organizations that have been submitted by GCT/SUWA. We value the connected landscape and the historic, prehistoric and scientific objects, and recreation opportunities within the entire monument designated under Presidential Proclamations 10286 and 6920. As with the scoping comments we submitted, our greatest concerns and expertise are focused on park adjacent lands and potential impacts to the resources and values of Bryce Canyon and Capitol Reef National Parks and Glen Canyon National Recreation Area. We submit these comments in addition to GCT et al. to highlight and address those park specific concerns. 

National Parks Conservation Association

The mission of the National Parks Conservation Association 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 field office in Salt Lake City, Utah. NPCA represents over 1.6 million members and supporters who care deeply 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 represents over 2,500 current, former, and retired employees and volunteers of the National Park Service, with over 45,000 collective years of stewardship of America’s most precious natural and cultural resources. Our membership includes former National Park Service directors, deputy directors, regional directors, and park superintendents. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service.

Management Areas

We encourage the BLM to adopt a modified version of Alternative C, the preferred alternative, that protects dark nights skies and natural quiet, upholds off-road vehicle and route closures from the 2000 management plan and prioritizes cultural resource protection and Tribal Nation involvement in management decisions. We emphasize the importance of ensuring management of the monument lands that are adjacent to the national parks complement and are consistent with park management.

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.”

Resource-Specific Comments

Tribal Stewardship

Proclamation 10286 articulates the historic and current day connection that Tribes have to the GSENM landscape and management direction to ensure this connection is maintained. “The Secretary shall, to the maximum extent permitted by law and in consultation with Tribal Nations, ensure the protection of sacred sites and cultural properties and sites in the monument and provide access to Tribal members for traditional cultural, spiritual, and customary uses, consistent with the American Indian Religious Freedom Act (42U.S.C. 1996) and Executive Order 13007 of May 24, 1996 (Indian Sacred Sites), including collection of medicines, berries and other vegetation, forest products, and firewood for personal noncommercial use in a manner consistent with the care and management of the objects identified above and in Proclamation 6920.” Pres. Proc No. 10286, 86 Fed. Reg. 57,335 (Oct. 8, 2021).

Overall, we support Alternatives B/C/D in Rows 67-78 to ensure Tribal Nations are engaged early in the planning and decision-making process to prioritize traditional ecological knowledge and better protect cultural resources and values. We urge the BLM to collaborate with Tribes to identify traditional cultural properties, sacred landscapes, traditional uses and other issues and concerns within the monument and to effectively incorporate traditional ecological knowledge and Tribal representatives in co-stewardship and management of the monument and the interpretation of monument history, cultural sites and traditional uses.

Fish and Wildlife 

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.1Proclamation 6920, 61 Fed. Reg. 50223 (Sept. 18, 1996). BLM should identify and protect wildlife corridors, migration pathways and critical habitat for wildlife and vegetation in collaboration with other state and federal agencies, including NPS, to preserve healthy wildlife communities, overall ecosystem functions and resiliency in a changing climate.

BLM should exert maximum effort to achieve stated wildlife conservation goals: preserving the integrity of wildlife corridors, migration routes, and access to key forage, nesting, and spawning areas by limiting adverse impacts from development in the monument; managing habitats for the recovery or reestablishment of native populations and work to improve habitat quantity and quality (forage, water, cover, space, security, trophic level integrity, and biogeochemical processes); and conserving habitat for migratory birds. Finally, BLM should continue to facilitate appropriate research to improve understanding of fish and wildlife species and habitat and increase public education and appreciation of fish and wildlife species through interpretation.

Management of Fish and Wildlife should focus on specifically native habitat for native wildlife in Row 86 (Alternative B/C/D) and Row 87 (Alternatives B/C/D) and should prioritize natural processes and techniques.

Row 88 

Adopt Alternative B/C/D but modified to include the following language – Management will be coordinated for areas that border adjacent National Parks to also meet NPS habitat management goals. 

Row 88 Rationale

Protection of wildlife species in the Planning Area, which include big game populations and more than 40 special status species, will also help to protect wildlife values in immediately adjacent NPS-managed areas. As stated in Bryce Canyon’s Foundation Document, “Park boundaries are irrelevant to the migratory hummingbirds or nesting peregrine falcons; Rocky Mountain elk, mule deer, and pronghorn cross through the plateau forests and meadows within and beyond the park; other animals have adapted to occupy the distinctive erosional features of the amphitheater and adjacent habitats.2Foundation Document, Bryce Canyon National Park, May 2014 at 6. (; see also Species Checklist for Bryce Canyon National Park at,2,4,5,3,11,12,7,9,6,8,10,13,14,16,15,17/false, viewed November 15, 2018.

Capitol Reef likewise shares wildlife species habitat with the adjacent Planning Area, including, among others, mule deer and bighorn sheep as well as threatened, endangered and sensitive species such as the bald eagle, Mexican spotted owl, peregrine falcon, and the southwestern willow flycatcher.3See Species Checklist for Capitol Reef National Park at,viewed November 15, 2018; see also Capitol Reef National Park General Management Plan, September, 1998 at 79 (

Glen Canyon hosts bighorn sheep, bald eagles, golden eagles, and California condors, and these species ranges are not confined to the Parks.4See Species Checklist for Glen Canyon National Recreation Area at, viewed November 15, 2018.

In addition, the Escalante River and its tributaries within the monument feed into riparian areas in Glen Canyon. The health of these water bodies is vital to the health of numerous fish species downriver, including endangered species such as the Colorado Pikeminnow, Razorback Sucker, bonytail and humpback chub.

Along with being important components of these park ecosystems, these animals are also observed and enjoyed by park visitors. They are NPS resources and values that are important to consider in monument management and planning decisions.

Special Status Species

Row 102

Adopt and modify Alternative B/C/D – Maintain and restore habitat connectivity and unrestricted special status species movement between ecological areas, seasonal use areas, and other areas important for sustainable populations within the monument and across monument boundaries in partnership with NPS, USFWS and other agencies.

Row 102 Rationale 

See Row 88 rationale.

Visual Resources 

The Colorado Plateau is a vast, wide, open landscape that affords incredible views across the mosaic of public lands, in some cases 360-degree views for a hundred miles without any visual intrusion from development. 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 imagine our lands as seen by the first inhabitants.

From Bryce Canyon’s rim, visitors can look east over hoodoos and to the Monument beyond to unspoiled lands and geological features of Grand Staircase. “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.” Bryce Canyon Foundation Doc. at 8. Figure 3-39 inexplicably designates the land adjacent to Bryce Canyon as moderate value for maintenance of visual quality and we urge the BLM to change the designation of lands in the park’s viewshed to high value to mirror the high value designations for visual quality on land contiguous with Capitol Reef and Glen Canyon.

We urge the agency to do its utmost to ensure that high quality conditions are preserved in areas visible from Bryce Canyon, Capitol Reef and Glen Canyon, as well as viewpoints in the monument. Additionally, we urge BLM to safeguard the high quality, unspoiled scenic byways and backways that connect the planning areas with the parks, particularly Burr Trail and Hole-in-the-Rock Road. These routes are gateways to the adjacent national parks and their quality affects the overall visitor experience in the region.

For visual resource management, we support Alternative D, which “would only assign VRM Class I or II objectives to GSENM lands, resulting in all landscapes retaining their landscape character.” ES-17.

Alternative D best reflects the direction of Proclamation 10286 and the findings of the AMS and best protects national park viewsheds. 

We strongly oppose Alternatives A and B which identify a number of management areas adjacent to Capitol Reef National Park, Glen Canyon National Recreation Area, Bryce Canyon National Park, and scenic backways as Class III or IV. Alternative C also includes, though to a lesser degree, VRM Class III areas near Capitol Reef and Glen Canyon and a large area in the viewshed of Bryce Canyon. 

Row 123

Adopt Alternative D, which would assign VRM Class I or II objectives to all GSENM lands. 

Row 123 Rationale

Alternatives A and B do not meet the BLM’s obligations under the proclamation and other applicable laws and are based on arbitrary and capricious foundations. Alternative D, on the other hand, best protects the visual resources that are necessary to the proper care and management of monument objects and best serves the public’s strong and growing interest in protecting the monument’s visual resources and other objects.

Alternative D is also the only alternative that will protect viewsheds of Bryce Canyon and Capitol Reef National Parks and Glen Canyon National Recreation Area. Alternative A, with VRM Class III and IV within the viewsheds of the national parks “could result in adverse impacts on these NPS landscapes where management activities would be allowed to attract attention of the casual viewer.” 3-242. While smaller in area, Alternatives B and C still include VRM Class III in the viewshed of all three parks and do not ensure that high quality conditions are preserved in areas visible from Bryce Canyon, Capitol Reef and Glen Canyon, as well as viewpoints in the monument.

Dark Night Skies

Proclamation 10286 specifically recognizes the quality of the dark night skies of GSENM as a resource that must be protected. “The Grand Staircase-Escalante’s large, isolated, and, at times, impenetrable landscape is one of the most naturally dark outdoor spaces left in America, providing views of the cosmos that are nearly unrivaled in the contiguous United States, and an opportunity for visitors to encounter a landscape at night, undisturbed by electric lights, in the same way people have experienced the West for most of America’s history. According to recent research, over 90 percent of the landscape, or nearly 1.7 million acres, contains pristine night skies, meaning that observers would see no indication of artificial skyglow anywhere in the night sky. Only natural sources of light are visible to the human eye, such as starlight, airglow, aurora, and zodiacal light.” Pres. Proc No. 10286, 86 Fed. Reg. 57,335 (Oct. 8, 2021).

For dark night sky management, we strongly oppose Alternative A and support Alternatives C and D, particularly direction to seek International Dark Sky status and BMPs to protect dark night skies.

It is critical that BLM work collaboratively with neighboring federal agencies, local communities and other partners to ensure the purity of dark night skies are maintained throughout the monument and the connected landscape. NPS recognizes 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. People visit International Dark Sky Parks just to experience their dark, night skies, to learn about them through ranger-led interpretive talks and view them through high powered telescopes.

Row 127

Adopt the goal from Alternative A in the final plan.

Row 127 Rationale

In addition to reducing impacts on night skies and protecting the purity of dark, night skies within the monument, we urge BLM to celebrate and interpret this dwindling resource for monument visitors. 

Row 128

Adopt the objective from Alternatives B, C, and D in the final plan, modified to include language from Alternative A: “Manage, monitor, and periodically inventory outdoor lighting fixtures to protect the quality of dark night skies and other GSENM objects in partnership with local communities, Tribes, universities, other agencies, and stakeholders.” Both monitoring/ inventory and management to protect dark skies and other GSENM objects is important.

Row 128 Rationale 

While it is important to monitor lighting and periodically update the inventory for dark skies, The objective from Alternative A is insufficient to meet the public’s interest in protecting dark night skies and the agency’s obligations under the proclamation. 

The Colorado Plateau is one of the last sanctuaries of darkness amidst a rising surge of light pollution with one of the highest concentrations of Dark Sky Places designated by the International Dark Sky Association in the world. Circling GSENM, Capitol Reef, Zion and Bryce Canyon National Parks, Pipe Springs and Cedar Breaks National Monuments and Kodachrome Basin State Park are all designated International Dark Sky Parks, a designation reserved for parks with “exceptional” (see International Dark Sky Places, available at and well-preserved night sky resources. Torrey is an International Dark Sky Community recognized for adopting “quality outdoor lighting ordinances” Id. and educating their residents about the importance of dark skies. Rainbow Bridge National Monument is a designated International Dark Sky Sanctuary, “the first of its kind in the National Park Service, and distinguishes Rainbow Bridge National Monument for the quality of its naturally dark night skies and the site’s cultural heritage.” Id. The Kaibab Paiute Tribe earned a designation as the first “dark sky nation” in the world and the Kaibab Paiute reservation is and International Dark Sky Community known as the “Thunder Mountain Pootsee Nightsky.” (see Dark Sky over Thunder Mountain Pootsee Nightsky, available at The Colorado Plateau, with GSENM at its heart, provides unparalleled opportunities for cross-jurisdictional partnership to protect the purity of dark night skies in the monument. 

Natural Soundscapes 

Proclamation 10286 specifically recognizes the intense quiet and quality of GSENM natural soundscape as a resource that must be protected. “The Grand Staircase-Escalante area also provides a remarkable natural soundscape with infrequent human-caused sounds. From popular recreational destinations to remote, isolated locations, acoustic baseline research has found that some of the quietest conditions found in protected areas across the United States can be found in the Grand Staircase-Escalante landscape.” Pres. Proc No. 10286, 86 Fed. Reg. 57,335 (Oct. 8, 2021). 

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 monument and 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”). 

The final plan should include management direction for the development of a soundscape management plan that complies with the management direction in Alternative D, while also including provisions for periodic inventories of, monitoring of, and increasing public awareness and appreciation of and engagement with, natural soundscape resources. 

Row 134

Adopt the management direction for Alternative A, modified to make clear that the soundscape management plan must include components aimed at increasing public awareness and appreciation of and engagement with natural soundscape resources (Row 132); continuing to inventory and monitor natural soundscapes in partnership with local communities, universities, other agencies, and stakeholders (Row 133); and establishing quiet hours at campgrounds, designated camping locations, and other locations (Row 136). Alternative A should also be modified to include the following language from the 2000 MMP – Studies will be coordinated for areas that border adjacent National Parks. 

Row 134 Rationale

Developing a natural soundscape management plan is a critical strategy for achieving the goal of protecting the quality of the monument’s natural soundscapes and should be incorporated into the final plan. Actions to increase public awareness and appreciation of and engagement with natural soundscape resources, continuing to inventory and monitor natural soundscapes in partnership with local communities, universities, other agencies, and stakeholders, and establishing quiet hours would be critical and complementary components of that plan. 

Cross boundary coordination between agencies in inventory and monitoring, education and management are critical to ensuring the protection of natural quiet in the monument and adjacent parks. NPS strives to “preserve, to the greatest extent possible, the natural soundscapes of parks.5NPS, Soundscape Management Policy 4.9 (2006) available at” “In and adjacent to parks, the Service will monitor human activities that generate noise that adversely affects park soundscapes, including noise caused by mechanical or electronic devices.” Id. 

Row 135

Adopt the management direction for Alternative D.

Row 135 Rationale

The management direction for Alternative D is most consistent with protecting the quality of the natural soundscapes and other objects identified by the proclamation and are reasonable and attainable. The other alternatives, and especially Alternative A, are insufficient to achieve that goal and applicable mandates, and are insufficient to protect the natural quiet in national parks in areas adjacent to passage and outback areas in the monument.

Bryce Canyon has identified the “predominance and maintenance of natural quiet” as “an essential resource critical to visitor experience and the functioning of biological systems.”6Bryce Canyon National Park Foundation Document at 11, available at Indeed, “[d]uring sound monitoring efforts in the park, at some locations natural ambient decibel levels often were lower than data collection systems could measure, making Bryce Canyon an exceptionally quiet place.” Id. at 24. “However, this also means the quiet nature of the park—and by extension the visitor experience—are exceptionally susceptible to disturbance from extrinsic noise.” Id.

Similarly, natural quiet is an important part of visitors’ experience in Capitol Reef. There is currently “very little noise pollution in the park” and “[t]he backcountry areas of the park are managed for wilderness qualities, including natural quiet.” Capitol Reef Gen. Mgmt. Plan at 109. Thus, any “increase in noise that affects the natural quiet of the backcountry . . . would be considered significant.” Id.

To protect the natural quiet in the planning area and adjacent Parks, BLM should continue to manage with constraints on development and human activity and add stipulations or enforceable requirements to any permitted development or activity that has the potential to degrade the natural soundscapes.

Livestock Grazing

Row 172

Adopt the following management direction for livestock grazing in Glen Canyon NRA as proposed in Alternatives C and D – Allocate the pastures and allotments that are partially and fully within Glen Canyon as unavailable for livestock grazing, cancel any existing term grazing permits and prohibit new term grazing permits. In addition, allocate allotments adjacent to Bryce Canyon, Capitol Reef and Glen Canyon as unavailable to livestock grazing, cancel any existing term grazing permits and prohibit new term grazing permits.

Row 172 Rationale

Closing pastures and allotments partially and fully within Glen Canyon is the most effective way BLM can ensure non-impairment and protection of Glen Canyon values and purpose and that grazing management in the NRA will be approved by the National Park Service and consistent with their recommendations.

Management of Glen Canyon grazing allotments as proposed under Alternatives A and B does not meet BLM obligations to address conflicts between recreation users and livestock or to protect riparian and upland vegetation and cultural resources from grazing-related adverse impacts.

Glen Canyon operates under the same NPS Organic Act of 1916 as national parks, monuments, and historic sites with the fundamental purpose to “…. conserve the scenery and the natural and historic objects and wildlife 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.” Although the enabling legislation for Glen Canyon states that the administration of grazing leases within the recreation area shall be by BLM, it is also explicit that BLM administration of grazing inside Glen Canyon is subject to the provisions of the Organic Act i.e. with no resulting impairment to park values and purpose.

Several agreements between BLM and NPS (“Umbrella” Memorandum of Understanding 1984 Between Bureau of Land Management and National Park Service, Interagency Agreement between Bureau of Land Management and National Park Service for Grazing Management on Glen Canyon National Recreation Area) also state that before authorizing a grazing activity within Glen Canyon, NPS must determine if recreation area values and purposes are affected, a process called a “Values and Purposes Determination”. The values of the recreation area have been defined by NPS as the vegetation, soil, water quality, wildlife, archaeological, historic, paleontological, scenic and recreation resources that make up the scenic, scientific, and historic features which define the outdoor recreational use and enjoyment of Glen Canyon. Glen Canyon Grazing Mgmt. Plan 1999 at 2.

NPCA and the Coalition also encourage 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 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.

Recreation and Visitor Services

Proclamation 9682 severed the connection to the national parks with the removal of KEPA lands from the monument and opened lands adjacent to the parks to incompatible development and recreation including mining, drilling, target shooting and OHV access.

President Biden clearly intended to restore the connection between GSENM and the national parks in the broader landscape in Proclamation 10286 by enumerating the objects and values to be protected in lands adjacent to the parks including but not limited to: the Circle Cliffs “in the northeast corner of the Grand Staircase-Escalante landscape adjacent to Capitol Reef National Park”, “the Upper Escalante Canyons, adjacent to Capitol Reef National Park and Glen Canyon National Recreation Area” and “the Grand Staircase, a series of intensely colorful cliffs and plateaus that connect Bryce Canyon to the Grand Canyon.” Pres. Proc No. 10286, 86 Fed. Reg. 57,335 (Oct. 8, 2021)

The GSENM Resource Management Plan is the opportunity to return to managing the monument and the parks in an interconnected manner such that each unit serves as protection for its neighboring unit. To do this, we support the BLM’s proposal in Alternative C to reestablish zones to manage recreation as it did in the original plan for Grand Staircase-Escalante – compatible with management goals and objects for adjacent federal land, Tribal recommendations and traditional uses, and consistent with protecting monument objects and values.

Both Capitol Reef and Glen Canyon are managed by management zones. Almost the entire portion of Capitol Reef adjacent to GSENM is managed as a “Primitive Zone.” Capitol Reef Gen. Mgmt. Plan at 27. According to NPS: “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. Terrain is rough, trails are few, and opportunities for solitude is abundant. The visitor is surrounded by one of the most ruggedly beautiful and remote rockscapes in America, defined by craggy uplifts and deep, twisting canyons. . . . . Travel through this zone requires cross-country hiking or horseback riding on unimproved trails and routes.” Id. at 28.

Similarly, NPS has designated a significant portion of Glen Canyon’s land adjacent to the GSENM boundary as Glen Canyon’s “Natural Zone,” which “includes the recreation area’s outstanding scenic resources, relatively undisturbed areas isolated and remote from the activities of man . . ..”7Glen Canyon National Recreation Area General Management Plan (Glen Canyon Gen. Mgmt. Plan at 4-5).

While we support the establishment of management zones, we believe some of the management prescriptions for the proposed Special Recreation Management Areas (SRMAs) and Extensive Recreation Management Areas (ERMAs) and the Outback Areas will not adequately protect Monument objects and values or adjacent national parks. It is critical that BLM prioritize the protection of Monument objects and values over the enhancement of recreation and clearly articulate that throughout the plan.

Recreation and appropriate infrastructure should be concentrated in the front country and passage zones. Recreation management and infrastructure in the front country and passage zones leading to national parks (Burr Trail, Hole-in-the-Rock Road, etc.) should be coordinated with NPS to ensure management on both sides is compatible and does not increase access to sensitive resources or already crowded areas of the parks and monument (e.g., Coyote Gulch). The outback zone should more closely mirror management prescriptions for the primitive zone including vehicle number and group size limits, Right of Way exclusions, no competitive events, and minimal noise and development.

Row 194: Appendix E

BLM should adopt the proposed objective for Alternatives B/C/D with the following modifications to Appendix E.

In addition to clearly articulating that the priority in the recreation management areas will be protection of Monument objects and values and not recreation, the Agency should adopt the following management prescriptions for all specially designated areas, including those adjacent to or contiguous with NPS lands – 

• No prescriptions encouraging additional motorized or mechanized travel routes in specially designated areas

• No new airstrips allowed

• Require use of personal waste systems unless facilities are provided

• Prohibit commercial vending

• Prohibit competitive events, motorized and nonmotorized

Row 216

Adopt Alternative D which prohibits recreational target shooting throughout the monument.

Row 216 Rationale

Target shooting is inconsistent with the purpose of this monument. Prohibiting recreational target shooting will prevent damage to cultural resources and other Monument objects and values, will best protect natural soundscapes and wildlife in the Monument and in adjacent parks where recreational shooting is not allowed, and will increase visitor safety by eliminating target shooting along main travel routes where visitors are concentrated. With limited law enforcement staff in the monument and neighboring parks, prohibiting target shooting throughout the monument will be easier to manage and enforce.

Travel and Transportation Management

OHV and aircraft takeoff and landing areas, including drones, are incompatible with management of national parks and should be removed from park adjacent lands to preserve natural soundscapes, reduce incursions into parks where these activities are illegal and cut dust pollution, especially near Capitol Reef and Bryce Canyon, both designated Class I areas under the Clean Air Act. We are particularly concerned about roads designated as open to OHV access leading right up to park boundaries in remote areas where limited national park law enforcement rangers are unable to regularly monitor and enforce park closures.

Off-high way vehicle (OHV) recreation (also referred to as all-terrain vehicles (ATVs) and utility-task vehicles (UTVs)) is one of the fastest-growing recreation sectors in Utah and the AMS at 5-36 states “ATV and UTV use has become one of the fastest-growing—and one of the most controversial—recreational activities” in the monument.

OHV use diminishes the natural soundscape, generates emissions from both vehicle exhaust and the generation of increased particulates in the air (dust), can result in direct injury and/or mortality of big game species through collision, and can have direct and indirect adverse impacts on biological soil crusts, vegetation and water resources (especially surface-disturbing illegal off-road trespass).

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 OHV use outside park boundaries that cross illegally into national parks, which can intrude on natural quiet, negatively impact wildlife, crush fragile desert soils and plant life, and increase wind and water erosion. OHVs, including street legal ATVs, are not allowed on any roads inside Capitol Reef and Bryce Canyon National Parks and only on designated routes and areas inside Glen Canyon NRA. Therefore, we continue to urge the BLM to consider appropriate levels of OHV use both within the GSENM and adjacent to national park units, particularly roads that cross jurisdictions or are near park boundaries. 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, we maintain that allowing for increased use within and adjacent to protected landscapes risks resource damage.


Grand Staircase-Escalante plays a critical role in the region’s interconnected natural, cultural, and recreational landscape. With increasing recreation visitors and a changing climate, the BLM must actively manage for ecosystem function and connectivity in partnership with adjacent federal land managers. We urge you to adopt Alternative C (the preferred alternative) with modifications to enhance protections for preserving clean air, dark night skies, unspoiled vistas, natural soundscapes, native plants and wildlife, geologic and paleontological resources and other monument objects and values in the monument and neighboring national parks.

Thank you for your consideration of these comments and those of our members and supporters. As mentioned previously, in addition to these comments, we have also signed on to comments of our allies submitted by Grand Canyon Trust. 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.


Ernie Atencio
Southwest Regional Director
National Parks Conservation Association
PO Box 537
Arroyo Hondo, NM 87513

Cory MacNulty
Southwest Regional Campaign Director
National Parks Conservation Association
307 W 200 S, Suite 4004
Salt Lake City, UT 84101

Michael B. Murray, Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013






  • 1
    Proclamation 6920, 61 Fed. Reg. 50223 (Sept. 18, 1996).
  • 2
    Foundation Document, Bryce Canyon National Park, May 2014 at 6. (; see also Species Checklist for Bryce Canyon National Park at,2,4,5,3,11,12,7,9,6,8,10,13,14,16,15,17/false, viewed November 15, 2018.
  • 3
    See Species Checklist for Capitol Reef National Park at,viewed November 15, 2018; see also Capitol Reef National Park General Management Plan, September, 1998 at 79 (
  • 4
    See Species Checklist for Glen Canyon National Recreation Area at, viewed November 15, 2018.
  • 5
    NPS, Soundscape Management Policy 4.9 (2006) available at
  • 6
    Bryce Canyon National Park Foundation Document at 11, available at
  • 7
    Glen Canyon National Recreation Area General Management Plan (Glen Canyon Gen. Mgmt. Plan at 4-5).