Grand Staircase-Escalante National Monument proposed management plan and protest period

We have one more opportunity to provide input on the future of the lands of Grand Staircase National Monument (GSENM), a future that will include minimal protections to the landscape and natural and cultural resources if the newly-released management plan goes into effect. The reasons that inspired the initial designation of Monument status are congruent with the reasons we as bikepackers seek backcountry travel by bike through GSENM. The entire planning area is one of the most scenically pristine areas in the United States, including for nighttime dark skies. We value clean air to breathe, and dark skies to sleep under. Many of us live in parts of the country where this is not an option, and bikepacking across this landscape provides a rare and valuable opportunity. As bikepackers, we value the opportunity to ride through open, wild landscapes with minimal human development. GSENM as managed as a monument offers rare opportunity for solitude, remote travel, and healthy, minimally impacted landscape.

Last month, the Bureau of Land Management (BLM) released a plan to open nearly all of the lands removed from Grand Staircase Escalante National Monument (GSENM) to mining and drilling. President Trump’s unprecedented Monuments reduction cut 900,000 acres from GSENM, a decision that is currently being challenged in court. And just two weeks ago, the BLM released their proposed management plan for the remaining GSENM lands within the greatly reduced Monument boundaries, further undermining the protections granted by National Monument status. These plans threaten cultural and historical sites and wilderness qualities from increased mining and grazing leases, the prioritization of motorized travel and road development, and non-native grass seeding. The BLM chose the least protective version of the four draft plan options considered after a public comment period in the fall of 2018. Bikepacking Roots submitted our own commented at that time, and we urged members to do the same and provided a number of our concerns related to how the different options would potentially affect the bikepacking experience.

Why should we, as bikepackers, care about this? GSENM offers bikepackers a particularly remote and undeveloped high desert bikepacking experience on a network of 4x4 roads that traverse the wild valleys and plateaus of southern Utah. Our Plateau Passage and Wild West Route explore parts of GSENM, and the Cottonwood, Skutumpah, and Smokey Mountain Roads have long been popular with bikepackers and bike tourers. The quiet and wild experiences afforded in this Monument would be drastically altered by some of the changes we're likely to see should the protections of National Monument status be removed - coal mining, the chaining of native pinion and juniper forests to promote grazing, paving of some of the gravel roads, and more.

We strongly encourage other bikepackers to share their concerns with the BLM and to to advocate for greater protections for GSENM and the integrity of future protections granted by National Monument status. The most effective comments will cite specific sections of the management plan with specific concerns. To see our suggestions on what you might include in your own commenting, please see our annotated section references below.

Comments are due on September 23, 2019.
 
To learn more about the management plan, check out this concise article published by the Salt Lake Tribune. And just this week, the Department of the Interior’s Board of Land Appeals halted the BLM's plans to chain native pinyon-juniper forest and sagebrush stands in one large area within GSENM for cattle grazing range development (a process that generally involves two bulldozers dragging a large chain through the woodlands to uproot trees in their entirety). This highlights the level of protection, or lack thereof, being given to an area with designated National Monument status. The Southern Wilderness Alliance details here the implications of the Board of Land Appeals' decision and how you can support the continued protection of native habitat in GSENM.

To see the full plan and final environmental impact statements, visit the BLM's GSENM planning website and look for the "Volume 1: Chapters 1-4 of GSENM-KEPA Proposed RMPs/Final EIS" document.

To submit your own protest, follow this link to the BLM website, look for the "Volume 1: Chapters 1-4 of GSENM-KEPA Proposed RMPs/Final EIS" document, and then click on the "Submit Protest" button at right.

The overarching theme of the proposed plan is notably reducing protections on resources in GSENM. Thousands of additional acres are opened to livestock grazing and rangeland development (and some subject to native forest removal and reseeding for increased livestock forage), roads will be paved and/or further developed and greater OHV use will be permitted, constraints will be lessened on mineral leasing and mineral materials disposal, group size restrictions are reduced, and zero acres are managed for their wilderness qualities. These notably reduced protections outlined in the proposed management plan are acknowledged to reduce air quality, degrade wildlife and fish habitat, decrease soil, water and vegetation health, and alter, harm or destroy cultural and paleontological artifacts and sites.

In our initial comment submitted in November, 2018 and in the talking points we recommended including in public comments at that point, we raised a number of concerns. These were related to how the then-proposed alternative management plan options failed to address key concerns that would negatively affect the bikepacking experience and would harm natural and cultural resources. The now-preferred management plan alternative, Alternative D, offers nothing to mitigate our original concerns, and we strongly urge GSENM management to remain under the directive of the No Action/Current Management Plan. This plan, what GSENM has been managed under in recent years, offers far more extensive protections to the scenic, cultural, ecological, and human-powered recreation values.
 
Based on our original comments, we would like to clearly point out the following specific examples of how our original concerns have not been addressed in the new proposed management plan.
 
11.17.2018: Under 2-3.13, mineral leasing for oil/gas/geothermal, Alternative D (Preferred Alternative) opens nearly all of the lands removed from monument status by the president to oil gas and coal development.

9.19.19 protest: The proposed plan “places the fewest constraints on mineral leasing and mineral materials disposal in GSENM. 650,888 acres (of 861,538 total acres) in Kanab-Escalante Planning Area (KEPA) is opened to mineral development. Only 120,990 of these acres have major constraints; the rest are moderate. Opening these lands to drilling, strip mining, and underground mining would have incredibly detrimental effects on the largely undisturbed natural values of the greater GSENM landscape. These values are what draw bikepackers to this region – the opportunity to ride for hours on 4x4 roads without seeing other cars, to traverse large landscapes without traveling among mineral extraction operations and large-scale grazing operations. This is a rarity in the West, and it is one of the most unique values of the original GSENM.
 

11.17.2018: Under 2.3.71, when outlining management of vegetation, destruction of native piñon-juniper forest for range improvement to support increased cattle grazing (2.3.12). Increased cattle grazing will have a detrimental impact to the biological soil crusts of GSENM lands; reduced biological soil crust coverage will decrease air quality as dust is increased.  

9.19.19 protest: The proposed plan opens up the most acres to livestock grazing in GSENM (991,874 acres), and prioritizes rangeland health. This increases emissions and reduces air quality in GSENM. Again, our largest concern with this is the chaining and destruction of native forests – uprooting tens of thousands of acres of native vegetation to support increased grazing should not be done within any National Monument. We acknowledge that GSENM is and will be a “working Monument,” grazing should be permitted only in areas where it will not damage remaining soil crust and with herd sizes that can be supported by the naturally-occurring native forage.
 

11.17.2018: Under 2.3.14, plan D opens up lands to cross-country off-road vehicle play and increases the number of legal off-road vehicle routes in the backcountry.

9.19.19 protest: The proposed plan opens 1,002,350 acres to OHVs, and there are only 1,464 acres of OHV closure within the Monument. Identified OHV routes are increased under the new plan. As mentioned earlier, solitude and seldom-traveled roads are among the most attractive elements of GSENM for cyclists. Increased OHV traffic will eventually lead to GSENM feeling (and sounding) like so many other areas in the West that are dominated by motorized recreation. This should not be the case within a National Monument.
 

11.17.2018: Under 2.3.5, the Preferred Alternative calls for allowing “casual collection” of fossils by anyone. This would legalize the removal of any fossils by anyone, opening up the risk of rare specimens being removed from GSENM.

9.19.19 protest: Although casual fossil collection is not permitted under the proposed plan, the plan will result in increased impact – disruption or destruction – of cultural and paleontological resources due to increased OHV access, lessened protective measures on resources and increased resource extraction and associated surface disturbance with mining, drilling, and road development, and a smaller area managed for the protection of wilderness characteristics.
 

9.19.19 Protest: Additionally, the proposed plan poses the greatest threat and likelihood for disturbing wildlife, fish and special status species by reducing protective measures such as increasing group size, reducing resource-specific protective measures that increase habitat degradation through surface disruption (ie: mining, grazing, drilling), and applying fewer restrictions on OHV use and competitive events. In the proposed plan, only four localized areas are managed within the already-halved GSENM with appropriate protection of a SRMA.
 
Ultimately, the proposed plan dramatically reduces protection of the resources integral to the health and future of the GSENM lands; this poses a notable threat to the future of this landscape and our bikepacking opportunity for generations to come. We strongly request that you do not implement a change in management until after the current litigations around the Monument reduction are settled, and once settled continue to manage GSENM and KEPA (the Kanab-Escalante Planning Area) under the directive of the No Action/Current Management Plan.