Public Comment in regards to the :
BEARS EARS NATIONAL MONUMENT MONUMENT MANAGEMENT PLANS AND
ENVIRONMENTAL IMPACT STATEMENT
Dear United States Department of the
Interior, Bureau of Land Management and the United States Department
of Agriculture, U.S. Forest Service Officials;
I currently live in Moab, Utah and call
the greater Bears Ears region my backyard. I have been exploring this
area for over five years and find it to be one of the most unique,
remote, culturally rich and sensitive areas left in the Lower 48. One
of the reasons I enjoy this region so much is the primitiveness, the
solitude, the great number of archaeological sites, and the joy these
public lands bring to myself and many others.
I am highly disappointed that the
proposed management plan has been fast tracked and does not include
consideration for the original monument boundary that was made in
the first presidential designation under the Obama Administration.
Further management should not occur until court cases have been
completed and other management decisions have been considered to
include these areas that have been left out. We are missing out on a
large chunk of land that should be protected under the Antiquity Act.
After reading the extensive draft
management plan produced by the United States Forest Service and
Bureau of Land Management, I only have deeper concerns for the future
of this area. I am highly disappointed that Alternative D is the
preference. This alternative does not allow for ongoing monitoring,
puts multiple uses priority over wilderness, and does not identify or
allow for adaptive management principles. The proposed management
plan even states that having monument status will raise the profile
of Bears Ears to potential visitors, which in turns increases
visitation, and will impact the area greatly. Continuous monitoring
and adaptive, flexible management principles are critical to the
future of this sensitive area. I fully support Alternative C and
find it to be a flexible management plan that fully considers the
future of the Monument, while also not being extremely restrictive in
all areas.
Specific topics that stand out and are
of utmost concern are below with chapter numbers included:
Chapter 2.4.2.3 Management actions
for fire management
Alternative D allows for chaining to be
completed in areas where it has been previously chained is one
decision that should not be allowed in the Bears Ears Region. This
does not allow other agencies or tribes to have any say for a
practice that may at one time was a good idea. But in order to be
consistent with the protection, preservation, and restoration of the
monument objects and values, chaining must not be allowed or the
agencies must come to agreement. Therefore, Alternative A, B, or C is
preferred. It has been shown that chaining disrupts soil, vegetation,
habitat, land characteristics, and produces profound land scars,
where a larger chance of flood/rain impacts will occur.
Public Comment in regards to the :
BEARS EARS NATIONAL MONUMENT MONUMENT MANAGEMENT PLANS AND
ENVIRONMENTAL IMPACT STATEMENT
Dear United States Department of the
Interior, Bureau of Land Management and the United States Department
of Agriculture, U.S. Forest Service Officials;
I currently live in Moab, Utah and call
the greater Bears Ears region my backyard. I have been exploring this
area for over five years and find it to be one of the most unique,
remote, culturally rich and sensitive areas left in the Lower 48. One
of the reasons I enjoy this region so much is the primitiveness, the
solitude, the great number of archaeological sites, and the joy these
public lands bring to myself and many others.
I am highly disappointed that the
proposed management plan has been fast tracked and does not include
consideration for the original monument boundary that was made in
the first presidential designation under the Obama Administration.
Further management should not occur until court cases have been
completed and other management decisions have been considered to
include these areas that have been left out. We are missing out on a
large chunk of land that should be protected under the Antiquity Act.
After reading the extensive draft
management plan produced by the United States Forest Service and
Bureau of Land Management, I only have deeper concerns for the future
of this area. I am highly disappointed that Alternative D is the
preference. This alternative does not allow for ongoing monitoring,
puts multiple uses priority over wilderness, and does not identify or
allow for adaptive management principles. The proposed management
plan even states that having monument status will raise the profile
of Bears Ears to potential visitors, which in turns increases
visitation, and will impact the area greatly. Continuous monitoring
and adaptive, flexible management principles are critical to the
future of this sensitive area. I fully support Alternative C and
find it to be a flexible management plan that fully considers the
future of the Monument, while also not being extremely restrictive in
all areas.
Specific topics that stand out and are
of utmost concern are below with chapter numbers included:
Chapter 2.4.2.3 Management actions
for fire management
Alternative D allows for chaining to be
completed in areas where it has been previously chained is one
decision that should not be allowed in the Bears Ears Region. This
does not allow other agencies or tribes to have any say for a
practice that may at one time was a good idea. But in order to be
consistent with the protection, preservation, and restoration of the
monument objects and values, chaining must not be allowed or the
agencies must come to agreement. Therefore, Alternative A, B, or C is
preferred. It has been shown that chaining disrupts soil, vegetation,
habitat, land characteristics, and produces profound land scars,
where a larger chance of flood/rain impacts will occur.
Under Alternative D, wilderness
characteristics will not be managed in ROW and future ROW will lose
consistency of Monument objects and values. Alternative C will
provide more protection for objects, values, and wilderness
characteristics, where these facets should be more of a priority.
This chapter is vaguely described in
the draft management plan and needs to have more discussion. One of
the utmost priorities of the Monument is keeping wilderness
characteristics intact. The Monument region is extremely unique in
its remoteness and wild character. With the proposed Alternative D,
no provisions are mentioned to specifically to protect wilderness
characteristics. These sensitive areas within the Monument should NOT
be managed for multiple uses. Too much is at stake and too much can
be lost.
Both the Indian Creek and Shash Jaa
Units, must have the highest of standards for lands with wilderness
characteristics. This is what makes the Monument unique and must
continue to be managed in primitive standards. Alternative D is in no
way consistent with Wilderness Management goals. It is unclear why
Alternative D in this section is labeled as “not applicable”.
Preferably, Alternative B that states no new roads will be
constructed, designated OHV closed areas, use of hand tools for
vegetation treatment, and restrict the construction of unnecessary
new structures and facilities is a much better option for future
protection.
Under the draft management plan,
Alternative D does not provide the utmost protection of
paleontological resources. Alternative C provides more protection,
education, and future monitoring plans. Under Alternative D,
Potential Fossil Yield Classification (PFYC) 3 is not mentioned at
all. Also not mentioned under Alternative D is no plan for the
agencies to develop a survey and monitoring program for paleontology
resources along climbing routes. Over time, the agencies will have no
documents or idea of what has been lost or degraded over time in a
high use area such as a climbing area. Alternative D has no mention
of education or interpretation to inform recreational users of
importance of not impacting pale ontological resources. This is not
consistent with the Monument goals to protect and preserve objects
and values. There is zero mention of the high use areas of Indian
Creek to receive future monitoring plans to track impacts of
paleontological resources. Therefore, Alternative C would better
serve the Monument goals.
Under
Alternative D, pets may be allowed off leash. This will allow for
numerous problems including soil/vegetation impacts, pet waste, and
does not fall in line with the highest protection of cultural
resources within the Monument. Therefore, Alternative C is preferred
with the objective of having pets on a leash. Also under Alternative
D, target shooting would be allowed within the Indian Creek unit with
specific prohibitions. Under no circumstance, should target shooting
be allowed within any unit of the Monument. It is not ideal within
the Indian Creek Unit, as it is one of the most popular units with
numerous visitors. It is unsafe and with very little Ranger/Law
Enforcement officials within the area, it may be out of control if
not continuously monitored. The objectives of the Shash Jaa Unit are
more inline with Monument goals and should match the goals of the
Indian Creek Unit for more consistency. Also within the Indian Creek
Unit, under Alternative D, an organized event/activity group size of
25 OHV/mechanized vehicles, 50 individuals, or 15 pack animals is too
large. The Monument has numerous culturally and archaeological
sensitive areas that may be impacted by large numbers of visitors.
Sensitive ecological zones, washes, riparian areas, water driven
ecosystems (such as Indian Creek, the creek itself), and numerous
other fragile areas are at high risk. OHV groups do not always stay
on the designated trail and have easier means to disturb a large
area. Also, large groups, especially OHVs cause an extreme amount of
noise pollution. Therefore, Alternative B is ideal with having group
size limited to 12 OHV, 35 individuals, or 12 pack animals is a more
reasonable goal. This would greatly reduce impacts to the highly
sensitive objects and values of the Monument.
For the Shash Jaa Unit of the Monument,
with the preference of Alternative D, pets may be allowed off leash.
This will allow for numerous problems including soil/vegetation
impacts, pet waste, and does not fall in line with the highest
protection of cultural resources within the Monument. Therefore,
Alternative C is preferred with the objective of having pets on a
leash. Also under Alternative D, target shooting would be allowed
within the unit with specific prohibitions. Under no circumstance,
should target shooting be allowed within any unit of the Monument. It
is unsafe and unnecessary. Also within the Shash Jaa Unit, under
Alternative D, an organized event/activity group size of 25
OHV/mechanized vehicles, 50 individuals, or 15 pack animals is too
large. The Monument has numerous culturally and archaeological
sensitive areas that may be impacted by large numbers of visitors.
Sensitive ecological zones, washes, riparian areas, and numerous
other fragile areas are at high risk. OHV groups do not always stay
on the designated trail and have easier means to disturb a large
area. Also, large groups, especially OHV cause an extreme amount of
noise pollution. Therefore, Alternative B is ideal with having group
size limited to 12 OHV, 35 individuals, or 12 pack animals is a more
reasonable goal. This would greatly reduce impacts to the highly
sensitive objects and values of the Monument.
Under both units, it is imperative to
plan to identify and restrict if needed for the future, if
reoccurring issues occur with recreation and visitor services. This
includes monitoring of soil, vegetation, trails, roads, and
archaeological/cultural resources. The preferred alternative D does
NOT identify or state adaptive management of trails, routes, and
includes no reclamation procedures. These all need to be included in
the future management as tourism is likely to increase in the
Monument over the years.
2.4.16.1 Soil and Water Resources
As far as the preferred alternative D
in regards to woodland habitat, the plan should account for more
archaeological sites (impacts on natural or cultural resources). Once
again, this conflicts with the goals of protecting the Monuments
objects and values.
There is numerous data missing from
Chapter 3 of the proposed management plan, the in-availability of
data and incomplete information is astounding. It is suggested to
have more NEPA documents available for site specific data. In
section 3.512, is was stated that only 8 % of cultural/archaeological
resources in the BLM Shash Jaa unit has been surveyed for cultural
resources and only 32% on USFS land. There is a high probability or
cultural resources to be found in Shash Jaa Unit and further surveys
should occur and be taken into account for future management. In
section 3.5.1.2.2 the surveyed cultural resources have only been
14.7% for the Indian Creek Unit. This is only a fraction of what is
still to be found and researched. Once we lose archaeological
treasures, we will never get them back.
The loss of “integrity” of these
cultural values and resources will be astounding.
Changes to access will occur with
further development. It is imperative that cultural landscapes, TCP,
sacred Indian sites that have currently not been documented, should
be evaluated and included in the Monument management plan.
As far as recreation and visitor
services, including the protection of paleontology, and cultural
resources, we can not rely only on self regulation and education.
More Field Rangers through the BLM and USFS is of utmost importance
and more Law Enforcement Rangers need to make a big presence,
especially as visitor use goes up in numbers. Popularity and
overcrowding might not occur within the next few years, but land
managers need to think long term and what is best for the Monument
for the future.
Alternative D provides no no option to
close routes if great impacts occur. Alternative D allows for the
most grazing and allows for the most open areas for land use
authorizations. This does not hold inline with the Monuments goals
and objectives. Some restrictions should occur.
The wilderness characteristics of the
Monument, such as: naturalness, solitude, primitive and unconfined
recreation must be obtained throughout the years. Alternative D
protects zero acres of lands managed to protect with wilderness,
while Alternative C will allow for 43, 000 acres to be protected for
future generations. It is clear that Alternative D allows multiple
uses over protecting wilderness characteristics.
It is utmost importance that all tribes
be fully involved in the planning process and take deep consideration
of their wishes for this sacred piece of land that has been a part of
many generations throughout time. The Navajo, Ute, Navajo, and Hopi
tribes should work closely with government to government cooperation.
The management plan for Bears Ears
National Monument NEEDS adaptive management with some limitations and
Alternative C can provide that. Please deeply consider all previous
comments and suggestions with deep thought and remember the
importance of the greater Bears Ears region and why this place was
protected in the first place.
Kind regards,
Crystal Muzik
Under Alternative D, wilderness
characteristics will not be managed in ROW and future ROW will lose
consistency of Monument objects and values. Alternative C will
provide more protection for objects, values, and wilderness
characteristics, where these facets should be more of a priority.
- Alternatives for lands with wilderness characteristics
This chapter is vaguely described in
the draft management plan and needs to have more discussion. One of
the utmost priorities of the Monument is keeping wilderness
characteristics intact. The Monument region is extremely unique in
its remoteness and wild character. With the proposed Alternative D,
no provisions are mentioned to specifically to protect wilderness
characteristics. These sensitive areas within the Monument should NOT
be managed for multiple uses. Too much is at stake and too much can
be lost.
Both the Indian Creek and Shash Jaa
Units, must have the highest of standards for lands with wilderness
characteristics. This is what makes the Monument unique and must
continue to be managed in primitive standards. Alternative D is in no
way consistent with Wilderness Management goals. It is unclear why
Alternative D in this section is labeled as “not applicable”.
Preferably, Alternative B that states no new roads will be
constructed, designated OHV closed areas, use of hand tools for
vegetation treatment, and restrict the construction of unnecessary
new structures and facilities is a much better option for future
protection.
- Paleontology resources
Under the draft management plan,
Alternative D does not provide the utmost protection of
paleontological resources. Alternative C provides more protection,
education, and future monitoring plans. Under Alternative D,
Potential Fossil Yield Classification (PFYC) 3 is not mentioned at
all. Also not mentioned under Alternative D is no plan for the
agencies to develop a survey and monitoring program for paleontology
resources along climbing routes. Over time, the agencies will have no
documents or idea of what has been lost or degraded over time in a
high use area such as a climbing area. Alternative D has no mention
of education or interpretation to inform recreational users of
importance of not impacting pale ontological resources. This is not
consistent with the Monument goals to protect and preserve objects
and values. There is zero mention of the high use areas of Indian
Creek to receive future monitoring plans to track impacts of
paleontological resources. Therefore, Alternative C would better
serve the Monument goals.
- Recreation and Visitor Services - Indian Creek Unit
Under
Alternative D, pets may be allowed off leash. This will allow for
numerous problems including soil/vegetation impacts, pet waste, and
does not fall in line with the highest protection of cultural
resources within the Monument. Therefore, Alternative C is preferred
with the objective of having pets on a leash. Also under Alternative
D, target shooting would be allowed within the Indian Creek unit with
specific prohibitions. Under no circumstance, should target shooting
be allowed within any unit of the Monument. It is not ideal within
the Indian Creek Unit, as it is one of the most popular units with
numerous visitors. It is unsafe and with very little Ranger/Law
Enforcement officials within the area, it may be out of control if
not continuously monitored. The objectives of the Shash Jaa Unit are
more inline with Monument goals and should match the goals of the
Indian Creek Unit for more consistency. Also within the Indian Creek
Unit, under Alternative D, an organized event/activity group size of
25 OHV/mechanized vehicles, 50 individuals, or 15 pack animals is too
large. The Monument has numerous culturally and archaeological
sensitive areas that may be impacted by large numbers of visitors.
Sensitive ecological zones, washes, riparian areas, water driven
ecosystems (such as Indian Creek, the creek itself), and numerous
other fragile areas are at high risk. OHV groups do not always stay
on the designated trail and have easier means to disturb a large
area. Also, large groups, especially OHVs cause an extreme amount of
noise pollution. Therefore, Alternative B is ideal with having group
size limited to 12 OHV, 35 individuals, or 12 pack animals is a more
reasonable goal. This would greatly reduce impacts to the highly
sensitive objects and values of the Monument.
- Recreation and Visitor Services - Shash Jaa Unit
For the Shash Jaa Unit of the Monument,
with the preference of Alternative D, pets may be allowed off leash.
This will allow for numerous problems including soil/vegetation
impacts, pet waste, and does not fall in line with the highest
protection of cultural resources within the Monument. Therefore,
Alternative C is preferred with the objective of having pets on a
leash. Also under Alternative D, target shooting would be allowed
within the unit with specific prohibitions. Under no circumstance,
should target shooting be allowed within any unit of the Monument. It
is unsafe and unnecessary. Also within the Shash Jaa Unit, under
Alternative D, an organized event/activity group size of 25
OHV/mechanized vehicles, 50 individuals, or 15 pack animals is too
large. The Monument has numerous culturally and archaeological
sensitive areas that may be impacted by large numbers of visitors.
Sensitive ecological zones, washes, riparian areas, and numerous
other fragile areas are at high risk. OHV groups do not always stay
on the designated trail and have easier means to disturb a large
area. Also, large groups, especially OHV cause an extreme amount of
noise pollution. Therefore, Alternative B is ideal with having group
size limited to 12 OHV, 35 individuals, or 12 pack animals is a more
reasonable goal. This would greatly reduce impacts to the highly
sensitive objects and values of the Monument.
Under both units, it is imperative to
plan to identify and restrict if needed for the future, if
reoccurring issues occur with recreation and visitor services. This
includes monitoring of soil, vegetation, trails, roads, and
archaeological/cultural resources. The preferred alternative D does
NOT identify or state adaptive management of trails, routes, and
includes no reclamation procedures. These all need to be included in
the future management as tourism is likely to increase in the
Monument over the years.
2.4.16.1 Soil and Water Resources
As far as the preferred alternative D
in regards to woodland habitat, the plan should account for more
archaeological sites (impacts on natural or cultural resources). Once
again, this conflicts with the goals of protecting the Monuments
objects and values.
There is numerous data missing from
Chapter 3 of the proposed management plan, the in-availability of
data and incomplete information is astounding. It is suggested to
have more NEPA documents available for site specific data. In
section 3.512, is was stated that only 8 % of cultural/archaeological
resources in the BLM Shash Jaa unit has been surveyed for cultural
resources and only 32% on USFS land. There is a high probability or
cultural resources to be found in Shash Jaa Unit and further surveys
should occur and be taken into account for future management. In
section 3.5.1.2.2 the surveyed cultural resources have only been
14.7% for the Indian Creek Unit. This is only a fraction of what is
still to be found and researched. Once we lose archaeological
treasures, we will never get them back.
The loss of “integrity” of these
cultural values and resources will be astounding.
Changes to access will occur with
further development. It is imperative that cultural landscapes, TCP,
sacred Indian sites that have currently not been documented, should
be evaluated and included in the Monument management plan.
As far as recreation and visitor
services, including the protection of paleontology, and cultural
resources, we can not rely only on self regulation and education.
More Field Rangers through the BLM and USFS is of utmost importance
and more Law Enforcement Rangers need to make a big presence,
especially as visitor use goes up in numbers. Popularity and
overcrowding might not occur within the next few years, but land
managers need to think long term and what is best for the Monument
for the future.
Alternative D provides no no option to
close routes if great impacts occur. Alternative D allows for the
most grazing and allows for the most open areas for land use
authorizations. This does not hold inline with the Monuments goals
and objectives. Some restrictions should occur.
The wilderness characteristics of the
Monument, such as: naturalness, solitude, primitive and unconfined
recreation must be obtained throughout the years. Alternative D
protects zero acres of lands managed to protect with wilderness,
while Alternative C will allow for 43, 000 acres to be protected for
future generations. It is clear that Alternative D allows multiple
uses over protecting wilderness characteristics.
It is utmost importance that all tribes
be fully involved in the planning process and take deep consideration
of their wishes for this sacred piece of land that has been a part of
many generations throughout time. The Navajo, Ute, Navajo, and Hopi
tribes should work closely with government to government cooperation.
The management plan for Bears Ears
National Monument NEEDS adaptive management with some limitations and
Alternative C can provide that. Please deeply consider all previous
comments and suggestions with deep thought and remember the
importance of the greater Bears Ears region and why this place was
protected in the first place.
Kind regards,
Crystal
*Opinions expressed are solely my own and do not express the views or opinions of my employer.
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