The BLM is accepting public comments on the Indian Creek and Shash Jaa’ units of Bears Ears National Monument until November 15, 2018. Please consider making the following points when submitting comments.
To submit comments online, visit https://p2a.co/TGrcoBU
Because the BLM and USFS are only planning for 15% of the original Bears Ears boundaries in the current process, the most protective management possible for the area must be applied. All management decisions considered under the current process must prioritize the protection of the resources the Monument was designated to protect.
Under the BLM and USFS’s current plan, cultural resources are left at risk. The BLM’s proposal to develop cultural resource monitoring and management strategies two years down the road is not sufficient. The BLM must proactively consult with interested Tribes to develop solutions to protect these resources before it is too late by committing to develop an interim approach that can be implemented as soon as the management plan is completed. The agencies must also work with the Tribes to develop a broader plan and ensure the process is meaningful and inclusive of Tribal interests, not just condensed into the Trump administration’s arbitrary one-year timeline. The BLM should stop prioritizing speed and begin prioritizing Tribal involvement.
In completing a final plan, BLM should focus on the following:
- BLM should manage for the protection of the entire Bears Ears landscape for cultural and paleontological resources — including ongoing inventory and management.
- The agency, in co-management with the interested Tribes, should maintain the option to close or reroute social trails when cultural resources are threatened, instead of relying primarily on educational principles for the public.
- The BLM should manage identified lands with wilderness characteristics for wilderness values, as this provides protection for cultural resources, paleontological resources, and other irreplaceable Monument objects.
- The BLM and USFS should consider one alternative that extends management for the entire Bears Ears National Monument boundaries, as outlined in President Obama’s 2016 proclamation. 85% of the original Bears Ears boundaries should not be left out through this planning process while the legality of Trump’s Proclamation is being challenged in court. (words taken from Southern Utah Wilderness Alliance,
You may email your comment to: blm_ut_monticello_monuments@blm.gov
Include your address, telephone, email.
Shash Jae Unit: butler wash, san juan
river, bears ears buttes, comb ridge, arch canyon, mule/fish canyon,
doll house ruin, moon house ruing
Indian Creek Unit: lockhart basin,
harts point, Bjack mesa, lavendar mesa, shay canyon,
Alternative D : preferred action
Cultural Resouces: management
actions---agreed page 2.4.1.2 page 24
- Management actions for fire management
alternative B preferred: chaining
disrupts soil, vegetation, habitat, land characterists, land scars
(more chance of flood/rain impacts)
ROW: 2.4.3.3 alternatives for land and
realty
preferred alternative C: more
protections for objects and values of monuments, wilderness
characterists is more of a priority (for both indian creek and shash
jae unit)
- Alternatives for lands with wilderness characterics
Alternative B is preferred, most
protection for unique areas, NOT multiple use in these senstive areas
(both units)
both units: alternative B : no new
roads, ohv closed areas, only hand tools, restrict consturction of
new structes/facilities ((((alternative D: not applicalbe/ WHY?))
- paleotogical resoyrces
alt c, include class PFYC 3 (this is is
not in alt. d)
alt c, more protection while allowung
climbing other uses
alt c, indian creek unit, MUST have
education to inform recreational users of not impacting
paleontological resources
alt c, MUST develop future monitoring
plan to track impacts, volunteers useful to further this goal,
2.4.7.4
Recreation-Indian Creek Unit
alt c: pets must be on a leash (pets
wander, etc, soil impacts)
alt B: target shooting NOT allowed (too
many visitor impacts)
ALT B: OHV/ groups limitied to 12
sensitive ecological zones, washes, OHV to go off roads, noise
impacts, soil impacts, water driven alt ecosystem, indian creek
itself (water), fragile areas,
- Recreation- shash jaa unit
alt B: no new trails, sites, facilities
unless necessary to maintain objects/values (main purpose of
monument) !
2 - Shash Jaa
PETS (no one to monitor pet use)
25 OHV is too many under alternative D
PLAN to identify, and restrict if
needed for future, if reoccuring issus
NOT including monitoring of soil, etc
(recreation)
NOT identify or adapative mgmt of
trails, routes, no reclamtion
- soil and water resources
alt. D not accounting for full spectrum
of bird (nesting )
2.4.16.1
woodland ---> account for more
arcahelogical sites (impacts on natural or cultural resources)
CONFLICTS with monouments objects and VALUES
CHAPTER 3
- availability of data and incomplete information
(have more NEPA documents) for site
specific data
3.512
ONLY 8 % in blm shasa jaa unit has been
survyed for culutural resources
32% on USFS
HIGH probability in shash Jha Unit
- inidian creek
meidum probability 14.7% has been
survyed
Traditional Cultural Poperty
Bears Ears Buttes
ute, navajo, hopi, ute, elk ridge
LOSS Of “integrity” cultural
value, /resource
(actions that permit site disturbance)
changes to access !!!!! will occur !!!
culutral landscapes, TCP, sacred indian
sites have NOT been documented
cant rely ONLY on self regulation and
education
no option to close routes if great
impacts occur
alt d allows for most grazing
alt d allows for the most open areas
for land use authorizations
wilderness: naturalness, solitude,
prmitive and unconfined recreation must be obtained throughout the
years (over 61,000 acres in shash jaa unit, 39,000 acres in indian
creek unit)
alt D protects zero acres of lands
mangeaged to protect with wilderness, alt c, allosw 43, 000
ALT D allows multiple uses over
protecting wilderness characteristics
alt d – multiple uses, present risk
to paleotological resources
SOUNDSCAPES !
NEED adaptvie management with SOME
limitations
19% of riparion area open to new ROWs
in alternative D, zero percent in alt C
-monument- status raises the profile to
potential visitors, increases visitation,
-less assurance of future habitat and
resource conservation (alt d)
-popularity and over crowding,
OHV limited, increase risk of going off
desinated route with impact to vegetation and soils
must have full support and cooperation with tribes !!! Navajo Nation, Hopi Tribe, Ute Mountain Ute Tribe, Pueblo of Zuni, and Ute Indian Tribe,
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