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  #1  
Old November 14th, 2012, 02:15
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Outdoor industry calls for Utah Canyonlands monument

Quote:
PUBLIC LANDS: Outdoor industry calls for Utah Canyonlands monument

Phil Taylor, E&E reporter
Greenwire: Tuesday, November 13, 2012


A coalition of outdoor recreation businesses today asked President Obama to designate a national monument protecting 1.4 million acres of federal lands in southern Utah.

The Outdoor Industry Association in a letter today urged Obama to use his Antiquities Act authority to protect Greater Canyonlands, an area surrounding Canyonlands National Park that it described as a "geologic wonderland and a treasure trove of ancient cultural and archaeological artifacts."
"Many of us know and love the Greater Canyonlands area firsthand, and would like to see the area preserved because it is a premier part of our nation's natural heritage," the group wrote. "But as people who make their living in the outdoor industry, we also want to stress that preserving landscapes like Greater Canyonlands makes good economic sense. Wildlands are the foundational infrastructure for our industry."

The campaign is the latest show of political strength by OIA, a trade group that has threatened to yank its semiannual trade show from Salt Lake City if Utah state officials do not soften their stance on federal land management. Members include outdoor retailers Patagonia, JanSport and Black Diamond Equipment, as well as a bevy of outfitting shops.

The Canyonlands proposal is one of several by conservation groups urging Obama to take unilateral action to protect public lands. In a divided Congress, few expect to see significant conservation bills pass.

In its letter, OIA warns that the Bureau of Land Management's plans allow damaging off-highway vehicle use and would open scenic and primitive areas to oil and gas drilling and mining.

The Southern Utah Wilderness Alliance is also lobbying for a Canyonlands monument and has enlisted the support of Aron Ralston, who cut his hand off after becoming trapped by a rock in the Canyonlands area, inspiring the movie "127 Hours."

The proposal was panned this morning by Rep. Jason Chaffetz (R-Utah).

"My starting point on the monument plan is NO," he wrote on Twitter. "I will work with all sides, but this is not the way to proceed."

Conservation groups are proposing monuments in New Mexico's Organ Mountains and Rio Grande del Norte, as well as Colorado's Brown's Canyon and a large swath of land north of the Grand Canyon, among other areas. Obama has designated four national monuments, none of them nearly as large as the Canyonlands proposal.
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  #2  
Old November 14th, 2012, 19:31
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Re: Outdoor industry calls for Utah Canyonlands monument

While this is troubling, I see it as a flawed plan in several ways. There isn't a single member of Congress from Utah who supports this action and several attempt by SUWA and their supporting groups have repeatedly failed to pass legislation that would restrict OHV access, oil and gas exploration, State Trust Land use, etc on these BLM managed public lands. (See Red Rock Wilderness Act)

If Obama, or any sitting POTUS were to create a national monument of the Greater Canyonlands Area, it would be open to lawsuit, as the action would be giving preference to businesses and manufacturers who focus on hiking, climbing, non-mechanical transportation and negatively impact the businesses and manufacturers which focus on mechanical and motorized forms of transportation (OHV, 4WD, Mtn Biking etc), not to mention the negative financial impact that it would have on the town of Moab, which has a tourism based economy.

The bigger issue here is the need to modify the American Antiquities Act of 1906, specifically Sec 2 ,http://www.nps.gov/history/local-law/anti1906.htm which gives the President authority and discretion to take this kind of action, without Congressional approval. This needs to be amended immediately. I suspect that we will see proposed legislation from members of Congress representing Utah, in the near future to do so.
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Old November 14th, 2012, 19:34
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I really want to see all of the various 4wd clubs, atv clubs, and other outdoor recreation clubs stand up and very publicly boycott these businesses. I'd like to see hundreds of jeeps in front if these stores with giant banners and signs giving them a huge black. Eye.
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Old November 15th, 2012, 01:51
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Re: Outdoor industry calls for Utah Canyonlands monument

A message from Del Albright:

Quote:
UTAH UNDER THE GUN FROM OUTDOOR INDUSTRY ASSOCIATION

Outdoor Industry Association (businesses making a living off the great outdoors) launches massive attack on Utah for more land restrictions, this time in the form of a new Monument Proposal that 100 businesses signed onto and sent to President Obama. I don’t think anyone asked Utah what they thought….???

Some companies that are in the forefront of closing lands seem to include: Teva, CamelBak, Moab Coffee Roasters, North Face, New Belgium Brewing, and more. I’m really surprised that REI did not sign on as they are usually in the lead for more Wilderness and motorized restrictions.

Pdf with companies listed: http://www.delalbright.com/Access/Ca...s%20letter.pdf
BRC Alert and what to do: https://www.sharetrails.org/alerts/2...pushed-in-utah

National leaders are taking a counter action to this, but you can help too. Go to the BRC alert and do what you can.

Thank you,
Del
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  #5  
Old November 15th, 2012, 09:59
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Re: Outdoor industry calls for Utah Canyonlands monument

For the lazy clickers...


Outdoor Industry Association--Boulder, CO--Frank Hugelmeyer
Black Diamond Equipment--Salt Lake City, UT--Peter Metcalf
Backcountry.com--Park City, UT--Jill Layfield
Eastern Mountain Sports--Peterborough, NH--Will Manzer
Petzl--Clearfield, UT--Roody Rasmussen
Western Spirit Cycling--Moab, UT--Ashley Korenblat
Patagonia--Ventura, CA--Casey Sheahan
PROBAR LLC--Salt Lake City, UT--Jules Lambert
Gregory Mountain Products--Salt Lake City, UT--Billy Kulczycki
Mountain Hardwear--Richmond, CA--Topher Gaylord
Canyon Voyages Adventure-Company--Moab, UT--Don and Denise Oblak
Rim Tours--Moab, UT--Kirstin Peterson
Teva--Goleta, CA--Joel Heath
Moki Mac--Green River, UT--Bob Quist
Moab Cliffs and Canyons--Moab, UT--Brett Sutteer
Jansport--Morland, KS--Skip Yowell
Lost River Clothing—Company--Moab, UT--Dave Knowles
Skinny Tire Events ----Road Cycling in Moab--Moab, UT--Beth Logan
Red Wing Shoes--Red Wing, MN--Bill Sweasy
Canyonlands Field Institute--Moab, UT--Karla VanderZanden
Miguel’s Baja Grill--Moab, UT--Dave Bodner
Camelbak--Petaluma, CA--Sally McCoy
Magpie Adventures--Moab, UT--Maggie Wilson
Ekletica Café--Moab, UT--Julie Fox
Prana--Carlsbad, CA--Theodosakis Beaver, Founder--Scott Kerslake, CEO

Moab Destination—Management--Moab, UT--Fiona Raison
Moab Coffee Roasters--Moab, UT--Jana Wilson
Osprey Packs--Mill Valley, CA--Michael Pfotenhauer
Horny Toad Activewear--Santa Barbara, CA--Kate Larramendy
With Gaia Design--Moab, UT--Kalen Jones
Marmot Mountain, LLC--Rohnert Park, CA--Mark Martin
North Face--San Leandro, CA--Ann Krcik
Nichols Expeditions--Moab, UT--Chuck and Judy Nichols
American Recreation Products--Boulder, CO--Brett Jordan
Nikwax Waterproofing--Seattle, WA--Chas Fisher
White Horse Residential Homes--Moab, UT--Mark Griffith
Bergans USA, LLC--Longmont, CO--Patry Loomis
The Conservation Alliance--Bend, OR--John Sterling
Desert Bistro--Moab, UT--Karl and Michelle Kelley
Aspen Skiing Company--Aspen, CO--Mike Kaplan
Backbone Media LLC--Carbondale, CO--Nate Simmons
High and Wild--Castle Valley, UT--Jay Smith
Adventure Bound River—Expeditions--Grand Junction, CO--Tom Kleinschnitz
Ute Mountaineer--Aspen, CO--Bob and Ruth Wade
Far Out Expeditions--Bluff, UT--Vaughn Hadenfeldt
Loki Outerwear--Grand Junction, CO--Seth Anderson
Whitewater West--Grand Junction, CO--Pete and Monica Atkinson
Bryce Valley KOA—Kampground--Cannonville, UT--John Holland
4 Corners Riversports--Durango, CO--Andy Corra
Pine Needle Mountaineering--Durango, CO--Jeremy Dakan
Imlay Canyon Gear--Mt. Carmel Junction, UT--Nolan Jones
Mountain Waters Rafting--and Adventure Co.--Durango, CO--James Wilkes & Dan Bechtel
Deer Hill Expeditions--Mancos, CO--Douglas and Beverly Capelin
Red Desert Adventures--Springdale, UT--Eric Draper
Kling Mountain Guides--Durango, CO--Josh Kling
Open Sky Wilderness Therapy--Durango, CO--Aaron Fernandes
Wasatch Touring--Salt Lake City, UT--Charlie and Dwight Butler
Verde PR and Consulting--Durango, CO--Kristin Carpenter-Ogden
Venture Snowboards--Silverton, CO--Klemens and Lisa Branner
The Family Outing--Murray, UT--Richard Luke
New Belgium Brewing--Ft. Collins, CO--Jenn Vervier
Neptune Mountaineering--Boulder, CO--Gary Neptune
International Mountain Equipment--Salt Lake City, UT--Scott Carson
La Sportiva--Boulder, CO--Jonathan Lantz
Scarpa--Boulder, CO--Kim Miller
Trio Restaurant Group--Salt Lake City, UT--Mikel Trapp
GTHI--Boulder, CO--Malcolm Daly
The Access Fund--Boulder, CO--Brady Robinson
SOAR Communications--Salt Lake City, UT--Chip Smith
Stohlquist WaterWare--Alamosa, CO--Jim Stolhquist
Outside Adventure Film School--Boulder, CO--Michael Brown
Outdoor Utah Adventure Guide--Salt Lake City, UT--Red Oelerich
Veterans Expeditions--Boulder, CO--Nick Watson
Army Ranger--Fishpond Inc.--Denver, CO--John Land Le Coq
Excalibur Distribution/DMM Inc.--Sandy, UT--Steve Petro
American Alpine Club--Golden, CO--Phil Powers
Stonewear Designs--Louisville, CO--Kitty Bradley
SNOCRU--Sundance, UT--Ed Lewis
NRS--Moscow, Idaho--Bill Parks
Chalk Bag Specialist--Pocatello, ID--San Krieg
Quality Bicycle Products--Ogden, UT--Steve Flagg
Asana Climbing--Boise, ID--Jamey Sproul
Wild Iris Mountain Sports--Lander, WY--Jennifer Barrett
Alpine Sports--Ogden, UT--Peggie Chambers Ambrey
Oceanmedix.com, LLC--Wilson, WY--Dennis Emory
The Base Camp--Billings, MT--Scott Brown
Thompson Manufacturing Inc.--Clearfield, UT--Rock Thompson
Outdoor Research--Seattle, WA--Dan Nordstrom
International Mountain Guides--Ashford, WA--Phil Ershler
Logan Outdoor Products/Camp Chef--Logan, UT--Ty Measom
Far Bank Enterprises--Bainbridge Island, WA--Travis Campbell
Mountain Gear--Spokane Valley, WA--Paul Fish
Ultralight Adventure Equipment--Logan, UT--Chris McMaster
Peak Sports--Corvalis, OR--Jeff Katz
Montrail--Richmond, CA--Topher Gaylord
Treasure Mountain Inn--Park City, UT--Andy Beerman
Mountain Tools--Carmel, CA--Larry Arthur
Mammoth Mountaineering Supply-- Mammoth Lakes, CA--Dave Talsky
Christoph & Company--Park City, UT--Lesley Christoph
Wilson’s Eastside Sports--Bishop, CA--James Wilson
Desert Rock Sports--Las Vegas, NV--Steve Mallory
Grassroots Outdoor Alliance--Park City, UT--Roanne Miller
Midwest Mountaineering--Minneapolis, MN--Rod Johnson
River Sports Outfitters--Knoxville, TN--Laura Jones
Burton Snowboards--Burlington, VT--Jake Burton Carpenter Donna Carpenter--Owners
Jetboil, Incorporated--Manchester, NH--Perry Dowst
Mammut Sports Group--Shelbourne, VT--Bill Supple
Penguin Brands--Greater Boston Area, MA--Donna Williams
River Runner Outdoor Center--Columbia, SC--Guy Jones
Pack and Paddle--Lafayette, LA--Rebecca Williams
Pack Rat Outdoor Center--Fayettville, AR--Carolyn Crook
Rabbit Mountain--Miami, FL--Edward Gerety
Equip--Derbyshire, UK--Matt Gowar
Exped--Zurich, Switzerland--Heidi Brun CEO
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  #6  
Old November 15th, 2012, 13:31
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Re: Outdoor industry calls for Utah Canyonlands monument

i'm surprised by a few of those companies. dang.
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  #7  
Old November 15th, 2012, 16:03
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Re: Outdoor industry calls for Utah Canyonlands monument

I've got product from ten of those companies on the list, including one of my favorite Moab restaurants (I may have lost my appetite there now)! The last paragraph of the letter was most telling, written just like every wilderness alliance statement and not at all representing the truth of the matter, which consists of countless closed spurs, wilderness study area boundaries, and further ignores the better efforts of the governing agencies travel management plans as if they don't exist.
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  #8  
Old November 15th, 2012, 17:48
Kman1983 Kman1983 is offline
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Re: Outdoor industry calls for Utah Canyonlands monument

I have been posting on the companies FaceBook pages and several have gotten irate and claim it doesn't mean eliminating 4x4 access before deleting my posts. I think many of them have NO CLUE what they signed. Also don't forget to boycott Ben & Jerrys they donated $30K to this group to close our trails here in Vermont: http://www.greatoldbroads.org/Broads...des_Fall08.pdf
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Old November 15th, 2012, 17:53
Kman1983 Kman1983 is offline
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Re: Outdoor industry calls for Utah Canyonlands monument

Oh and don't forget to sign the petition to protect our right to access public lands! It only takes a minute to register, https://petitions.whitehouse.gov/pet...Kn#thank-you=p
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Old November 15th, 2012, 20:17
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Re: Outdoor industry calls for Utah Canyonlands monument

Quote:
Originally Posted by Kman1983 View Post
I have been posting on the companies FaceBook pages and several have gotten irate and claim it doesn't mean eliminating 4x4 access before deleting my posts. I think many of them have NO CLUE what they signed. Also don't forget to boycott Ben & Jerrys they donated $30K to this group to close our trails here in Vermont: http://www.greatoldbroads.org/Broads...des_Fall08.pdf
seems so. red wing boots and camp chef have already redacted, the folks over at pirate are doing their part well.

i have a pic up on a fbook page i help manage....

http://www.facebook.com/photo.php?fb...type=1&theater

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  #11  
Old November 15th, 2012, 22:33
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So you are part of that page huh? I get laughs from their daily. One if the better vehicle specific FB pages IMO.
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  #12  
Old November 16th, 2012, 00:11
Rush Power Systems Rush Power Systems is offline
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Re: Outdoor industry calls for Utah Canyonlands monument

Quote:
Originally Posted by XJEEPER View Post
While this is troubling, I see it as a flawed plan in several ways. There isn't a single member of Congress from Utah who supports this action and several attempt by SUWA and their supporting groups have repeatedly failed to pass legislation that would restrict OHV access, oil and gas exploration, State Trust Land use, etc on these BLM managed public lands. (See Red Rock Wilderness Act)

If Obama, or any sitting POTUS were to create a national monument of the Greater Canyonlands Area, it would be open to lawsuit, as the action would be giving preference to businesses and manufacturers who focus on hiking, climbing, non-mechanical transportation and negatively impact the businesses and manufacturers which focus on mechanical and motorized forms of transportation (OHV, 4WD, Mtn Biking etc), not to mention the negative financial impact that it would have on the town of Moab, which has a tourism based economy.

The bigger issue here is the need to modify the American Antiquities Act of 1906, specifically Sec 2 ,http://www.nps.gov/history/local-law/anti1906.htm which gives the President authority and discretion to take this kind of action, without Congressional approval. This needs to be amended immediately. I suspect that we will see proposed legislation from members of Congress representing Utah, in the near future to do so.
I wish it were so, but we have Matheson, big lefty, who just barely beat Love. When he does not have the pressure of an election he sides with SUWA. And Clinton closed off a huge amount of Utah land, and bravely did so from Arizona, let’s face it Obama makes Clinton look conservative. And finally nothing will pass the senate, sorry to be so pessimistic, I like your plan better, just don’t see it.

I am so sick of the “outdoor retailers assoc” every year here in UT they start complaining about something and threatening to pull the convention from our state. This is followed by the lapdog media stories about how much money the convention generates. I am up for a 4x4 picket at the UT companies listed.
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Old November 16th, 2012, 13:03
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Re: Outdoor industry calls for Utah Canyonlands monument

I found this on Those Guy's Offroad it has an ARRA link.

Folks, this is very simple to do.... so do it!


Urge your Members to Oppose Efforts to Lock Up Enormous Tracts of Public Lands


Earlier this week non-motorized recreation groups joined a number of Utah businesses on a letter to President Obama urging him to designate 1.4 million acres of public lands in Utah as a National Monument. The letter stated, ?Federal land use plans inappropriately open scenic and undeveloped land to drilling and mining and fail to address exploding off-road vehicle use that is damaging riparian areas, cultural sites, soils and solitude? (emphasis added). Of course the letter fails to note that a recent management plan was put in place for the area that is supported by local governments and limits motorized and non-motorized activities to routes that have been subject to environmental analysis and public involvement. Further, the letter from non-motorized organizations cites an economic impact study that shows ?that outdoor recreation is ?an overlooked economic giant,? generating $646 billion in national sales and services in 2011 and supporting 6.1 million jobs...? Again, they are telling only part of the story. The same study shows that approximately $257 billion or nearly 40% of the total $646 billion in economic impact is derived from motorized recreation. And, as you know, motorized recreation is far too often shut out of National Monument areas.


ARRA and our partners are pushing back. Click here to view a response letter signed by 14 national organizations representing responsible motorized recreation. This letter is a start, but we need your help to ensure that the President understands that effective land management is best achieved through deliberative local processes that engage all stakeholders ? not through Administrative fiat.


Please click the Take Action link to send an email to the President opposing this and other massive, inappropriate designations of National Monuments. It is important for motorized recreation enthusiasts all across the country to weigh in as today anti-access organizations have targeted Utah, but tomorrow it may be your state.


http://www.arra-access.com/site/R?i=JomQAs7Z_hSBhiAVkxgHcA


Found Here:
http://thoseguysoffroad.com/tgorforu...ic,1616.0.html


Also found this on PNW Jeep

This is a list of companies that all signed a petition sent to the president to close canyon lands in moab to 4x4's. There is also a petition to sign that is countering their petition and asks the president to keep land open for all tax payer not just a select few.

https://petitions.whitehouse.gov/petition/not-exclude-4x4-community-enjoying-our-recreational-lands-country/s6BHJcKn?utm_source=wh.gov&utm_medium=shorturl&utm _campaign=shorturl


Attachments:
petition supporters list.jpg [ 84.25 KiB | Viewed 18 times ]

Found Here:
http://www.pnwjeep.net/forum/viewtopic.php?f=28&t=32452

Last edited by Icemans; November 16th, 2012 at 13:04. Reason: forgot link.
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Old November 17th, 2012, 02:29
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Re: Outdoor industry calls for Utah Canyonlands monument

Quote:
PUBLIC LANDS: Utah Republicans oppose 1.4M-acre Canyonlands monument

Phil Taylor, E&E reporter
Published: Friday, November 16, 2012


Utah's Republican lawmakers are opposing a proposal by conservationists and an outdoor industry group for President Obama to designate a national monument around Canyonlands National Park, arguing that such designations should be vetted by the public and carried out by Congress.

But conservation groups in Utah said they have been calling for the Bureau of Land Management to initiate a public comment process to protect the area since March 2011.

At issue is a proposal to turn 1.4 million acres of mesas, plateaus and canyons surrounding Canyonlands into a monument where off-highway vehicle use; uranium, potash and oil sands mining; and oil and gas drilling would be restricted.

The Outdoor Industry Association on Tuesday said it hopes to be a "catalyst" for broader discussion of a monument, arguing that the long-term economic benefits of conservation far outweigh any short-term gains from developing the lands for resource extraction (E&ENews PM, Nov. 13). In a gridlocked Congress, the president should use the Antiquities Act to immediately protect the area, they argued.
But Utah Sens. Orrin Hatch and Mike Lee and Reps. Rob Bishop and Jason Chaffetz in a letter to the president yesterday said congressionally authorized land-use proposals are more accountable and transparent to the public. In addition, resource extraction is an important economic driver in Utah and can be balanced with the preservation of open space, they said.

"We strongly urge the rejection of the most recent -- and all future -- petitions for national monument designations by presidential decree," they wrote.

Greater Canyonlands is one of several areas conservation advocates are targeting for potential monument designations during Obama's second term.

While such designations can curtail energy development and motorized access -- sparking accusations of "land grabs" by some Westerners -- supporters point to research suggesting national monuments improve quality of life and attract tourists, retirees and high-wage earners.

Still, monument proposals are politically dicey in Utah, a state that has vowed to "take back" federal lands and where many still seethe from President Clinton's 1996 designation of the 1.9-million-acre Grand Staircase-Escalante National Monument.

Bishop's office acknowledged the economic benefits from recreation on public lands but said a large portion of the revenue comes from motorized off-highway vehicles and mountain bikes, both of which are prohibited in wilderness areas.

In their March 2011 petition to protect the Canyonlands area, the Grand Canyon Trust, Southern Utah Wilderness Alliance, Sierra Club, National Parks Conservation Association and Natural Resources Defense Council asked BLM to temporarily close about 1,050 miles of primitive routes in the region while it studies the effects off-highway vehicles have on soil erosion, loss of native plant and animal life, degradation of air and water quality, damage to archaeological sites and impacts to nonmotorized visitors.
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Old December 8th, 2012, 22:09
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Re: Outdoor industry calls for Utah Canyonlands monument

Best response I've seen on the subject........Lynn Jackson nails it.


(Ashley Korenblat’s complete statement:http://sagebrushcoalition.com/2012/1...nlands-letter/ )

Rebuttal to the Outdoor Industry Association/Ashley Korenblat Statement on a Proposed National Monument for southeastern Utah

Lynn Jackson

December 6, 2012

My name is Lynn Jackson. I have lived and worked in southeastern Utah since 1964, in Carbon, Wayne and Grand counties. I was a geologist, supervisor and manager for the Bureau of Land Management in Hanksville and Moab for 32 years, retiring in 2010. I now do public land consulting, and in November was elected to the Grand County Council. My Council term does not start until January 2013, and my comments herein are my own, based on my own experience in this area, and are not intended to reflect the position of Grand County.

My comments are provided as rebuttal to Ashley Korenblatt’s recent written statement regarding the need for a National Monument in southeast Utah as proposed by the Outdoor Industry Association (OIA). I feel compelled at this time to address what I see are inaccurate, incorrect and misleading assertions identified as rationale for creation of this monument.


I think one of the general themes that I find so objectionable in this statement, is the purported eagerness to engage in a full dialogue and discussion regarding the future of our region, even though OIA has already petitioned the President to take unilateral action and create this Monument under the authority of the 1906 Antiquities Act. Regardless of the misinformation and scare tactics being utilized, as a westerner I find this backdoor methodology quite insulting. Westerners take pride in dealing in good faith. This is not good faith. It’s “trust us, we know what’s in your best interests and we’re all for talking about the future of the area, but oh by the way, we’ve already made an end run process around legitimate collaboration.” Even though, after decades spent in public land management in southeastern Utah, I fully understand and support the concept of setting aside and protecting some of our prized lands, for this very reason alone, I can’t and won’t support this disingenuous process they are engaged in.

The primary points I’d like to address in this rebuttal are based on the main themes I see in the statement, generally summarized as follows:

The proposed Monument and surrounding National Parks are in imminent danger of being destroyed by mineral development.
The BLM has no tools to manage these public lands and there is immediate need for the creation of a new “plan” for the public lands in the Monument area.
The recreation industry has been the primary economic growth engine in the western US for the past four decades.
Creating a Monument will clean up our air in the area.
The OIA proposal is completely separate from SUWA’s proposals for southeast Utah.
Establishing a one industry economy in southeastern Utah is to the benefit of all residents.
Creation of a new Monument would result in measurable and significant increases in visitor use to our already well known area.
The duplicitousness of the process OIA is utilizing.
Condoning the continued abuse of the 1906 Antiquities Act.
I’ll now address these point by point, with quotes from the statement in italics at the beginning.

1. The proposed Monument and surrounding National Parks are in imminent danger of being destroyed by mineral development.

“Several million acres …. have been identified for future and continued development of oil and gas, tar sands, potash, oil shale, uranium, and other extractive industries.”

*

“…And second, the growing number of drill pads, for example, on the road to Canyonlands is making me nervous. While currently the tar sands and oil shale areas are some distance from the park, there is technically no law in place that would keep those industries from working the land right up to the park boundary.”

*

“We have to find a mechanism for effective zoning in the region, or the ultimate winners will be the shareholders of the various Canadian companies who are currently seeking permits for potash and oil shale all around us.”

*

“Of course a drill pad here and a potash plant there may not be a significant detraction, but there are widespread proposals in our region for both oil and gas and potash, and tar sands and oil shale operations will result in huge sections of the land that would be off limits to all of us.”

These are extreme overestimations unless the statement is referring to the entire western United States. Based on my direct experience as a geologist and federal land manager for 32 years in this area, there is minimal risk of any massive scale mineral development occurring within the area identified for the proposed Monument, or even in areas I would consider as “adjacent “ to the Monument. There is potential for some relatively minimal level of mineral development, which to rural counties can mean a great deal in the form of well-paying year round jobs with benefits, and county tax revenues to provide local essential government services.

Of the mineral resources identified in the statement, the only one with potential for new development in the near term would be potash, utilized primarily in the fertilizer industry. When the worldwide price of potash increased in 2007-2008, applications were filed on approximately 600,000 acres of federal lands in our area to “explore” for the resource. From the hundreds of oil and gas exploration holes drilled in the region over the past 60-70 years, geologists have known that the area is underlain by deposits of potash 5,000 to 6,500 feet in depth. It is not technically feasible to mine the deposits at these depths. Recovery would have to be through drilling and solution mining techniques, a relatively new and yet to be proven method of recovery in our region in regards to development of a new property. We do not know the exact concentrations or thicknesses of this resource across the Paradox basin since the oil and gas exploration holes were not drilled to look for or analyze potash, and consequently they did not take potash core samples or utilize logging techniques conducive to evaluating the actual potash beds. Therefore, it is not unfeasible that potash companies could in fact conduct this exploration and end up determining that thicknesses and concentrations simply won’t allow for commercial development.

In addition to the depths of the resource, which make it technically unfeasible to recover by standard mining techniques, and uncertain concentrations and thicknesses, we need to factor in the worldwide market for potash. 70% of the world’s supply comes from Canada; in addition, they have reserves that make them the “Saudi Arabia” of potash. Even if potash exploration in our area shows there to be areas of commercial grade deposits, any subsequent development would limited in light of the Canadians ability to control the supply in the market and manage the price to assure their long term position is not threatened. It is my opinion that many of the applications are what I would refer to as primarily speculative, based on the dramatic price increase. This is very typical in all mineral industries whenever the commodity price increases rapidly. Of the dozen or so exploration applicants, only 3 of them are actively pursuing permits to allow for the exploration. If this exploration finds the resource to be commercial in these areas, at most we may see one or two small operations at the scale of the current potash plant below Dead Horse Point. The Intrepid plant along the Colorado river is the single largest tax paying entity in Grand County, adding $750,000 into Grand County’s annual budget of approximately $20 million dollars, and employing 50 – 60 workers on a year round basis.

In regards to oil shale within the area the OIA group proposes for a National Monument, there are no oil shale deposits present. None. All oil shale in the western United States occurs in younger geologic formations which have all been removed by erosion from this region with the exception of areas high in the Bookcliffs of northern Grand County. So we can take the oil shale “threat “completely off the table for purposes of Monument discussion.

There is a large tar sands deposit in eastern Wayne County, the Elaterite Basin deposit, which would be within the boundaries of the proposed Monument, but for three reasons it will never be developed. The first is the extremely remote location and distance from any infrastructure. The second is the extreme topographic constraints that would hinder development. The third is that it occurs within the Glen Canyon National Recreation Area, which is managed by the National Park Service pretty like a National Park. There are also a few minor noncommercial deposits of tar sands in the White Canyon area of San Juan County and the Ten Mile Wash area of Grand County, both more of a geological oddity than an actual resource.

There are areas within the proposed Monument that present the potential for relatively modest oil and gas resource production, such as seen at the Big Flat. But from the hundreds of oil exploration holes that have been drilled in this general area since the 1950’s, we know with relative certainty that there are no major deposits that come anywhere near the levels seen in the Uinta Basin to the north or the San Juan Basin to the south, each with over 20,000 wells. As with oil shale deposits, the formations that contain these significant oil and gas resources in those basins have all been removed by erosion in our area. From my knowledge of the geology of the region and the geology within the boundaries of the proposed Monument, the Big Flat area and an area south of Moab on Hatch Point with similar geologic features, are effectively the only areas with potential for production. We would be talking about dozens of wells if developed, not thousands. But again, for an area like Grand County even a few dozen wells can have a significant impact to revenues available to its citizens.

With uranium resources, the area has been explored exhaustively since the 1950’s, and there are no massive deposits left to be found. Based on the small lateral extent of uranium deposits, they are discovered from surface outcrops. Drilling to find new uranium deposits is cost prohibitive because it takes so many wells to find and characterize a given small deposit. At best, a uranium industry would not exceed activity levels seen during the recent uranium “mini boom” in southeastern Utah in 2007 -2011, and all of that activity occurred in areas where it had been previously discovered and developed. And again, the worldwide picture for uranium must be considered. After Fukishima, the worldwide demand and subsequent price for uranium plummeted. Future demand for nuclear energy around the world is simply not there. The potential for a boom like that which occurred in the 1950’s, the boom that created many of the roads and trails that our visitors utilize to recreate in our back country, is highly unlikely to nonexistent.

There are minor deposits of copper in the region, but again, we know where those areas are at, and all are non-commercial with the exception of the deposit at Lisbon Valley, outside of the proposed Monument. I am not aware of any potential commercial copper resources within the Monument boundaries.

As a geologist and past public land mineral resource specialist throughout southeastern Utah, I am unaware of any “other extractive” industries related to mineral resources the statement speaks of. The statement that “Several million acres … have been identified for future and continued development of oil and gas, tar sands, potash, oil shale, uranium, and other extractive industries,” appears to be simply a “scare” tactic for the uniformed. And whether purposeful and unethical in this effect, or based on a lack of knowledge and understanding of the regions mineral resources, it is unfounded, and untrue.

The statement also indicates a lack of understanding of how mineral exploration and development interact with world financial markets. At its core, the minerals industry in the modern era is a complex, inter-related worldwide industry. Early Europeans and the United States set the model of conducting worldwide exploration and development operations. In today’s worldwide mineral financing industry, particularly for unproven mineral resource development, potential developers rely to a great extent for investment capital primarily on the Canadian and Australian stock markets. Anyone can raise capital through participation in these markets. They are not limited to Canadians or Australian companies. So implying this type of development in our area will only benefit Canadians appears to be yet another scare tactic. In fact, one of the two active participants in exploring the potash resource in Grand County is an American based corporation, not Canadian. They do however raise exploration investment capital through the Canadian stock exchange, which I suspect is why some see them as a “Canadian” company. Shareholders anywhere can benefit from investment in these companies, and citizens in the State and the affected counties can benefit from creation of direct jobs, service industry development, tax revenue, and the “supporting businesses in the form of healthcare, real estate and insurance professionals” (to quote from the statement). This type of potential development benefits everyone; it certainly does not send all the proceeds to Canadians.

2. The BLM has no tools to manage these public lands and there is immediate need for the creation of a new “plan” for the public lands in the Monument area.

“While the BLM staff in the area work hard to plan for all uses of the land, they have very few means of fully protecting the region’s critical recreation assets. The land use laws and regulations that the BLM must follow generally favor either total conservation or resource extraction. There are very few tools available that are specifically designed to protect the recreation assets that drive the area’s economy.”

After a 32 year career in the BLM, in southeast Utah, I can tell you this is a patently untrue. The BLM can and has withdrawn areas from mining claims and development, specifically along the Colorado, Green and Dolores River corridors. This actually occurred during the last Republican administration, and withdrew approximately 110,000 acres of public land along both rivers from ever being developed from mining claims, protecting nearly 200 miles of these three rivers. The river corridors were also placed in a “no leasing” category for oil and gas resources, meaning just what it implies, oil and gas will not be leased and no exploration or development can occur.

From 2003 to 2008 the BLM fully engaged the public, local and state government and resource user groups in creating Resource Management Plans (RMP’s) for the majority of the area within the proposed Monument region. Again this was done during the last Republican administration, and contrary to what the environmental community would have you believe, that these were “Bush” plans and by implication were flawed toward resource development, these RMPS’s resulted in highly restrictive management decisions for any future mineral or industrial development in southeastern Utah. Even the Bush administration recognized the high scenic and recreational value of southeastern Utah and let the local BLM offices develop plans that are primarily focused on recreational development and economies. The amount of lands made available for any future mineral development were significantly decreased from what they had been in the previous RMP’s prepared in the early to mid-1980’s. Stringent restrictions and operating constraints, developed to protect soil, air, visual, and recreation resources, were prescribed in areas where any type of mineral development would be allowed.

As the politics of public land management generally go, there was controversy over these southeastern Utah “Bush” RMP’s in late 2008 when the Obama administration took office. Over my 32 year career at BLM I observed that the normal flow following a new political administrations election, was that the first year the new party in power trusted no one in the executive (civil service) branch. If they were told by their political supporters that something was wrong, that is who they listened to. So when the environmental community appealed these plans and informed the new Department of Interior political appointees that the “Bush” plans would result in destruction of southeastern Utah they sprang into action. Yes they found some flaws in the first round of lease sales under the new RMP’s, a massive lease sale hastily forced onto local offices by the political maneuverings of an outgoing political party. The new administration also agreed to engage the environmental community in trying to reach a “negotiated settlement” relative to the RMP litigation, ostensibly to allow change to the new RMP decisions into something the environmental community wanted. But a funny thing happened in the next 2-3 years. As the new administration looked more closely at these RMP’s, they found they were quite well written and did indeed protect the core recreational and scenic qualities of southeastern Utah. They apparently also found the environmental community was not engaging in good faith and/or reasonable negotiations, and subsequently at some point early in 2012 ended these negotiations, effectively saying “we’ll see you in court.” SUWA’s web site even chastises the administration for abandoning the negotiated settlement approach.

In addition to the “tools” the BLM has available through RMP’s they can also choose to do additional detailed analysis to look more closely, and project what development could look like and what likely environmental impacts would be, prior to leasing. So even after BLM had spent 5 years developing the RMP’s, the current Secretary of Interior developed a new nationwide process called Master Leasing Plans (MLP’s) and directed BLM offices to take a closer look at sensitive areas and development consequences prior to leasing under the new RMP’s. The BLM in Moab is now looking at an 800,000 acre area in Grand and San Juan counties under these new guidelines. Until this process is completed, again with full public participation, there will be no new oil and gas or potash leases issued. From my experience I can assure you that the MLP process will again add additional restrictive measures to any new mineral development and will undoubtedly add areas where leasing or development will not be allowed.

To take BLM’s resource management abilities and “tools” even a step further, the new RMP’s also resulted in the development of “Travel Plans” for the area. Prior to these new RMP’s there were no travel plans, and as hard as it is to believe, there were no restrictions to off road travel. You could legally drive off road if you so chose. This was a relic from the 1970’s and 80’s when there weren’t many motorized recreational uses in the area and off road use hadn’t been an issue. By the late 1990’s and early 2000’s, when the region started seeing a massive inflow of recreationists (and according to the statement, a new Monument will attract even more visitors), everyone saw the impact from off-road use was becoming an issue. People in motorized vehicles simply didn’t know which trails on the ground were acceptable or unacceptable to use, so they drove them all, they even started creating new trails. BLM worked tirelessly with county and state officials, and user groups to develop a sound travel management plan as part of the RMP efforts that clearly designated what trails could or could no longer be used. It closed about half of the inventoried routes in the Moab area. Old routes into Wilderness Study Areas, or areas BLM determined under the new RMP process contained wilderness characteristics, were closed. Duplicate routes to the same areas were closed. Maps were prepared and signs erected, and lo and behold, the vast majority of unauthorized off road use has pretty much stopped. Yes, every once in a while someone can come up with pictures of new tracks where they shouldn’t be, but this becomes rather overstated when they then decry the entire area is being destroyed as if this were occurring on every acre out in the backcountry.

So I take great exception with statements that the BLM “has very few means of fully protecting the region’s critical recreation assets”, and that the only thing that can “save” the area is a National Monumental. That’s a bunch of “hooey”, to quote Bill Clinton. The area proposed for the new Monument is highly protected under the BLM’s current RMP’s, and as a direct participant in the RMP in Grand county I can assure you the recreation industry received “top billing” in the preparation of those new RMP’s. The public had full opportunity for participation in this process, and the MLP process will result in yet additional restrictive measures. Did all the commercial bicycle trails get the complete protection mountain bike touring businesses desired? Apparently not, but that’s part of the compromise OIA assures us they’re willing to make in developing a “management plan” for the new proposed Monument. The BLM’s RMP’s are the management plans that will work, and they should be allowed to be implemented. I am confident that the judicial system will uphold them because the full process was followed with public involvement, analysis of alternatives, disclosure of reasonably foreseeable impacts, etc. The legal system isn’t swayed by arguments from interest groups, on either side of an issue, that simply don’t like the decisions. The new BLM RMP’s are all we need to protect and promote our recreation and tourism industry in southeastern Utah.

3. The recreation industry has been the primary economic growth engine in the western US for the past four decades.

“… the West’s protected public lands are a major reason why the western economy has outperformed the rest of the U.S. economy in key measures of growth–employment, population, and personal income–during the last four decades.”

This is an all-encompassing statement that sounds good for the Monument argument, but likely would not withstand rigorous socio-economic analysis if the intent in making the statement is that all this growth has occurred as a result of the recreation industry. While I am not a socio-economic expert, it seems to me that a great deal of this economic growth in the west over the past four decades has in fact been driven by the minerals industry. Oil and gas exploration and development in New Mexico, Colorado, Wyoming and Utah are near all-time highs. Gold development in Nevada and Montana brought many new jobs and economies to those areas. Coal development in Wyoming, Colorado and Montana developed to supply the regions new power plants. This generated home construction, service industry businesses and the like. I suspect this development would be found to be one of the major drivers in the economic growth the west has experienced during this period. I would also suggest that other significant aspects of the west’s economic growth over the past four decades have been in the construction industry, particularly in the large metropolitan areas of the west like Las Vegas, Phoenix, Los Angeles, and based to a large extent on people fleeing urbanized sections of the US and immigration. In addition to this decade long growth there has also been recent economic growth related to renewable energy, primarily wind, solar and geothermal.

I’ve no doubt one of the factors leading to this sustained growth is indeed related to the wide open spaces and recreational amenities of the west. Perhaps I’m misinterpreting the statement, but to suggest that the west’s economic activity and growth over the past four decades is related primarily to recreation and the “West’s protected public lands” seems a gross overstatement of actual factors that have led to this economic growth.

4. Creating a Monument will clean up air resources in our National Parks.

“Because if we don’t sort this out and come up with a plan, little by little the area right up to the Park boundary will be sliced and diced with roads and trucks and air we really shouldn’t be breathing.”

The statement concludes that development next to Park boundaries will result in bad air, again implying, I assume, that the creation of a Monument will prevent this. But where does our hazy, bad air come from? From uses adjacent to the parks? I’m not an air quality specialist but during the latter part of my career I became quite involved in air quality issues in our region. Our hazy air comes from places far distant to southeastern Utah, places like Las Vegas, Phoenix, Los Angles, and all the coal fired power plants and suburban southwestern cookie cutter housing developments downstream. I like most westerners and Americans, want to have good breathable air, but I suggest creation of a Monument will not do one thing to increase the quality of air in this area.

5. The OIA proposal is completely separate from SUWA’s proposals for southeast Utah.

“First of all, a few misperceptions: perhaps most significantly, the letter we wrote was misconstrued as an endorsement of a 200 page petition filed by SUWA last year that seeks to close all kinds of roads.”

In all due respect, most of us out here did not just fall off the turnip truck. We’ve been dealing with SUWA for decades. What OIA suggests for a National Monument is exactly the same area as SUWA has petitioned for as a National Monument. The OIA group clearly indirectly endorses SUWA’s general petition, the fact that they may keep a few more roads and trails open is window dressing. Part of any rationale debate and dialogue is honesty and full disclosure. At least have the good manners to admit your group supports the general concept of a National Monument with the same boundaries proposed by SUWA. We’ll at least know you’re truthful in your position and we can begin the discussion from there.

6. Establishing a one industry economy in southeastern Utah is to the benefit of all residents.

“The outdoor industry makes money and creates jobs. And they are sustainable. Remember the infinite sign from high school math? Well when you compare the recreation economy to non-renewable resource extraction, you get to use the infinite sign on the recreation side of the cost benefit calculation, but you always have to come up with a lifespan of a mine or a well.”

“We can have resource extraction and a healthy recreation economy, but not in the same place.”

I agree with the opening statement, the outdoor industry does make money and provides jobs. The economic benefits also spin through a communities other support infrastructures and businesses. I have some problem however with the “sustainable” end of the argument, unless you assume a 9-10 month per year jobs, with relatively low pay and no benefits, year after year could be considered to be “sustainable”. The jobs are far more sustainable for the business owners themselves. I suspect most recreation service industry employees would also disagree with the assessment of job “sustainability”.

Yes I remember the “infinite” sign from high school and college. Respectfully, I don’t agree that it applies here, and I’ve never seen it used in any socio-economic analysis. Yes mineral extraction jobs come to an end, sometimes due to exhaustion of the resource, and other times due to vagaries of worldwide mineral commodity supply and demand. Moab found this out the hard way in the mid-1980’s thinking the uranium industry would go on forever. I would also add that the current potash mine along the Colorado River has been in operation for over 60 years and has reserves to continue for decades.

Yet here we are again 30 years after the collapse of the uranium industry, due to factors far beyond our control, with special interest groups telling us it’s in our best interests to do away with all other forms of industry. I suggest the recreation industry is not “infinite” and in fact could be subject to the same vagaries of worldwide commodity supply and demand, principally related to the cost a barrel of oil and the subsequent cost of a gallon of gas. At what point does a gallon of gasoline hit a price where tourists quit travelling so extensively or start cutting back on the amount of travel? $4.50, $5.00, $5.50? This kind of mineral commodity change will affect all aspects of our recreation economy, from the cost of an airline ticket, to the cost of gasoline to drive here from elsewhere, to the cost outfitters have to charge for shuttles and trips, to the revenue available to local governments to provide basic government services such as public safety, health, education, etc.

I and others believe it is never wise to put all ones “eggs in one basket”. Small scale commodity development, such as the actual mineral resource base within the proposed Monument would suggest could occur there, can be allowed without destroying the recreation industry. We’ve had mineral commodity development in this area since the 1950’s, completely unregulated in the early years, and it doesn’t seem to have destroyed our landscape. In fact, the roads and trails it created into the heart of this great landscape are exactly why we have such a thriving recreation industry, people can get out into it on their bikes, or ATV’s, or on horse, or foot to see it and experience it.

7. Creation of a new Monument would result in measurable and significant increases in visitor use to our already well known area.

“A national monument will attract visitors to the region and protect the recreation assets that drive the local economy.”

How does OIA know this? Our region is already known around the globe, starting with John Wayne movies! We have two National Parks and a National Recreation Area already within or directly adjacent to the newly proposed Monument. The Grand County Travel Council spends a million dollars per year in advertisement. The State of Utah spends millions of dollars more a year on tourism advertising. We get untold advertisement in various industry and outdoor magazine articles. I’m certainly not convinced that designation of a Monument will make any more folks come to our region. Perhaps we should look at economic analysis and visitation data from other Monuments, such as Grand Staircase-Escalante, to see what might actually happen before we assume this would be the case here. Grand Staircase is also adjacent to two National Parks and the same National Recreation Area and may have data applicable to our situation. This is the type of information that should be utilized in any type of good faith collaborative process prior to taking unilateral actions for a Monument creation.

8. The duplicitousness of the process OIA is utilizing.

“I would actually prefer to create a National Recreation Area, which requires an act of Congress, around Greater Canyonlands.”

*

“And then there is the general anger about a process where the president signs a document and works out the details later.”

*

“So, why a monument? The problem is that a National Recreation Area takes an act of congress and congress doesn’t seem to be able to pass anything these days, especially land use laws. So the outdoor companies didn’t think legislation was an option. And they thought that if a monument proclamation could be written with recreation as a key reason for the designation this would result in the creation of a management plan whose purpose would be to optimize all outdoor recreation.”

*

“Bottom line: Doing nothing is not an option for anyone who either likes to go outside in the Greater Canyonlands region—by whatever means—or who depends in any way on the health of the recreation economy in Southern Utah. If you think a monument is too restrictive, that’s fine, but we need to come up with something. We can have resource extraction and a healthy recreation economy, but not in the same place.”

*

“I myself believe in democracy, and democracy is about communication and sharing. It is about coming up with ways to live together in a community. So I am willing to work with the federal government to find a way to set aside some special places for recreation.”

In all due respect, irrespective of the personal preferences identified in the statement, perhaps a more proper course of action for such a substantial lands action proposal should involve full public debate before it occurs or before a special interest group proposes it. A process that would allow up front full dialogue and discussion rather than an individuals’ or a special interest groups “druthers”. A process that would allow a full analysis of actual facts related to resources and economies, rather than an end run request to the President for further misapplication of the 1906 Antiquities Act, legislation primarily enacted to protect antiquities, not special interest groups preferences.

We westerners do get angry when a President locks up millions of acres of land without having the good graces to speak to us about it first. My experience with public land management and partnerships is that it’s far better to work collaboratively up front on concepts and goals, and then prepare the boundaries. Everyone gets heard and has input, and subsequently, even though they may not get everything they want, they can live with it. See the Washington County public lands/wilderness process. That’s what works.

I would even suggest that had the Clinton administration not proceeded as they did with creation of the Grand Staircase-Escalante National Monument, that Utah’s Governor and Legislature may not have been so fired up to file lawsuits to obtain ownership of federal lands within the State. I’m not saying I endorse the transfer of all federal lands in Utah to the State, but I can certainly see why a state would feel this way. How many million acre plus land closures should any state be subject to without finally trying to do something about it?

Yes, the designation of National Recreation Areas and National Parks take an act of Congress. As broken as Congress has been the last decade or so, it’s still one of the primary institutions at the heart of our democracy that provides for the general concept of government checks and balances. I doubt if special interest groups “end running” this process is the way our founding fathers envisioned the process for such serious actions. And I will again invite anyone to review, in detail, the BLM RMP’s. I know they are detailed and complex, but if one reads them objectively they may come to the conclusion that southeastern Utah already has a “recreation” plan for public lands. One may not like all the decisions in the plan, but it was a collaborative process that developed the plan.

I suggest an alternative “Bottom line”: we have “done something” and continue to “do something. We have recreation focused BLM RMP’s that were conducted over a 5-6 year period with full public involvement and collaboration with county and state governments, and other federal lands management agencies and user groups. The RMP’s did in fact “zone” the area. Some areas are focused on motorized recreation, some focus on non-motorized recreation. I’m not aware of any areas where the “focus” was mineral commodities, but some commodity exploration and extraction is allowed in areas where it will not interfere with the unreasonably with recreation use and economy of our area. Additionally there is yet another ongoing effort by BLM to further refine these areas in a Master Leasing Program.

9. Condoning the continued abuse of the 1906 Antiquities Act.

“Only lands already owned by the federal government can be declared national monuments. National monument designation protects and reserves landmarks, structures, and other objects of historic or scientific interest as authorized by the Antiquities Act of 1906.”

This is true, the President has the authority to create National Monuments under the Antiquities Act of 1906. What exactly are we protecting with this particular Monument proposal? Antiquities, historic landmarks, objects of historic or scientific interest? No, the driving force behind what’s being proposed appears to me to be the protection and enhancement of an economy based on one use. I suggest the Antiquities Act was never intended for this type application. I know from unsuccessful state litigation against the Grand Staircase Escalante National Monument that the courts differ from my opinion. However, I suggest it’s time to bring the intent of the Antiquities Act back in compliance with its intended use. The President should have broad powers, but when it comes to making vast acreages of public lands off limits but to a single use, that should be left to consensus building, collaboration by all interested parties, and Congressional action. That’s what we do for National Parks and National Recreation Areas. This abuse of the Antiquities Act has gone on long enough, and again I suggest this is one of the driving forces in the various western states trying to wrest control of these federal lands from the federal government. They are tired of such broad unilateral actions with such far reaching impact on regional and local economies and lifestyles.

SUMMARY

I’ve lived in southeast Utah for 48 years, been in Moab for 30 of those years. I’ve worked as a geologist and land manager in southeast Utah for 34 years. I know the citizens and communities. I’m well aware of the array of natural resources present. We all prize our iconic landscape and our recreation industry, and I believe the majority of our citizens would agree that we don’t want to do anything foolish to put our landscape or our tourism economy at risk. I recognize Moab and Grand County has a diverse population and I’m certain we have residents’ who would agree with this Monument proposal. But I don’t think the majority of our citizens would support this proposal or the methods being employed to create it. I certainly do not and will not support it.
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