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A Rebuttal to the OIA / Ashley Korenblat Statement on the Proposed Greater Canyonlands NM

by on December 7, 2012

(Ashley Korenblat’s complete statement can be read HERE or HERE)

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:

  1. The proposed Monument and surrounding National Parks are in imminent danger of being destroyed by mineral development.
  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.
  3. The recreation industry has been the primary economic growth engine in the western US for the past four decades.
  4. Creating a Monument will clean up our air in the area.
  5. The OIA proposal is completely separate from SUWA’s proposals for southeast Utah.
  6. Establishing a one industry economy in southeastern Utah is to the benefit of all residents.
  7. Creation of a new Monument would result in measurable and significant increases in visitor use to our already well known area.
  8. The duplicitousness of the process OIA is utilizing.
  9. 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.


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.

  1. Lisa Ceniceros permalink

    As always, well said Lynn!

  2. Michael Bellew permalink

    Can’t argue with accurate science.

  3. Gil Ceniceros permalink

    Very thoughtful response! It’s hard not to use swear words, isn’t it!

  4. Steve St.Clair permalink

    Thanks Lynn, for clearly pointing out the rest of the story. Fear, uncertainty, and doubt are what the OIA letter is trying to instill and stands on. Having your input is truly refreshing.

  5. Wow, truly a great, well reasoned and articulate argument. Good job!!

  6. tibbettsmasonry permalink

    Thanks Lynn great job
    I still wonder what they are trying to protect and from who?
    James Tibbetts

  7. Mike permalink

    Very informative , thank you.
    Just curious and was wondering if you may know what the helicopter work out on Spring Canyon Bottom road was all about this past summer ?

  8. Excellent job! Thank you for taking the time to write this.

  9. Trena Harrison permalink

    Thank Goodness we have someone with your knowledge on our side. Very well written, with precise responses to every article of hogwash SUWA put in the petition. Thanks Lynn

  10. Zach Bastian permalink

    I hope this will be printed in the Times.

  11. sixstringsteve permalink

    What a fantastic rebuttal. Thank you for all the work you have put into this!

  12. Carlo Sanchez permalink

    WOW!! I must say I got a whole new insight on the process. Thanks

  13. Dan Kent permalink

    What happened to you, Lynn? I remember the day I commiserated with you in your BLM office about the “death by a million cuts” Southern Utah seemed to be facing; how it seemed that everything you tried to do to protect the “resource,” as the BLM refers to our Great Mother, was ham-strung by the unseen hand of industry and big money, working out their corporate corruption and greed on our vulnerable American National Public Lands thru their handservants, the local and national politicians. What changed? Do you like what Moab is becoming, what is happening to our now overrun, once magical surroundings? When is the last time you experienced a quiet, dark night? Maybe the best argument for an expanded Canyonlands National Park, (aside from it being a partial fulfillment of its protected wildlands destiny begun before you were born), is that cock-sure, sagebrush-burning Western wannabees like yourself will have to go somewhere else to nickel and dime to death the sacred, life-giving landscapes we so desperately need in this age of spiritual disintegration. If you can’t see the value ($$$) in a monument, maybe you can admit that the BLM can’t stop squat when push comes to shove, and a monument will be a great way to slow the abuse, which always follows roads and their lazy, unimaginative, selfish defenders. Quality of life does not revolve around money. In fact, wealth has been shown to have an inverse relationship to happiness. I have lived in the Intermountain West all my life. Please don’t talk about “us Westerners” as though we all DIS-like the government when it protects the land we love, but LIKE the barrage of energy development schemes being currently foisted upon us by that same government: its a travesty that is contaminating our water for millenia and shattering the continuity of habitat for our beloved wildlife. Are you blind to all the new wells, pipelines, exploration grids, toxic waste dumps, nuke piles and roads being built in or proposed for our precious little dry, desert corner of Utah? Next time I see you on your “hog” i’ll think about the .005% of the US energy supply we are wrecking our county to extract…

  14. William permalink

    Jeepers lose roads to Oil and Gsd in Moab

    Fidelity Oil & Gas just north of Canyon lands National Park constructed a 26 mile pipeline that damaged at least 2 Red Rock Jeep Club trails by making one lane roads into two lane roads for large trucks. The destruction of the land used by jeepers has been going on for over two years. Lynn was a paid consultant for a consulting firm whose only customer was American Potash. What is good for American Potash may not be good for jeepers in Moab.
    If you enjoy driving in the oil fields of Uintah County come to Big Flats above Moab for a close experience. We will soon be very similar. This area is under BLM management and they ignore the needs of all other users. The BLM does anything the oil companies want and the hell with other users

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