Bears Ears National Monument (BENM) is an exquisitely beautiful and unique 1.36-million-acre gem of public land, located in Southern Utah. BENM is currently going through resource management planning following recent expansion of the monument by presidential proclamation. For more details on the monument expansion, history of BENM, and discussion of resource management planning versus travel management planning for public lands, check out our recent articles on these topics on the Utah Public Lands Alliance (UPLA) website.

The proposed Resource Management Plan (RMP) for BENM was developed via collaboration of the Bureau of Land Management (BLM), US Department of Agriculture’s Forest Service (FS), and the Bears Ears Commission (a group representing six Native American tribes). The RMP includes five Alternatives for public comment. All five Alternatives will result in detrimental impact on outdoor recreation access in BENM. Thus, we urge our members and other outdoor recreation enthusiasts to take advantage of the public comment period to advocate for preservation of recreation access. In this article, we’ll compare the varied levels of impact across the five Alternatives. The deadline to submit public comments is June 11, 2024.

The common thread through all five proposed Alternatives in the BENM RMP is: recreation access is viewed as a threat to preservation of natural and cultural resources. Rather than evaluate how recreation can be managed to prevent and mitigate potential impacts on natural and cultural resources, closed or restricted access is the dominant strategy utilized. Unique characteristics of each alternative include:

• ALTERNATIVE A: this is the “no action” alternative by which (most) existing management would continue.
  • BLM lands: eight special recreation management areas (SRMAs) and two extensive recreation management areas (ERMAs) would remain intact.
  • Forest Service lands: management based on Recreation Opportunity Spectrum (ROS) categories of primitive, semi-primitive non-motorized, semi-primitive motorized, and roaded natural.
  • Travel management (OHV): existing designated OHV routes would remain open (see table below)
    • 928,080 open to limited OHV access
    • 436,075 acres closed to OHV access
  • Areas of Critical Environmental Concern (ACECs): existing ACECs would remain in place, no new ACECs would be created
  • Recreational shooting: permitted
  • Recreational facilities: existing facilities would remain open and intact
• ALTERNATIVE B: provides the most permissive management for recreation access considerations. However, conservation is still heavily prioritized over recreation and public access.
  • BLM lands: would be managed through four SRMAs and four ERMAs
  • Forest Service lands: same as Alternative A
  • Travel Management (OHV):
    • 797,525 acres open to limited OHV access
    • 566,627 acres closed to OHV access
  • Travel Management (aircraft): landings and takeoffs would be limited to Bluff Airport and Fry Canyon Airstrip, with the potential for additional locations to be identified in future implementation level decisions.
  • ACECs: BLM would designate the Indian Creek ACEC, Lavender Mesa ACEC, and Valley of the Gods ACEC. The San Juan River ACEC and Shay Canyon ACEC would not be designated as ACECs.
  • Recreational shooting: permitted generally, with the exception of closures in the Indian Creek Corridor Recreation Management Zone (RMZ), San Juan River SRMA, and prohibitions in campgrounds, developed recreation facilities, climbing areas, existing and designated trails, parking areas, trailheads, across roadways, rock ES-7 writing sites, and structural cultural sites. If problems with recreational shooting occur in the future, the BLM would consider future restrictions or closures.
  • Recreational facilities: may be developed as needed
• ALTERNATIVE C: similar to Alternative B, with additional restrictions to use of drones
  • BLM lands: same as Alt B
  • Forest Service lands: same as Alt A
  • Travel Management (OHV):
    • 700,122 acres open to limited OHV access
    • 664,030 acres closed to OHV access
  • Travel Management (unmanned aircraft / drones): use of drones eliminated throughout most of BENM, with case-by-case exceptions through a permitting process
  • ACECs: same as Alt B
  • Recreational shooting: same as Alt B
  • Recreational facilities: limited development of facilities with emphasis on maintaining natural conditions across the landscape
• ALTERNATIVE D: severe restrictions to recreation access; the primary management priority is for landscape conservation that is achieved through eliminating or heavily restricting recreation
  • BLM lands: managed through creation of seven Management Areas
  • Forest Service lands: same as Alt A
  • Travel Management (OHV):
    • 381,239 acres open to limited OHV access
    • 982,914 acres closed to OHV access
  • Travel Management (aircraft): same as Alt B
  • Travel Management (unmanned aircraft / drones): same as Alt C
  • ACECs: BLM would designate the Indian Creek ACEC, Lavender Mesa ACEC, Valley of the Gods ACEC, John’s Canyon Paleontological ACEC, and Aquifer Protection ACEC. The San Juan River ACEC and Shay Canyon ACEC would not be designated as ACECs.
  • Recreational shooting: same as Alt B
  • Recreational facilities: minimized development of recreational facilities and management in favor of emphasizing natural conditions
• ALTERNATIVE E (the preferred alternative): most recreation access eliminated throughout BENM; maximizes the considerations and use of Tribal perspectives on managing the landscape; emphasis is on resource protection and the use of Traditional Indigenous Knowledge and perspectives on the stewardship of the landscape.
  • BLM & Forest Service lands: SRMAs and ERMAs would be eliminated; recreation managed based on a zoned approach. Four zones would be designated: Front Country, Passage, Outback, and Remote.
  • Travel Management (OHV):
    • 794,181 acres open to limited OHV access
    • 569,971 acres closed to OHV access
  • Travel Management (aircraft): same as Alt B
  • Travel Management (unmanned aircraft / drones): same as Alt C
  • ACECs: all existing ACECs would be carried forward, the John’s Canyon Paleontological ACEC and Aquifer Protection ACEC would also be designated.
  • Recreational shooting: eliminated in full throughout all of BENM
  • Recreational facilities: development allowed only in Front Country and Passage zones, when deemed an absolute necessity

As you can see from the management guidelines proposed by each alternative, there is no alternative that is pro-recreation. A pro-recreation alternative would retain all existing recreation opportunities in the monument as open, including all currently designated motorized routes. It is critical to emphasize that management by closure is not management; rather, this method of “management” serves to banish the public from the opportunity to access and enjoy our public lands. There are many effective strategies to manage public lands, including BENM, by means other than road closures, activity bans, group size limits, and exclusion zones.

We encourage outdoor recreation enthusiasts to submit comments on this RMP to advocate for a pro-recreation alternative that would involve active management techniques such as constructing new infrastructure to sustainably handle increased visitation; this would include new trails, trailheads, parking areas, bathroom facilities, campgrounds, etc. It is possible to manage the natural landscape in a manner that conserves the land, protects wildlife habitat, and retains the rugged, wild characteristics of the landscape, while also creating appropriate places, structure, and guidelines for humans to access, enjoy, and recreate throughout the land.

For more details about the BENM RMP, along with guidance on how to write a high-impact comment to submit for the public comment period, join us for a webinar on May 30 at 6:30pm MT. Utah Public Lands Alliance and BlueRibbon Coalition are partnering to share about how the RMP will affect OHV and outdoor recreation access. Tips and best practices will be presented to help you craft your own substantive comment. Click this link to register for the webinar.

For more details about the Bears Ears National Monument RMP, check out the RMP planning website, the draft RMP, and the BLM’s press release and invitation for public comment:

• Bears Ears National Monument ePlanning website
• Bears Ears National Monument Resource Management Plan
• BLM, USDA Forest Service invite input on Bears Ears National Monument draft plan

UPLA is continuing to review the draft RMP and seek guidance from the outdoor recreation community to identify areas of concern regarding the impacts of each proposed Alternative  If you have questions or would like to share your input on the draft RMP, please contact UPLA’s Natural Resources Consultant, Rose Winn, at rose@uplapla.com.

People often ask what they can say to make their comments effective, or “substantive”. Most
comments do a pretty good job at telling What you want, what’s often missing is the Why which
justifies your comments. There are many justifications that BLM cites for every proposed closure or
restriction to access for each trail, and it is impractical for you to write meaningful comments on all
of them. If everyone running a trail just picks the items most important to you from the list below
and states specific reasons why the trail should remain open.

We really need your input on individual routes, we can’t get it any other way. The more detail you
give the better, but even if you only write about one or two – that will make a tremendous impact in
preventing BLM from making arbitrary decisions to close or restrict OHV access to that trail, and
give us better grounds for legal challenges. Perhaps the most important things for recreationists to
convey about a given route are its value and its manageability.

Click Here to See All Our Suggestions as a PDF

Click Here to See A Sample BLM Route Report for The Barracks Trail

Suggestions on Topics for Making Comments With Sample Route Report

Efforts by the Federal Government to restrict access to our public lands has never been as vicious and threatening as it is now. There are 12 Utah Travel Management Plans coming in the next 12 months, as well as the devastating BLM Conservation and Landscape Health Rule.

Who Will These Affect? SUWA and other extremist environmental groups have long focused on the elimination of motorized off highway vehicle use, these actions will affect every user of public lands in Utah. Equestrians, hikers, rock climbers and other recreation groups that have welcomed expansion of wilderness areas will begin to understand that their journeys to their favorite areas will become much, much longer, as the road network they use to reach their staging areas are closed by designation of Wilderness, Wilderness Study Areas, Lands with Wilderness Character, and ACECs are expanded.

What should I do?

• We all must take some time to understand the rules of the game if we expect to win.
  1. UPLA provides a series of 1-2 minute videos to educate you on the importance and methods to craft “substantive” comments that make a difference. You can find these videos on our Youtube channel, and also on Instagram and Facebook.
  2. Understand the definition of substantive: most definitions of substantive include that they have a “firm basis in reality and being therefore important, meaningful, or considerable”-none of the definitions include opinions not supported by facts Learn more on our educational videos and articles.
  3. Search for educational articles at https://utahpla.com/news/
  4. Join or subscribe to UPLA https://utahpla.com/help/ to get our free newsletters
• Learn and Use TrailSaver. Get out and use the OHV roads and trails important to you and report using UPLA’s TrailSaver. Order Stickers for yourself, your friends, clubs, and events. TrailSaver.com will organize your comments and provide reminders when they are needed for a particular plan, along with suggestions to make them more effective and specific instructions on how to submit them.
• Establish and enhance personal relationships with BLM and Forest Service staff in your area. Invite them to go on a ride with you. Ask them what their concerns or issues are and help them find a solution, and then recruit volunteers to execute the project. Remember, people don’t care how much you know until they know how much you care; it’s far easier to show them on a trail ride than in an office or conference room.
• Contact elected officials about your concerns, including County Commissioners, Members of the State Legislature, and Congressional members. Letters are great, but when hearings or votes are scheduled, phone calls are the best motivator to send your message.
• Support your local clubs and access protection groups like Utah Public Lands Alliance and BlueRibbon Coalition. Join or subscribe to their news alerts and share their social media posts with your friends. We can depend on organizations like BlueRibbon Coalition to fight for us in the courts, but if we don’t step up our action by submitting effective comments, we are impairing their ability to win.

Don’t throw all your eggs in one basket, we need YOU to get engaged on every front with us.

                                 Get Engaged and Start Acting as Big as We Are!

This article is 2 pages, please scroll to second page for more. This is the first article in a series about how to take action to stop them. Watch for more to come on specific tips. We will also be scheduling a Webinar soon.

Winn Rose – Bears Ears Article Series 1

Many of our treasured public lands in the state of Utah are going a variety of management planning revisions at this time or will be soon within the coming year. Current, active plans include the Bears Ears National Monument Resource Management Plan and the San Rafael Swell Travel Management Plan. For an overview of current and upcoming active plans, check out this article that provides an overview of those that are slated within the next several months.

The American people collectively own all public lands. They are one of the most valuable endowments of our citizenship, wherein every American may enjoy the rich beauty and vast array of natural and cultural resources that our public lands embody. Through the direction of the US Congress, various federal and state agencies like the Bureau of Land Management (BLM) and US Forest Service are designated to manage our public lands for the benefit of the American people. Agencies like the BLM and Forest Service do not own our public lands, they are merely responsible to manage it. Thus, as citizens, it is our right and responsibility to help direct each agency in public land management by participating in the planning process. Anyone who enjoys recreation or use of public lands for activities like off-roading, camping, horseback riding, hiking, mining, etc., must provide their input during the planning process to ensure that access to public lands for such purposes is prioritized and protected as management decisions are made.

In order for us to be effective as we participate in public land management planning, it is important to understand the goals and purpose of different types of plans. For example, right now we have the opportunity to provide public comment on a Resource Management Plan (for Bears Ears National Monument), and we’ll soon have the same opportunity to comment on a Travel Management Plan (for San Rafael Swell). What is the difference between a Resource Management Plan (RMP) versus a Travel Management Plan (TMP). RMPs and TMPs serve different but complementary purposes.

A Resource Management Plan is a comprehensive document that outlines the long-term management goals and strategies for a specific area of public land, such as a national forest, park, or wildlife refuge. RMPs typically address a wide range of natural and cultural resources, including wildlife habitats, water quality, vegetation, archaeological sites, scenic values, and recreational opportunities. These plans are often developed through a collaborative process involving stakeholders, agencies, and the public to ensure that multiple interests and perspectives are considered. RMPs provide guidance for land managers in making decisions about resource use, conservation, development, and restoration within the designated area. RMPs are intended to function like a 30,000-foot overview; they solely address management structure at a programmatic level, creating guidelines and guardrails for future site-specific and trail-specific plans. Per directives from Congress (36 CFR 212), RMPs do not make site-specific decisions regarding travel management because travel management decisions are made at the project level.

A Travel Management Plan focuses specifically on the management of motorized and non-motorized travel within a given area of public land. TMPs are developed to address issues related to off-road vehicle use, hiking, biking, horseback riding, and other forms of recreational travel. These plans aim to balance the public’s interests for recreational access with the need to protect natural and cultural resources, minimize conflicts among user groups, and ensure public safety. TMPs often involve the designation of specific routes, trails, and areas for different types of travel, as well as the implementation of regulations and enforcement measures to manage recreational use responsibly.

While RMPs focus on the broader management of natural and cultural resources, TMPs specifically address the management of recreational travel activities within a designated area of public land. Both types of plans are important tools for protecting public access to public lands, while ensuring the sustainable and responsible management of our treasured public lands for current and future generations. While it is of critical importance for outdoor recreation enthusiasts to participate in the planning process, it is equally important that we understand the goals and purposes of each plan to ensure that our public comments are effective, that the BLM, Forest Service, or other management agency actually uses our comments to shape the final decision for each plan. Increasingly, it is also critical that we hold managing agencies accountable to ensure that site-specific and trail-specific decisions are addressed solely within TMPs, and not implemented within RMPs.

Over the last several years, a disturbing trend in public land management planning is that public access and recreational uses take a backseat in priority in the planning process; an extreme environmentalist agenda is elevated in many public land management decisions. One example of this is the recent TMP that was implemented for the Labyrinth Rim & Gemini Bridges area near Moab. This is just one example, there are many more. Thus, our mission at UPLA is to inform and equip you to join in the effort to preserve public access to public lands for all forms of outdoor recreation. We offer resources and support to make it easy for you to participate in public land management planning, and to stay up-to-date on current plans that are open for public comment. We invite you to join us in the effort to protect public access to our nation’s beautiful public lands!

Rose Winn
Utah Public Lands Alliance
Natural Resource Consultant
Rose@UtahPLA.com

This page is dedicated to providing updated information on the Trail Canyon Travel Management Plan, E Planning Project Number DOI-BLM-UT-P020-2021-0002-EA. We will post new resources as they become available, with the most recent posts appearing at the top of this page after the static resource links at the top of the page.

Preliminary Alternative Maps were released in January 2021 with the results of the scoping report. In that scoping report, there were only 19 comments submitted.

The next phase will be the release of the Draft EA, expected this summer. If Alternative B were selected, as it was in Moab, very important routes including the Barracks Trail, Poverty Wash, and Hell Dive Canyon to Lambs Point will be closed. We need a massive effort to get people out and report their trails using www.TrailSaver.com Don’t wait, there’s a lot of trails that will need protecting.

If you have information that you would like added, please email us at landuse@utahpla.com

UPLA Articles

UPLA Article On Writing Substantive Comments 03/10/2024

UPLA Article with Links to All Utah Travel Management Planning Information

BLM Resources
Interactive Map from Scoping Report with Prelimary Alternatives

Trail Canyon Scoping Report 2021

Trail Canyon Scoping Route Reports 2021

So What Do We Need To Do Now?

1. Select an Area that has routes that are marked on the map as targeted for closure. Write down the route numbers.
2. Go to the BLM Route Report, refer to the link above. You can use the Search Bar on the webpage to find the Route Report for your trail, generally it will be about 4 pages long. Print it out, and try to understand what their resource concerns are. How do you determine what things mean in the Route Report? Google should be able to give you answers to abbreviations in the report. For example, I googled “What is PFYC Class 5?” and “What are abbreviation T E S T in BLM route reports for negative impacts” and it gave me all the answers.
3. Schedule time to go out and run the trail. Take your route report. Look for areas or conditions mentioned in the Route Report. Take photos along the route, especially noting any possible resource impacts they may have cited and think about alternatives when you’re on the trail.
4. When you get home, use TrailSaver to draft your substantive comments on the route. Be as specific as you can. 2 or 3 paragraphs on a route is an ideal length, include photos and gpx tracks. Videos are not recommended because of the large file size. If Archeological or Paleontology is listed, you won’t get a specific answer as to where that concern is located, but you can ask questions about possible mitigations around the concern such as rerouting the trail, informational signing, barriers to narrow trail to prevent stopping, etc. It is ok to mention how long you’ve been using the trail, with whom, etc, but this should be like the dessert to your meal, not the main course.
5. TrailSaver will email you a formatted draft of your report. You can edit, add to it or change it. When the BLM comment period opens, TrailSaver will send you another email with your report and more suggestions, along with instructions on how to submit reports to BLM.

Summary When you look at the comments required for one route, it seems like a lot, but when put in the scope of things, it might take you 20-30 minutes to write a good comment. Compare that to the fun you had running the trail, the people you enjoyed the company of on the trail, the overnight camping you did, and being able to enjoy this trail for generations to come and I hope you’ll agree it’s a good investment of your time. Please do your research and get out there and help save our trails!

We Need Your Support to Make This Come Together, please help!

www.TrailSaver.com

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