SUWA is the Southern Utah Wilderness Alliance, a 501c3 charitable organization with offices in Salt Lake City, Moab, and Washington DC. Their stated “Mission of the Southern Utah Wilderness Alliance is the preservation of the outstanding wilderness at the heart of the Colorado Plateau, and the management of these lands in their natural state for the benefit of all Americans.”

To fulfill their mission to have more lands designated as Wilderness, Wilderness Study Areas, or Areas with Wilderness Character SUWA has used their army of attorneys to bring countless lawsuits against the BLM and other land managers. The threat of litigation has often pushed land managers into submission when evaluating new plans in favor of SUWA’s extreme environmental policy. Their single focused dedication to wilderness is serving only a narrow segment of Americans, while depriving the vast majority of Americans from enjoying our public lands.

SUWA has significant financial resources to gain ground through the courts, but they may have a big chink in their armor when it comes to Finances.. Their latest 990 Tax Return showed they had $25M in assets at the beginning of 2022, but only $22M at the end. In addition, they have unrealized losses of $3.2M in investments, that’s a decline of almost $6M in 2022 alone, a 25% decline. Compounding the issue with their balance sheet, their total revenue decreased in 2022 by almost 50%, yet expenses increased. The result was a net loss of $46,713 in 2022, compared to a profit of $4,743,299 the 2021.

SUWA brags about their Stewardship program that engaged 145 volunteers spending 2,437 volunteer hours during 2022. Sounds impressive until you consider the work hours and money that OHV groups expend improving and maintaining public lands. UPLA’s Sand Mountain Service project last year had 175 people over 2 days working almost 1,400 hours on just that one project. In Washington County alone, UPLA, Desert Roads and Trails Society, Tri State ATV Club, and St George Jeepers spent many more work days last year working on various projects including installing a second composting toilet and building a 5 acre staging area. Countless groups through Utah invested similar volunteer and financial resources on projects not only for OHV, but many other user groups as well.

We are good at doing the work, but we have not been great at getting the credit for it.

I’d like to share a story by Scott Groene, SUWA Executive Director, that is quite revealing about some of SUWA’s exaggerated claims about the pending doom caused by motorized traffic.

“Last summer, a massive flash flood blew through Mill Creek Canyon in southeast Utah, a place I often visit. Bursts of torrential rain filled the canyon with a temporary and raging river that hauled decades-old debris downstream, rearranging the canyon floor. Wandering the canyon afterwards, I was awed by how the flood uprooted or snapped mature trees, created new slickrock bowls where thickets of willow and tamarisk had stood, and washed out heavy brush to leave a parklike stand of tall cottonwoods rising over a floor of smooth bare sand. But I know that next spring, the undergrowth will return. The soils and plants will reestablish themselves where there is now only exposed and water-sculpted stone. The canyon will return to its former state”

I find it humorous that the epic devastation described will be restored in just a few months, yet they consistently complain that impacts caused by motorized vehicles will take many years,  or never recover.

In a 2017 settlement of one of SUWA’s lawsuits against BLM, BLM agreed to revise or complete 13 new Travel Management Plans by 2025. The settlement requires BLM to expressly consider impacts to lands with wilderness character, sensitive natural resources, and cultural resources. The recent Labyrinth Rims/Gemini Bridges plan was disastrous to OHV and dispersed camping with 317 miles (30%) of roads and in excess of 120 dispersed campsites closed. Additional Utah Travel Plans to come include Book Cliffs, Dinosaur North, Dolores Triangle, Henry Mountains, Nine Mile, Pausaugunt, San Rafael Swell, and Trail Canyon.

While it is commonly known that SUWA declared war against OHV users 40 years ago, they have carefully hidden the story of the impact this will have on other users such as equestrians, rock climbers, canyoneers, hikers, campers, paragliding, base jumpers, rock hounders, photographers, hunters, fishermen, and river users, which will be outlined later.

To really understand SUWA’s actions, it is important to understand some concepts

Wilderness and Wilderness Study Areas can only be designated by an Act of Congress. An area with wilderness character can be designated by BLM, Forest Service, or National Monuments with the stroke of a pen by a mid level manager. Wilderness areas must be at least 5,000 acres in size, and have “naturalness” (where the imprints of human intrusion are “substantially unnoticeable”).

The area must be entirely roadless, no OHV, but also no highways through the area. The proposed Alternative D of the Grand Staircase National Monument would add 559,000 acres as Wilderness, and encompasses an area the size of the State of Delaware, yet allows on 5 roads to traverse the entire area.

The Red Rock Wilderness Act was originally introduced into Congress in 1989, and has been reintroduced every year since without passage. It will add 8 million acres of Wilderness to the 1.8 million currently existing in Utah, an increase of more than 500%

Permitted Uses are non-motorized recreation including horseback riding, non-commercial herb gathering, hiking, camping, fishing, and hunting. Note that bicycles of all types are not allowed. What is not spoken of is that many of these allowed activities  will be impacted because of the new difficulty getting near the area to recreate. A fisherman’s favorite fishing hole may be far less attractive if they have to hike 8 miles to get there. Equestrians will be faced with a much longer ride to get to their favorite areas because of the lack of roads and staging areas. These factors will also likely affect rock climbers, canyoneers, snowmobilers, hikers, campers, paragliding, base jumpers, rock hounders, photographers, hunters, and fishermen.

Prohibited uses include use of motorized vehicles in wilderness including trucks, cars, bulldozers, snowmobiles, off-road vehicles, helicopters, and other motorized equipment such as chain saws cannot be used within wilderness areas. Grazing is allowed only if the permit existed continuously prior to the designation of the area as a wilderness. Additional restrictions apply in other areas, in the Grand Staircase, grazing is currently not allowed on 125,000 acres, under Alternative D, it will not be allowed on 1,092,000 acres, a 50% reduction.

SUWA’s strategy seems to be well thought out, and it’s been effective at restricting access to public lands for many users, and as they work to expand the interpretation of FLPMA in new ways, they will continue to be one of our strongest foes. First, they eliminate roads of all types in an area, that is why there is a focus on eliminating duplicate roads to get an area to exceed that 5,000 acre target where it can be considered for wilderness designation. Next, they need to close campsites that are permanent in nature, this includes bear boxes and fire rings, and of course any campsite accessed by any type of road. Eliminating grazing, mining, and extraction of fossil fuels is next. After these are accomplished, they will have the area designated as having wilderness character, which requires BLM to manage it to prevent any disruption in that character.

The proposed BLM Landscape Health and Conservation Rule, which SUWA was a strong supporter of, will be the magic bullet to make these steps much easier to accomplish without Congressional action, including all of the following:

• The ability to sell Conservation Land Leases to almost anyone to manage land with the rules they establish, and for as long as it takes to achieve the stated goal of returning it to it’s natural intact landscape. They can also be used to “mitigate” other actions, very similar to the carbon offset rules currently used by major polluters to offset their actions. State and local governments are not eligible to purchase the leases, but foreign governments, corporations, and even a new publicly traded security known as a Natural Asset Corporation is being considered by the Securities and Exchange Commission.
• Direct that BLM must designate new ACECs-Area of Critical Environmental Concern. We already have 70 ACEC’s in Utah, but BLM is required under the rule to designate more, regardless of whether it is necessary. The Rule is intended to be perpetual, meaning that even after doubling that to 140 by 2030 or even 1000, they would still be required to designate more.
• Adding annual reporting requirements to BLM State Directors about their progress in establishing more ACECs is overly burdensome, and will become a great tool to terminate management that is not compliant with establishing more ACECs.
• Establishment of new terms such as the priority to preserve or restore “intact landscapes” without any clear definition of what that means.
• The requirement that decisions be based on “high quality science” will eliminate comments made without expensive science studies may be considered not substantive, which means they don’t have to address them under NEPA.
• Grazing will be seriously curtailed in many more areas, leading to concerns with our food supply and thus potential national security issues.
• Allows BLM to levee fees or taxes without Congressional approval, and under the terms of a lease, those NACs and foreign countries can set their own fees for use of the land.
• The Rule will have a disparate impact on those individuals impacted by the Americans with Disabilities act in emphasizing the priority of wilderness, even though only 3% of visitors are to wilderness areas.

Summary: Ben Burr, Executive Director of BlueRibbon Coalition, has said repeatedly, “we need to start acting as big as we are.”  UPLA’s mission is to protect access for all responsible users, not just a privileged few. All the various users using our public lands may have slightly different beliefs, but we should all join together in fighting for access for everyone and stop the divide and conquer philosophy that detracts from our collective power.

Here are some critical steps you can take to make a difference:

• Take the time to understand land actions and make substantive comments on them. Under FLPMA, if a comment is not made during the open comments period, you do not have standing to bring an action in court. Comments by all users are one of the most important steps you can take as an individual in preserving our joint access. UPLA is organizing a Comments Training Workshop in Salt Lake City the day before SLOREX opens (February 29). Watch for more details and sign up to attend.
• Join groups such as UPLA that fight for access for all users, and when able donate to them to fight for you.
• Share news to others about actions of concern, and plead for your friends to take action. If you see a post or article of interest, share it with your friends.
• Organize or participate with local groups to enhance and protect resources on public lands. Consider stepping out of your particular recreation field and work on other projects of importance to others. Cleanups or repairs are generally welcomed and supported by Land Managers, contact them for approval and assistance. The Utah Department of Natural Resources has a fantastic Grants program that can provide both money and volunteer resources to complete projects in your area.
• Take the Credit! When scheduling a project, be sure to notify your local media about the event with a Press Release. After the event is over, send them photos and a report about how many participated, what was accomplished, and if you know what your next project will be. Email that information to UPLA so we can use it when we need it.
• Don’t Give Up! SUWA is clearly one of our most potent enemies and they are emboldened by our current political climate, we must start to ACT AS BIG AS WE ARE.

Together We Can Win,
But We Can’t Do It Without You!

Loren Campbell

Sources and References:

SUWA 2022 Annual Report

SUWA 2022 Tax Return

BLM Landscape Health and Conservation Rule-UPLA Comments

BLM Landscape Health and Conservation Rule-UPLA link to Rule and Concerns

The National Park Service is accepting comments through January 30 regarding a policy that would require removal of existing anchors or permits for new anchors to be installed in wilderness or areas with wilderness characteristics. The climbing and canyoneering community seems to be somewhat divided on this currently, if you’re a climber, please read the proposal and submit your comments. Please also help UPLA by emailing your comments to me so that I can understand your views better.

UPLA will submit comments before the deadline, but I am tentatively opposed to the rule for the following reasons:

1. The national policy would put extreme pressure on local managers to never approve new installations, or replacement of ones that are failing to avoid liability and lawsuits, thus taking the recent action of closure rather than management.
2. The MRA procedure will discourage user proposals for anchors needed for safety, thus increasing risk to climbers. Liability concerns for park management to permit anchors will raise liability risk concerns, further deterring approval of permits.
3. Permanent anchors are virtually invisible to anyone not looking for them. When I was caving, we often left attached a bright colored strap just so they could be spotted.
4. The policy is not just limited to “wilderness” as designated by Congress, but also includes areas with “wilderness characteristics”
5. Implementation of this policy will inevitably lead to more red tape regarding qualifications of installers, liability of the installer.
6. The Application form is impractical. I assume climbing teams are often put together right before the climb, making it impossible to complete the form accurately. Privacy concerns about personal information in form being made public.
7. Review of the Wilderness Act §4(c) is necessary as to whether it “includes anything made by humans” in Reference Manual 41 §3.1. only appears there and not in Act.
8. I believe local managers or Park Superintendents, are best able to make these kinds of decisions, not a Washington decision.

Here’s the Park Planning Website https://parkplanning.nps.gov/document.cfm…

Here is a recommended template with comments suggested by Instructional Canyoneering Resource

Winter 4×4 Jamboree has always been a great event that UPLA is proud to be a part of, plus it’s been a steady and dependable source of funding for our public land use improvements and fights. This year, Desert Roads and Trails are putting UPLA and Blueribbon Coalition in a prominent location in the main building.

As you know, UPLA recently presented BlueRibbon with a check for $70,000 as a result of donations from many clubs, organizations, businesses, and individuals. Artec Industries recognized this and said they wanted to join the fight.

Artec is donating $10,000 of their product for a sweepstakes benefiting BlueRibbon Coalition during Winter 4×4 Jamboree. Stop by our booth and get your backpack and enter to win and help support the fight to keep trails open.

Artec Industries, renowned for its world-class aftermarket automotive parts, takes pride in supporting off-road enthusiasts. The partnership with UPLA and BlueRibbon Coalition reinforces their commitment to trail preservation, and ensures that the trails we all love remain accessible and well maintained for future adventures.

UPLA has always been proud of the fact that we are an all volunteer organization with no paid employees. Our fight to keep our public lands accessible has increased dramatically in both intensity and complexity, and for this reason the Board of Trustees will soon launch a search to hire a Public Policy Director to lead our efforts in a deep understanding of public land issues, staying informed on proposals being considered, and developing policy statements and comments that represent a balance of all outdoor recreational users.

We are still fine tuning our job description and finalizing our strategy, but following is a draft version.

if you know of someone that might be qualified and interested, please email Loren Campbell.

Public Policy Director Job Description 120523 Draft

The National Environmental Policy Act (NEPA) plays a pivotal role by requiring federal agencies to assess the impact of their proposed actions. One crucial aspect of the NEPA process is the public comment period, during which concerned individuals and organizations can provide feedback on proposed projects. Writing effective comments is a critical step in preserving access for all users to our public lands. UPLA together with BlueRibbon Coalition and Salt Lake Offroad Expo (SLOREX) are partnering to bring you a training seminar on how to write effective comments in NEPA actions.

Understanding NEPA and Public Participation: NEPA, enacted in 1970, aims to integrate environmental considerations into federal decision-making processes. It mandates that federal agencies assess the environmental impact of proposed projects and involve the public in the decision-making process. Public participation is a cornerstone of NEPA, as it recognizes the diverse perspectives and expertise that the public can bring to the table.

The Importance of Effective Comments: Effective comments play a vital role in influencing the outcome of NEPA actions. Agencies are required to consider and respond to substantive comments during the decision-making process, making it crucial for comments to be well-reasoned, fact-based, and relevant to the environmental analysis. Well-crafted comments can highlight potential environmental concerns, propose alternatives, and contribute to a more comprehensive understanding of the project’s impact.

Challenges in Comment Writing: Despite the importance of public participation, many individuals and organizations face challenges in writing effective comments for NEPA actions. Common issues include a lack of understanding of the NEPA process, technical complexities in project documentation, and difficulties in navigating regulatory language. As a result, comments may not effectively convey concerns, suggestions, or alternative solutions.

The Solution: UPLA, BlueRibbon, and SLOREX will be offering free training at the Mountain America Expo Center on February 29, the day before SLOREX opens. The session will be recorded and professionally edited as a valuable online resource we can use in the future.

Save the Date for now and Watch for more information about attending the session.

Today, a coalition of off-road groups took their challenge to the federal government’s arbitrary and illegal closure of over 300 miles of trails near Moab, UT, to federal district court for the District of Utah. The federal court filing follows a ruling by the Interior Board of Land Appeals to deny a stay of the closures earlier this month. Now it will be up to a Utah federal judge to decide whether the trails will remain closed while the litigation is pending, or whether they will be open and available to the hundreds of thousands of Jeepers, mountain bikers, dirt bike riders, and others who have enjoyed them for decades.

The coalition, which consists of the BlueRibbon Coalition, Colorado Off-Road Trail Defenders, and an individual named Patrick McKay, is asking the federal court to issue a preliminary injunction that will allow the trails to remain open while the litigation is ongoing.

“The government has already announced that they would begin re-vegetating, bulldozing, and otherwise erasing these trails the moment they were closed,” said Matt Miller, a Senior Attorney at the Texas Public Policy Foundation and lead attorney on the case. “That is why an immediate injunction is necessary. If these closures are not immediately reversed, there could be no trails left after this litigation concludes, even after the plaintiffs win.”

“The federal government’s closing of these world-class routes ignores the evidence on the ground, the needs of the community, and the rich history of off-road recreation in the area,” added TPPF Attorney Nate Curtisi. “Worse yet, this government overreach was done in violation of a myriad of constitutional and statutory protections that were made specifically to avoid these kind of arbitrary and capricious actions.”

“After reviewing the legal deficiencies with this decision, we committed to our members that we would do everything we can to keep these popular trails open,” said Ben Burr, BlueRibbon Coalition Executive Director. “Now that they are closed and the Bureau of Land Management will get to work erasing these trails from the landscape, the irreparable harm to our members will be difficult to quantify. It’s impossible to place a value on generations worth of traditions, experiences, and meaningful connections to these spectacular lands. The BLM didn’t just close 317 miles of trails, they closed 317 miles of some of the best trails, and we are prepared to do what it takes to keep them open.”

Please show your support to the sponsors of these actions!

Following are copies of both the Lawsuit Complaint and the Injunctive Relief Request

Federal Lawsuit ComplaintMoab-District-Court-Original-Complaint

Moab-Motion-for-injunction